Louvre Hotels Group - UK Tax Strategy

Louvre Hotels Group (“LHG”) is an international hospitality group engaged in hotel ownership, operation, management, franchising and related hospitality activities in a number of jurisdictions.

This UK Tax Strategy sets out the approach of the UK entities of Louvre Hotels Group to the management of their UK tax affairs. This strategy applies to the UK entities detailed in the list below named “UK Entities covered”, including the UK sub-groups headed by HORECO Ltd and KLEMCO Ltd, together with the other UK entities of Louvre Hotels Group identified in that list.
This Tax Strategy is published in accordance with the requirements of Schedule 19 to the Finance Act 2016, including paragraph 19 in respect of the relevant UK sub-groups and, where applicable, paragraph 22 in respect of qualifying UK companies which are not members of a UK sub-group.

The entities covered by this document regard publication of this Tax Strategy as satisfying their respective obligations under Schedule 19 to the Finance Act 2016 for the financial year ending 2026.

Louvre Hotels Group recognises that taxation forms an important part of its responsibilities in the jurisdictions in which it operates.
The UK entities seek to comply with applicable UK tax laws and regulations and to pay the appropriate amount of tax at the appropriate time.

Tax considerations may be taken into account as part of commercial decision-making. However, transactions undertaken by the UK entities are expected to have a genuine commercial rationale and economic substance.
The UK entities seek to apply UK tax legislation in a manner consistent with its wording, purpose and the underlying commercial activities of the business.

Governance

Responsibility for the tax affairs of the UK entities ultimately rests with the relevant Boards of Directors.
The Boards are supported by the relevant finance functions and by the Group Tax function of Louvre Hotels Group.
Day-to-day management of UK tax matters is undertaken by the appropriate finance and tax teams, with significant or unusual tax matters escalated to senior management and, where appropriate, to the relevant Board.

Identification and management of tax risks

Tax risks are considered as part of the Group's financial and business processes.
Particular attention is given to transactions and circumstances which may create material or complex UK tax consequences, including:

• acquisitions, disposals and corporate reorganisations;
• hotel acquisitions or disposals;
• changes in hotel operating, management or franchise arrangements;
• intragroup financing;
• transfer pricing and cross-border transactions;
• management fees, royalties and other intragroup charges;
• VAT;
• employment taxes;
• property-related taxation;
• withholding taxes;
• changes to UK tax legislation;
• significant contracts and restructurings.

Where an issue is considered material or technically uncertain, it is reviewed by the appropriate tax and finance personnel and may be escalated to senior management.
External professional advice may be obtained where appropriate, particularly in relation to complex, material or unusual transactions.

Internal controls

The UK entities seek to maintain appropriate processes and controls in relation to:

• preparation and review of tax returns;
• tax payments;
• accounting information used for tax purposes;
• identification of significant transactions;
• monitoring changes in tax legislation;
• transfer pricing documentation;
• review of uncertain tax positions; and
• communication with HMRC.

The UK entities may make use of exemptions, reliefs, allowances, elections and incentives made available by UK tax legislation where these are relevant to their activities.
In relation to cross-border and intragroup transactions, the Group seeks to apply applicable transfer pricing principles and to ensure that transactions reflect their underlying economic and commercial circumstances.

External advice may be sought where:

• legislation is complex or uncertain;
• a transaction is unusual or material;
• specialist UK tax expertise is required;
• there is uncertainty regarding the interpretation of legislation;
• a significant restructuring or transaction is contemplated.

The UK entities seek to adopt a prudent approach to UK tax risk.
Louvre Hotels Group recognises that UK tax legislation can be complex and that reasonable differences of interpretation may arise.
The Group therefore does not seek to eliminate all tax uncertainty, but aims to ensure that material tax positions are supported by an appropriate analysis of the relevant facts and legislation

The level of tax risk considered acceptable depends on a number of factors, including:

• the amount of tax potentially involved;
• the degree of technical uncertainty;
• the commercial substance of the transaction;
• the likelihood of challenge by HMRC;
• the availability of relevant HMRC guidance or case law;
• the potential financial consequences;
• the potential reputational consequences; and
• the wider commercial implications for the Group.

Material or unusual tax positions may be escalated to senior management or the relevant Board.
Where appropriate, external professional advice may be obtained.

The UK entities seek to maintain an open, professional and constructive relationship with HM Revenue & Customs.

The Group aims to:

• file UK tax returns within applicable statutory deadlines;
• pay taxes within applicable deadlines;
• respond appropriately and in a timely manner to HMRC enquiries;
• provide relevant information requested by HMRC;
• investigate material errors when identified and make appropriate corrections or disclosures;
• engage constructively with HMRC in relation to tax audits and enquiries; and
• seek to resolve differences of interpretation on the basis of the applicable law and the relevant facts.

Where a significant UK tax matter involves material uncertainty, the Group may engage with HMRC where it considers that such engagement is appropriate.
The Group seeks to communicate with HMRC in a transparent manner while protecting applicable legal privileges and commercially confidential information.

This strategy applies to the UK taxes relevant to the activities of the UK entities, including, where applicable:

• Corporation Tax;
• VAT;
• PAYE and employment taxes;
• National Insurance Contributions;
• Withholding taxes;
• Stamp Duty Land Tax and other property-related taxes;
• Stamp Taxes;
• Customs duties; and
• Other taxes and duties administered by HMRC.

This Tax Strategy has been prepared in accordance with Schedule 19 to the Finance Act 2016 and reflects the tax governance principles and practices applicable to the UK entities covered by this Strategy.

The Strategy is subject to formal review and approval by the Boards of Directors of HORECO Ltd, KLEMCO Ltd and Hotels Roma U.K. Ltd.

Formal Board approval is expected to take place in October 2026.
Following such approval, this section will be updated to record the relevant approval dates.

This Tax Strategy is effective for the financial year ending 31 December 2026 and is published in October 2026 for the purposes of Schedule 19 to the Finance Act 2016.

HORECO UK sub-group

Head of UK sub-group: HORECO Ltd

• Camp-Hull Ltd
• Aston Lock Hotel Ltd
• Runbaro Ltd
• Saliwawadon Ltd
• Milcadar Ltd
• Louvre Hotels Group U.K. Ltd

KLEMCO UK sub-group

Head of UK sub-group: KLEMCO Ltd

• Finaco Construction Ltd
• Basildon Hotel Ltd – Dormant
• Dartford Hotel Ltd – Dormant
• Fivest Ltd– Dormant
• Liverpool Ltd Hotel – Dormant
• Newotel Ltd – Dormant
• Runcorn Hotel Ltd – Dormant
• Salford Hotel Ltd – Dormant
• Sheffield Hotel Ltd – Dormant
• Tyne and Wear Ltd – Dormant
• Wrexham Hotel Ltd – Dormant

Other UK qualifying company

Hotels Roma U.K. Ltd strong>