Tax Policy Topland Group of UK Companies’ approach to tax Introduction The Topland Group of UK Companies’ (‘Topland’) principal activity is investment in commercial real estate. Topland is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities. Our commitment is underpinned by the following principles: 1. Tax planning Topland seeks to arrange its affairs in such a way as to ensure that it maximises all available claims and reliefs under UK tax legislation and in the manner in which the legislation was intended. Topland will continue to have a strong focus on compliance with all applicable tax legislation. 2. Relationships with HMRC Topland is committed to working collaboratively and pro-actively with HMRC, through open and transparent dialogue to ensure it is compliant with all of its compliance and filing obligations. 3. Tax risk management Taxation risk is mitigated through internal procedure and the use of specialists where appropriate. Where there is uncertainty over the appropriate tax treatment, Topland will seek specialist external advice or liaise with HMRC around the relevant issue(s) to discuss the appropriate tax treatment. Further to seeking specialist advice, there may still exist inherent risk and uncertainty with regards to a specific treatment. When assessing the level of any remaining risk Topland, will seek to take a balanced approach taking additional third party advice as appropriate. Areas of tax risk are typically highlighted by Topland employees or by external advisers, which are then escalated to the Group Finance Director. The tax risk is assessed, using external advisors where appropriate, and is further escalated to the relevant board of directors where necessary. 4. Governance Tax is the ultimate responsibility of the relevant board of directors. The Group Finance Director manages and implements the group’s approach to tax approved by the relevant board of directors. The Group Finance Director is also responsible for ensuring that policies and procedures that support the approach are in place. Topland’s greatest tax risk areas are identified by considering areas of high value taxation, new and unfamiliar transactions, or transactions with which there exists inherent tax complexity or uncertainty. Internal focus is directed to these higher risk areas, with external advisers also engaged by the group when required. External advisors will be used to support Topland where additional resource or expertise is required to mitigate these tax risks. This tax strategy relates to the accounting year ended 31 May 2019 and has been prepared in compliance with the duty of Topland to publish its tax strategy in accordance with paragraph 16 (2) of Schedule 19 of the Finance Act 2016. DISCLAIMER | CONTACT US © COPYRIGHT TOPLAND GROUP HOLDINGS 2018 TAX POLICY