TRU (UK) Asia Limited
Cannon Place
78 Cannon Street
EC4N 6AF
London, United Kingdom

UK Tax Strategy

Introduction

TRU (UK) Asia Limited (the “Company”) is a holding company of trading subsidiaries throughout Asia, operating retail stores and e-commerce sites under the Toys “R” Us and Babies “R” Us banners pursuant to a Master License Agreement with the brand owner, TRU Kids, Inc.

This statement sets out the Company’s UK Tax Strategy for the year ending 31 December 2021 as required by Paragraph 19 (2), Schedule 19 of the Finance Act 2016.

Approach to Tax and Tax Risk Management

Ultimate responsibility for the Company’s UK Tax Strategy and compliance with tax legislation rests with the Board of Directors who, through the Audit Committee, maintain an active oversight of tax strategy and risk management. The day-to-day management and implementation of our tax strategy and risk management is delegated to the CFO who in turn delegates this to country finance managers and regional office senior finance staff. The CFO escalates tax risks to the CEO and, if significant, external advice from professional tax advisors is sought and a report is made to the Board of Directors.

The Company routinely engages the advice and support of external professional tax advisors to manage tax risk. For example, where new tax regulations have been introduced or where the Company requires clarity on the tax treatment of a particular transaction, it will seek external advice from professional tax advisors to ensure that all tax risks are appropriately managed.

The Company also has a process in place to assess its wider business risks and controls risks and engages external professional advisors to undertake reviews of the effectiveness of its control environment and to ensure they have identified and are appropriately managing risks.

Attitude to tax planning

The Company’s approach to tax is based on full compliance with tax reporting requirements and acting in accordance with relevant tax laws and regulations to pay the correct amount of tax when it is due.

When entering into commercial transactions, the Company considers tax consequences with a view to mitigating tax risks. However, the Company does not undertake tax planning that is contrived or artificial. Where applicable, the Company takes advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation.

Working with HMRC

The Company is committed to maintaining an open and transparent relationship with all tax authorities, including HMRC.

Where the Company is unclear on the interpretation of legislation for tax purposes, it engages with professional tax advisors to clarify the correct treatment, and where appropriate, considers engagement with tax authorities to gain certainty on the approach taken.

December 2021