UK Tax Strategy

Scope

This strategy applies to ALDI Stores Limited and its UK subsidiaries (“ALDI”). The strategy is being published in accordance with Schedule 19 to the Finance Act 2016 and was approved by the Board of ALDI Stores Ltd.

This strategy applies from the date of approval by the Board until it is superseded and relates to the financial year ended 31 December 2018.

References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of Schedule 19 which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.

Aim

ALDI is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The group’s tax affairs are managed in line with the group’s strong focus on corporate responsibility and high standards of governance.

Governance in relation to UK taxation

• Ultimate responsibility for ALDI’s tax strategy and compliance rests with the Board of ALDI Stores Limited.

• Executive management of ALDI is delegated by the Board to the Managing Directors.

• The Managing Director of Finance and Administration (“MDFA”) is the Board member with executive responsibility for tax matters.

• Day-to-day management of ALDI’s tax affairs is delegated to the appropriate Directors within the business, who report to the Managing Directors.

• The Directors with day to day responsibility for tax are appropriately skilled and experienced individuals.

• Advice is sought from external advisers where appropriate.

• The Board ensures that ALDI’s tax strategy is one of the factors considered in all investments and significant business decisions taken.

• The Directors with day to day responsibility for tax will escalate material tax matters to the MDFA who will escalate to the Board, if appropriate.

Risk Management

• ALDI operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system.

• ALDI seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.

• Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.

• Appropriate training is carried out for staff who have responsibility for performing activities that relate to tax processes.

Attitude towards tax planning and level of risk

ALDI manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, ALDI seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. ALDI does not undertake tax planning unrelated to such commercial transactions.

The level of risk which ALDI accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times ALDI seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen.

In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Relationship with HMRC

ALDI seeks to have a transparent and constructive relationship with HMRC through regular meetings and communication in respect of developments in ALDI’s business, current, future and retrospective tax positions, and interpretation of the law in relation to all relevant taxes.

ALDI ensures that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, ALDI discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.