All3Media’s Group Approach to Tax
All3Media is a leading independent television and distribution company. The All3Media Group comprises more than 40 production and distribution companies across the UK, USA, Europe and Asia Pacific. All3Media is owned jointly by Warner Bros. Discovery and Liberty Global.
The All3Media Group’s tax profile is influenced by the dynamic industry in which it operates and a rapidly evolving global tax environment. Its overall tax objective is to comply with all applicable tax laws and regulations, to file all tax returns on time and to pay the right amount of tax when due in each relevant territory where the Group does business. At the same time, it is important that all areas of the All3Media business feel supported from a tax perspective to enable the Group to achieve its commercial objectives. This includes not only managing tax risk, but enabling each of the businesses within the Group to make good investment decisions with the knowledge of all associated tax costs. All3Media also works with its operating companies to claim any appropriate tax incentives that are available in the territories that it operates, for example TV production tax credits in the UK and other jurisdictions.
The taxes paid by the Group include corporate income tax, employment taxes and stamp duties. All3Media also collects significant amounts of indirect taxes and employment taxes on behalf of the tax authorities.
No furlough funds were claimed from the UK Government during the COVID-19 pandemic.
All3Media is committed to conducting its business with integrity and to the highest standards of corporate governance. Group policies and procedures apply to all employees, directors and officers and governs its approach in relation to accounting, reporting, taxation and disclosure matters.
The tax strategy of the All3Media Group is reviewed and approved annually by both the Group’s Executive Team (the “Executive Team”) and the Group’s Finance and Controls Committee (“F&CC”) which includes representatives from both Liberty Global and Warner Bros. Discovery. Under the supervision of All3Media Group’s CFO, the Group Head of Tax is responsible for delivering the tax strategy.
In accordance with All3Media Group’s governance procedures, all relevant tax matters are required to be reviewed and approved by the Executive Team and the F&CC. [The F&CC is required to approve transactions in line with the shareholder governance procedures.Delivery of the Group’s tax strategy is underpinned in each of the Group’s production and distribution companies by a Head of Finance who is responsible for implementing appropriate processes and controls as regards both finance and tax. An annual review of these controls forms the basis for the annual certification carried out by the Senior Accounting Officer. Another important element of All3Media Group’s approach to tax governance and risk management is to ensure that appropriate skills and tax knowledge are contained within the Group and that external tax and legal advice is sought when needed.
Tax Risk Management
Tax risks are assessed based on the amounts at stake and the potential reputational impact. The reputation of All3Media is of critical importance and this is taken into consideration when decisions are taken which have significant tax implications. Where complicated matters arise, input is sought from external advisers and from HMRC. The Executive Team has oversight of how tax risks are identified and managed and All3Media Group’s Head of Tax reports to the F&CC on a regular basis.
All3Media Group may consider different tax outcomes when considering how to structure commercially motivated transactions but does not undertake aggressive tax planning with a purpose of avoidance. We understand the importance of corporations not willfully engaging in tax schemes that go against the intention of legislative authority. When undertaking tax planning, the Group complies with all relevant tax laws and regulations. It carefully considers the tax analysis and risks involved and ensures that any tax planning is approved through governance and risk management procedures.
Where necessary advice is sought from external tax and legal advisors, typically where significant amounts of tax are involved and where the application of tax laws and regulations are complex, new or unclear. Clearances and rulings from the relevant tax authorities are also sought where relevant. Companies in the All3Media Group will apply to take benefit of tax incentives introduced by governments or regulatory authorities to stimulate investment, for example TV production tax credits in the UK and other jurisdictions. When companies in the Group sell or provide assets or services to each other, these transactions take place on arm’s length terms in accordance with OECD guidelines.
Relationships with HMRC
All3Media Group seeks to maintain a transparent and productive relationship with HMRC. Regular meetings are held to give updates on business developments and to discuss any relevant changes to tax legislation.
If significant issues arise, the Group will discuss these promptly with HMRC and also seek to respond to requests for information promptly and to engage with HMRC in a constructive manner as it is felt that this is the best way to resolve issues and to minimise uncertainty.
This statement was approved on 29 September 2022 and is published to comply with the requirements of Finance Act 2016, Schedule 19.