This policy statement covers the UK operations of Seminole HR Holdings, LLC (“Hard Rock” or the “UK Group”) and is intended to satisfy the UK tax strategy publication requirement under Paragraphs 19 (2) and 22(2) of Schedule 19 to the Finance Act 2016 in respect of the period ended 31 December 2021. The strategy below applies to taxes in the UK.
The responsibility for Hard Rock’s tax strategy, risk and the supporting governance framework is the responsibility of the Chief Financial Officer (“CFO”). Day to day responsibility for these functions sits with the Vice President of Tax (“VP-Tax”) who reports to the Senior Vice President of Finance (“SVP-Finance”). The Hard Rock Corporate Tax department consists of qualified and experienced tax professionals who work closely with the global accounting and finance groups.
Hard Rock has internal procedures and compliance programs to ensure Hard Rock meets its tax compliance responsibilities. Those procedures are reviewed and tested by external audit groups.
Hard Rock requires every employee to certify annually their commitment to Hard Rock’s Code of Conduct which stresses Hard Rock’s commitment to ethical, transparent and responsible behaviour.
Hard Rock provides support to the businesses by recruiting sufficient, highly trained, experienced staff specializing in both tax and finance matters. We are committed to conduct our tax affairs to the highest standards and in line with the Hard Rock Code of Conduct and to comply with all applicable anti-bribery, money laundering and anti-tax evasion legislation.
The tax strategy of the UK Group is to comply fully, within the intent of the UK tax laws while aligning our tax planning with business objectives to create and protect shareholder value. The tax planning undertaken by the UK Group seeks to reflect the commercial realities of our business operations taking account of potential tax costs, benefits and risks of proposed transactions, ensuring appropriate information is obtained to fully discharge the UK Group’s compliance requirements. Hard Rock will not undertake any tax planning that does not support the business objectives and commercial requirements of the group and does not have economic substance. Hard Rock will not undertake any tax planning unless Hard Rock believes that the strategy is compliant with tax legislation. Hard Rock will claim properly available UK allowances, deductions, reliefs, credits and incentives in conjunction with our tax planning.
The Corporate Tax Department pro-actively manages, reviews and reports on tax risks and employs an experienced tax team, primarily based in the US, which is part of the central finance function.
The Corporate Tax Department, along with the UK Group finance department, is accountable for day-to-day management of UK tax matters. Any decisions to be made in respect of uncertain tax issues will be subject to diligent professional care and judgement by the Corporate Tax Department.
Tax advice is sought from external advisors in relation to material uncertain transactions or where the tax department does not have the level of expertise required in a particular area. Any tax information, memorandum, and/or opinions received are in addition to and not a replacement for professional judgement to be exercised by Hard Rock. Filing positions not supported by a strong technical position are not adopted.
Despite following the above principles, it is inevitable, in such a fast changing international environment, that there will be instances where there is a degree of uncertainty and hence tax risk in relation to transactions or activity.
Hard Rock cooperates with HMRC in an open and constructive manner, with the highest degree of integrity, in order to foster cooperation, trust and pro-active discussion with HMRC regarding any tax issues.