For the Financial Year Ending 30 June 2025

This strategy applies to Vinarchy UK Group (previously Accolade Wines UK Group). References to ‘VUK’ or ‘the group’ are applicable for all the entities in the Vinarchy UK Group. The active group companies are listed at the end of the document.

This strategy is in force from the publication date. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of Schedule 19 of the UK Finance Act 2016, which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Customs duties, and Excise duties.

VUK regards this publication as complying with paragraph 16, Schedule 19 of the UK Finance Act 2016.

HOW WE MANAGE OUR TAX AFFAIRS

Tax compliance and governance

VUK is committed to ensuring it is in compliance with all UK tax laws
and regulations.  This includes:

• Paying the right amount of tax in compliance with all UK tax laws and regulations, as well as local laws and regulations for all jurisdictions that VUK has a tax obligation.
• Preparing all relevant filings in accordance with the laws and regulations of each jurisdiction in which VUK has a tax compliance obligation and lodging them in accordance with the timeframes as set by the local authorities.

Tax risks are managed by the tax team within the finance function, with clear review and reporting processes to ensure appropriate governance at each level of the group. The ultimate responsibility for tax risk management rests with the Board of VUK group, which delegates the execution of the tax strategy to the Executive Leadership Team.

Attitude to tax risks and risk management

VUK has a strong focus on tax compliance and aims to reduce its tax risks as far as reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligation.

Tax risks are assessed on an ongoing basis, including any new business transactions, and are reported to the Chief Financial Officer via regular updates.

VUK has processes and systems in place to ensure tax review is sought for non-standard or new business transactions. The tax impacts of any such transactions are reviewed as early as possible to consider the associated tax implications. There is also an additional control where material contracts are reviewed by the legal team and where relevant, referred to the tax team to ensure tax risks are considered and managed before execution.

Where there is uncertainty on the application of tax law, external advice is obtained, and where appropriate, discussions with HMRC are entered into, to assist with the group’s decision-making process and support the tax treatment adopted.

Measures proportionate to the level of tax risks are implemented to manage the risks. For example, VUK has implemented comprehensive processes for customer due diligence in order to assess alcohol fraud risk, which is one of the main tax risks for VUK.

Tax planning

The Group’s appetite for tax risk is determined by a desire to achieve certainty in its tax affairs. It does not undertake transactions that do not reflect commercial reality. Where appropriate, it will take advantage of exemptions, reliefs, and tax incentives consistent with and in the spirit of the relevant legislation. Professional advice is obtained by VUK on international related party transactions to ensure compliance with OECD guidance, local tax laws and regulations, and that these are undertaken on an arm’s length basis.

Working with HMRC

VUK has an open, honest, and transparent working relationship with HMRC. We work closely with our HMRC team to discuss and agree compliance requirements and processes to manage and control tax risks relevant to the VUK Group, provide business updates, and to share information where appropriate.

VUK proactively engages in regular communications with HMRC through the HMRC Customer Compliance Manager and the HMRC tax specialists. VUK enters into real-time discussions with HMRC to agree on the tax treatment of current and proposed activities, and to resolve queries.

Publication date: 27 06 2025

List of active UK entities this tax strategy applies to:

• Australian Wine Topco Ltd
• Australian Wine Holdco Ltd
• Amphora Intermediate II Ltd
• Amphora Finance Ltd
• Amphora Australia Holdings Ltd
• Vinarchy Holdings Europe Ltd (previously Accolade Wines Holdings
  Europe Ltd)
• Vinarchy Europe No 2 Ltd (previously Accolade Wines Europe No 2 Ltd)
• Western Wines Holdings Ltd
• Avalon Cellars Two Ltd
• Vinarchy UK Ltd (previously Accolade Wines Ltd)