Kew Green Hotels Tax Strategy

Kew Green Hotels Tax Strategy

The Group is a leading international hotel management company with over 55 hotels in their portfolio.

The Kew Green Hotels UK Group (“The Group”) consists of thirty-nine UK companies and one nonresident landlord company subject to corporation tax. CTG Metropark Limited is the parent of the UK
group with ultimate control residing in China.

UK Tax Strategy

This document sets out The Group’s approach to conducting its tax affairs and dealing with tax risk for
the year ending 31 December 2023.

The Group takes a conservative approach to tax planning and does not pursue aggressive tax planning
arrangements. Reliance is placed on external tax advisors where there is a need for specialised
guidance and support.

The Group's corporate objectives are to maximise shareholder value while also valuing and respecting
the broader community in which it operates. The Group takes all aspects of corporate responsibility
seriously and acts with honesty and integrity, including in its tax affairs. The Groups tax strategy is
aligned with its overall corporate ethos and commitment to responsible behaviour and high ethical
standards while operating a profitable business for the benefit of its stakeholders. The Group has
committed to achieving Net Zero by 2040, ten years ahead of the Paris Accord's target, and is taking
decisive action to mitigate the climate crisis and future-proof its business. The company's vision is
shaped by the recent UN IPCC "code red warning for humanity," which confirms the link between human
activity and the climate crisis.

This tax strategy document has been approved by the Board and is published in accordance with
paragraph 19(4) of Schedule 19 of the UK Finance Act 2016.

Risk Management and Governance Arrangements

The Group is committed to ensuring that its tax affairs are transparent and compliant with all tax laws
applicable in the UK and are in line with international best practices (e.g. OECD Transfer Pricing

Ultimate responsibility for the tax affairs of The Group sits with the Board of Directors. The Board of
Directors understand the importance of tax compliance and how it is achieved.

The Group has an in-house financial team who are responsible for the day-to-day activities and for
ensuring tax compliance across the group along with the support of external tax advisors. Tax
provisions are prepared early in the year by the financial management team, reviewed and amended
as required by external tax advisors before being subject to inspection as part of the audit process.

The Group seeks support of UK external tax advisors for ensuring the UK company complies, in an
accurate and timely manner, with all applicable tax laws and regulations, including:

- filing all mandatory tax returns, reports and disclosures;

- paying all direct and indirect taxes, levies and duties by the due date;

- maintenance of the proper records and documentation to support the tax filings;

- utilising, as appropriate, available tax reliefs and incentives. The Group will not, however, use such reliefs and incentives for purposes which are knowingly contradictory to the intent of the legislation. 

With reference to non-current or extraordinary transactions or operations, the tax consequences and
risks are identified by the financial management team or The Groups external tax advisors. Reliance
is placed on external tax advisors where there is a need for specialised guidance and support.

The wider group supervises the commitment of the UK companies in ensuring that it complies with the
group policy. The strategy aims to minimise the UK level of risk which, together with strong internal
controls, substantially reduces the tax risk to materially acceptable levels..

Attitude Towards Tax Planning (In The Contact of UK Taxation)

The Group tax planning approach reflects the strategy adopted at the worldwide group level.
The wider group has a small presence in the UK with the majority of its operations arising outside the

The Group takes a conservative approach to tax planning and does not engage in tax planning
arrangements where there is considered to be a risk of challenge by HMRC. The Group aims to
ensure full disclosure and be transparent about the filing position that it has taken.

The Group’s tax planning aims to support the commercial needs of the business. External advisers
provide appropriate input into business proposals to ensure that there is a clear understanding of the
tax consequences of any decisions made.

External tax advice is also sought with respect to areas of complexity or uncertainty in relation to
current tax legislation. Advice may also be sought from HMRC directly for assistance in interpretation
or application of tax legislation.

The Group's Approach Towards Dealings With HMRC

The Group ensures an open, cooperative, and professional approach in its relationship with HMRC.

Due to the relatively small size of its UK operations, it does not have a customer compliance
manager. However, this is being considered moving forward as the business continues to expand.

The Group is committed to:

- Making fair, accurate and timely disclosures in correspondence and returns, and responding to queries and information requests in a timely fashion;

- Seeking to resolve issues with HMRC in a timely manner, and where disagreements arise, to work with HMRC to resolve issues by agreement where possible;

- Being open and transparent about decision-making, governance and tax planning;

- Structuring transactions in order to give a tax result which is not inconsistent with the economic consequences (unless specific legislation anticipates that result), nor contrary to the intentions of Parliament; and

- Interpreting the relevant laws in a reasonable way and ensuring transactions are structured consistently. Where appropriate, pre transaction clearance from HMRC will be sought.