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Premium Credit Tax Strategy Statement

Premium Credit Limited (‘PCL’), the Group’s principal trading subsidiary, provides instalment finance solutions, supporting the purchase of insurance policies and other services to corporates and individuals in the UK and Ireland. Strong corporate governance is critical to maintaining stakeholders’ confidence and as such the Group is committed to complying with UK tax law, regulations and practices. For the Group, compliance means accurate payments of tax in line with the applicable laws, regulations and practices. It also involves disclosing relevant information to the tax authorities and where available claiming reliefs and incentives. Our overarching aim is to minimise any regulatory risk within our business, which includes taking a consistent low-risk approach to tax compliance risk, both in financial and reputational terms. We are fully committed to compliance with our tax obligations.

Tax risk management and governance

Tax risks are assessed against the same risk matrix criteria as any other risks, financial or otherwise, within the Group. The main assessment criteria include the potential impact on our reputation, our customers, financial results, legal and regulatory requirements, management effort and business interruption. Responsibility for the tax strategy, the supporting governance framework and management of tax risk ultimately sits with the UK Board and the Chief Financial Officer and is overseen by the Audit Committee, who ensure that tax decisions are made with appropriate diligence and accountability.

The key risks and controls for PCL in the UK are highlighted below:

Tax compliance and reporting risks: PCL is committed to meeting all statutory requirements with regards to its payment, filing and reporting obligations, and maintaining positive working relationships with the respective tax authorities based on trust, transparency and open and professional dialogue. The tax effects of business initiatives, transactions and commercial developments are considered in advance and appropriate advice and support provided for the implementation of business changes. Identifying and supporting implementation of business changes, whilst only undertaking tax planning in association with wider commercial transactions. Tax planning arrangements are considered for larger commercial transactions, however where having no purpose, other than tax avoidance, arrangements will not be entered into.

As with all businesses, PCL has the risk of submission of late or inaccurate returns and payments. In order to mitigate this risk, PCL have implemented robust internal controls and reviews, and use external professional tax advisors to advise on or prepare the UK Corporation tax filings. The type of taxes we pay are corporate income taxes, VAT, employment and other indirect taxes.

Transaction risks: the risk of transactions carried out or actions taken without appropriate consideration of the potential tax consequences: A detailed risk assessment is undertaken for all material business changes (i.e. business changes, new products). As part of this assessment, tax risk is assessed by external professional tax advisors to ensure all tax risks are assessed and addressed.

Legislative change risk: Legislative tax changes pose risk to our business and to ensure this risk is mitigated, we receive regular updates from our tax advisors and attend industry seminars. Our tax advisors are then engaged where necessary.

Tax risk appetite

PCL has a low-risk appetite for all business risks, including tax. As such, PCL is committed to ensuring it complies with not only the letter of the law, but also the intention of parliament, whilst maintaining value for its shareholders. This is achieved through segregated responsibilities within the businesses for tax compliance and liaising with a professional external recognised tax expert.

Our approach towards tax planning

PCL aims to be efficient with tax planning, including taking advantage of any government tax reliefs and incentives, such as Research & Development Expense Credits, in order to maximise value on a sustainable basis for the Group and its shareholders. However, any structuring that is undertaken must have commercial and economic substance, and PCL does not put in place any arrangements that are contrived, artificial or unlawful. Where tax planning is undertaken, we consult professional external tax advisors to ensure that the tax technical interpretations are fully aligned to our risk appetite.

Relationship with HMRC

In the spirit of cooperative compliance, PCL engage with HMRC with honesty, integrity, respect and fairness in an open and transparent manner. We do not take positions on tax that may create reputational risk and seek to resolve any issues with HMRC through proactive engagement and transparent discussion wherever possible.

We consider that the above statement complies with PCL’s obligation under paragraph 16(2) and paragraph 25 (1) of Schedule 19 Finance Act 2016 for the year ended 31 December 2025.

Paragraph 16(2) requires that a qualifying company or group must publish its UK tax strategy for the relevant financial year on the internet, in a way that is freely available to the public.

* The strategy must remain accessible until the next strategy is published.
* The publication must be in the financial year to which it relates.
* Paragraph 25(1) sets out the penalty regime for non-compliance.

This statement applies to all Group companies, including the principal trading subsidiary Premium Credit Limited (‘PCL’), which is based in Leatherhead, UK and is a UK registered and domiciled company. All employees are employed by PCL.