17 DECEMBER 2025
The following information is provided as satisfying HeadFirst Global plc’s (“HeadFirst”) requirements under Paragraph 16(2), Schedule 19 of Finance Act 2016, to publish its tax strategy in relation to the 2025 financial period ended 31 December 2025.
The tax strategy is approved, owned and overseen by the Board.
HeadFirst is a responsible taxpayer, committed to complying with the Group’s global tax obligations. The Group acts in accordance with the applicable tax laws and regulations in all territories in which we operate, including the UK, and strives to pay and report the right amount of tax in the right territory at the right time.
In the UK, the Group’s total tax contribution includes VAT, Corporation Tax, Employment Taxes, Social Security contributions, and the Apprenticeship Levy as well as other taxes.
The Group Chief Financial Officer (“Group CFO”) has overall responsibility for overseeing tax strategy, management of tax risk and the underlying tax control and governance framework. This responsibility includes the appointment as Senior Accounting Officer in the UK.
The Group Head of Tax, who reports to the CFO, has day-to-day responsibility for these areas and is responsible for the management of tax compliance and tax risks across the Group. The Group Head of Tax provides the Group CFO with regular updates on the Group’s tax obligations and any potential tax risks.
The Group Head of Tax leads an in-house team of tax professionals and engages professional services providers for tax advice as appropriate. The Group Tax team, which is based in the UK, has regular dialogue with other areas of the business, including finance and operational teams, to ensure tax matters are considered on a timely basis.
The Group’s Delegation of Authority, which has been approved by the Board, governs material decisions made by the Group and ensures Group Tax has oversight and input before approval of any decisions is given.
The Group’s tax control and governance framework seeks to ensure the Group’s processes and controls are designed to minimise unnecessary or disproportionate risks and any risks are identified and assessed in a timely manner.
Where an interpretation of tax law may be required, or where we don’t have the necessary technical expertise, external advice from leading professional services firms will be sought. External advisers may also be used for periodic reviews of key tax filings.
The Group has a low-risk approach to tax and does not enter into artificial tax arrangements on the basis that any tax decisions taken are aligned with the commercial and economic activities of the Group’s operations. The Group claims tax reliefs and incentives as available under tax legislation, but transactions are not entered into for the sole purpose of tax avoidance.
The Group’s relationships with tax authorities are based on openness, honesty and integrity. In the UK, the Group CFO and Group Tax team interact regularly with HMRC via the Group’s Customer Compliance Manager to discuss tax affairs on a real-time basis. We take a collaborative approach in all interactions with tax authorities and seek to make accurate and timely disclosure in correspondence and returns.