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This document, which has been approved by the Board of Directors of Lakeshore Lending Limited (“LL”), provides an overview of the tax strategy, tax policy and risk management of LL. The strategy is prepared in accordance with the requirements of Schedule 19 of the Finance Act 2016, and is effective for the accounting period 1 February 2018 to 31 January 2019 for LL and its subsidiary AG Retail Cards Limited (“AGRC”).
LL is the intermediate holding company of AGRC which trades under the Clintons’ trading name. Both LL and AGRC are UK incorporated and tax resident. During June 2018 the ownership of LL changed. LL ceased to be a wholly-owned subsidiary of American Greetings Corporation (“AG”), and has been a wholly-owned subsidiary of Clintons Holding Company LLC (a company registered in the United States of America) since April 2018.
We are committed to being a responsible business in all aspects, and paying the right amount of tax, at the right time, is a fundamental principle of our operation.
We consider our tax affairs to be transparent and compliant with tax legislation. We, however, recognise that tax compliance is increasingly complex. Complete elimination of tax risks (being the erroneous application of tax rules or calculations within tax returns) is impractical, as such, LL and AGRC’s assessment of the level of control required over the processes designed to reduce these tax risks is driven by the likelihood of occurrence and the scale of potential outcome.
We seek to identify, evaluate, monitor and manage these risks to ensure they remain consistent with our objectives. There is very close liaison with our professional advisors, from whom advice is sought on all tax-related matters, in particular where there are issues of uncertainty or complexity. Prior to the change in LL’s ownership in April 2018, there was also a close working relationship with AG’s tax department on group-related matters that impacted LL and / or AGRC.
The Company will avail itself to tax relief and allowances as permitted by law, however, we will not engage in tax schemes that are contrary to the clear intentions of tax legislation.
We will use tax planning within the confines of the above and the intent of such planning will support the overall business strategy, as well as ensure that commercial transactions are structured in a tax-efficient way. Consideration will be given in arriving at such tax planning decisions, to ensure that such decisions would not adversely impact on our reputation with our stakeholders.
We use external tax advisors to ensure that we receive the necessary technical guidance to ensure these tax planning concepts are adhered to.