STRICKLAND TRACKS LIMITED – TAX STRATEGY UK

STRICKLAND TRACKS LIMITED (hereinafter also “Strickland”) is a UK Company of the ITR Group. 

ITR (hereinafter also the “Group”) is an Italian multinational group engaged in the production and distribution of spare parts for earthmoving machinery (i.e., undercarriage, ground engaging tools (GET), and repair parts). 

The current configuration of the Group started in 1993, when USCO’s acquisition of ITR was finalised, with the simultaneous transformation of USCO S.p.A. (operating holding) into a player capable of producing and distributing its products worldwide. 

Numerous acquisitions have been made over the last decade, as a result of which the Group has taken on an articulated structure, which currently sees USCO S.p.A. directly and indirectly controlling many companies active in sectors complementary to and/or functional to the core business. 

The Group includes both manufacturing and distribution companies, located in Europe, North America, South America, Africa, the Middle East, Asia, and Australia. 

The Group also operates in the UK market with two sub-groups, namely Midland Steel Trader (MST) and Strickland. 

This tax strategy refers to the Strickland sub-group. 

Strickland Tracks is leader in Undercarriage Track Systems. The company manufacture and supply a complete range of steel and rubber track solutions for the entire spectrum of crawler machine applications, covering Agricultural, Recycling, Material Processing and Construction vehicles. 

The tax strategy is inspired to the following tax goals

1. “Tax Value” 

Efficiently manage the tax costs linked to business activities, by making use of available government incentives and relief in a manner which fully complies with both the letter and spirit of the law and reflects commercial transactions. 

2. Risks and Reputation 

Controlling and managing risks and preserve the Group's reputation through appropriate business practices and procedures. 

3. Tax Compliance 

Ensuring integrity in tax compliance and the correct determination of taxes, according to related deadlines and requirements. 

4. Virtuous corporate culture

Promote awareness at all company levels of the importance attributed by the Group to the values of transparency, honesty, correctness and compliance with the law; to the diffusion of a culture of "control"; and to the principles of corporate social responsibility.

5. Good faith and transparency in relations with the tax authorities

Develop and strengthen the personal and professional skills of the resources involved in the tax processes and in the management of the associated risks

6. Enhancement of internal resources

Establish relations with the tax authorities based on good faith, transparency and collaboration, so as to be recognised as a reliable counterparty.

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1. The approach of the Group to risk management and governance arrangements in relation to UK taxation

For proper fiscal risk management, the Group relies on business procedures and established business practices. This includes processes for assessing and addressing the tax implications of business decisions, ensuring compliance with UK tax laws.

Tax considerations are part of everyday operational decisions.

The responsibility for tax governance is on the finance department.

Employees, especially those involved in finance and management, are trained in the essential aspects of UK taxation. This empowers them to recognise and address tax-related issues within their roles.

To be compliant with UK tax regulations, the Group also rely on external consultants for complex tax issues or for staying updated with the latest tax laws and practices in the UK.

The Group maintains documentation and record-keeping practices to support tax compliance. This includes keeping detailed records of transactions, decisions, and justifications related to tax matters.

Risk assessments are conducted with the support of the Group tax advisors to identify potential tax risks and proactively mitigating them before they materialise.

This dynamic approach ensures ongoing compliance and effective risk management.

2. The attitude of the Group towards tax planning (so far as affecting UK taxation)

The Group does not participate in aggressive tax planning, or tax practices and strategies that abusively erode its tax base. The Group avoids transactions that lack business substance or are designed to gain undue tax advantage.

Working closely with external tax advisors, the Group seeks their counsel in situations where tax matters are ambiguous, open to different interpretations, uncertain, or when the in-house employees require additional expertise to evaluate tax risks.

The Group may access to tax incentives, reliefs, and exemptions which are always aligned with its commercial objectives and compliant with both the literal and intended spirit of the law.

3. The level of risk in relation to UK taxation that the Group is prepared to accept

The Group has a low appetite for tax risk in the UK and refrains from engaging in transactions that do not align with its business goals or lack a legitimate commercial basis. It proactively seeks clarity regarding its tax positions in the UK and strives to prevent needless disputes related to taxation. In pursuit of this, the Group is committed to adopting tax positions that are not only technically robust but also backed by thorough analysis, advice, and sufficient documentation to substantiate these positions.

4. The approach of the Group towards its dealings with HMRC

The Group is committed to conducting its interactions with HMRC with complete integrity and transparency. It adopts a proactive and cooperative approach to ensure compliance with all legal obligations and to pay the correct amount of tax. The Group holds the view that maintaining a positive relationship and collaborating effectively with Tax Authorities is the most effective strategy for managing reputational risk.