UK Tax Strategy

Superstruct Entertainment (hereafter also referred to as “Group” or “We”) is a global platform of premium live music festivals and music events. Superstruct Entertainment is aware of its corporate responsibility and recognizes that collecting and paying tax is an important contribution to the economies and societies in which its various businesses areoperating. As such, Superstruct Entertainment is committed to comply with all applicable tax laws and regulations, acting with integrity and transparency in its tax affairs, and ensuring that its Tax Strategy reflects a dedication to responsible tax practices.  

This UK Tax Strategy outlines Superstruct Entertainment ’s approach to managing its UK tax affairs and it applies to all UK group companies that are direct and indirect subsidiaries of Superstruct Entertainment.

Superstruct Entertainment considers that the information contained within this UK Tax Strategy and the publication thereof on our website, is compliant with the requirements of Section 161 and paragraph 16(2) of Schedule 19 of the Finance Act 2016, and is applicable for the financial year ending on 31 December 2024. This UK Tax Strategy is reviewed periodically, and applies from the date of publication until its superseded.

1. Our Approach to Tax Risk Management and Governance

Risk management is a core discipline at Superstruct Entertainment, whereby we follow a methodical approach towards the identification and management of risks within the Group. Tax risk management is part of this broader risk management framework. In this respect, Superstruct Entertainment adopted rigorous tax due diligence practices to identify, assess and mitigate all types of tax risks within the Group.

Superstruct Entertainment’s governance structure ensures that tax matters of the Group receive the proper level of attention and that any significant tax risks are properly addressed. Its governance framework is structured as follows:

• Superstruct Entertainment’s tax function is under the supervision of Superstruct Entertainment’s senior management, who is ultimately responsible for establishing, reviewing and adapting the broader control processes for governance, risk management and compliance within the Group.
• The responsibility for the Group’s tax strategy and overall tax risk management is delegated to the Director of Tax of Superstruct, who directly and regularly reports into senior management on tax matters. This is to ensure any significant identified tax risks are escalated to senior management for review and resolution, as well as ensuring that tax is one of the factors considered in all Superstruct Entertainment’s material investments and business decisions.
• The Director of Tax is responsible for the day-to-day management of tax compliance, planning & reporting within the Group, including in the UK. The Director of Tax is supported by a dedicated tax team and works in close coordination with the various business units. Subsequently, local management of each entity is individually responsible for ensuring that all applicable tax regulations, as well as internal governance procedures, are observed.
• Superstruct Entertainment furthermore engages external tax professionals from reputable firms to ensure that its tax affairs are managed in compliance with tax legislation, and that any tax risks are properly identified and mitigated at the highest standard.

2. Our Approach towards Tax Planning

Superstruct Entertainment’s approach to tax planning is driven by the need to support business operations while ensuring full compliance with UK tax legislation, within the spirit and letter of the law. Superstruct Entertainment adheres strictly to all relevant tax laws and does not engage in aggressive tax planning or artificial arrangements that lack genuine commercial purpose.

We maintain a zero-tolerance approach to tax evasion or the facilitation of tax evasion. This has been laid down in our Code of Conduct, which implements procedures and controls to prevent any person acting on behalf of Superstruct Entertainment from facilitating tax evasion. Everyone working for Superstruct Entertainment shares a responsibility to follow the Code of Conduct and to work with integrity.

By ensuring that tax-related decisions are grounded in sound commercial principles, with a focus on transparency and ethical considerations, Superstruct Entertainment maintains an open and honest approach to tax affairs, ensuring that all activities are fully compliant and align with the Superstruct Entertainment’s corporate values and the expectations of stakeholders.

To achieve this, Superstruct Entertainment also regularly seeks professional advice from independent tax advisors on complex tax matters and significant transactions, in particular where the tax treatment of certain transactions undertaken by the business are complex, unclear or uncertain under UK tax law. This enables us to evaluate the tax implications and risks related to potential transactions to ensure that we stay within our risk appetite.  

3. Our Attitude towards Tax Risks

Superstruct Entertainment recognizes that over the years, tax laws have become increasingly complex and constantly subject to change, which creates heightened risk and uncertainty. It is therefore critical that we continuously assess how we can ensure compliance with the tax regulations of the jurisdictions in which we operate, including in the UK.

Superstruct Entertainment takes a prudent and low-risk approach to managing its UK tax affairs and aims to minimize the tax risks to the lowest extent. Superstruct Entertainment’s low risk tolerance is set by senior management, who are conscious that negative publicity attracted by a poor attitude towards tax could have material adverse effect on its reputation and relationship with His Majesty’s Revenue and Customs (“HMRC”) and other key stakeholders, including its shareholders, employees and customers.  

To uphold its low tolerance towards tax risks, Superstruct Entertainment has implemented strong internal policies and processes, including our Code of Conduct, in order to ensure compliance with UK tax regulations and that any tax risks are identified and managed swiftly to acceptable levels.

4. Our Relationship with His Majesty’s Revenue & Customs (HMRC)

Superstruct Entertainment is committed to comply with all UK statutory tax obligations, filing requirements and/or tax disclosures required by HMRC.

Superstruct Entertainment values a cooperative and transparent relationship with HMRC, engaging in open and constructive dialogue, providing timely and accurate information, and promptly responding to any queries if such queries would be raised. The Group's approach to dealings with HMRC is characterized by mutual respect and commitment to resolve any disputes amicably and efficiently.

By fostering an open and transparent relationship with HMRC, Superstruct Entertainment aims to build trust and ensure that tax affairs are managed in a responsible and compliant manner.

Approved by the Board of Directors

Date: 24 December 2024