In accordance with the requirements of paragraph 16(2) of Schedule 19 of the Finance Act 2016, the JD Group presents its Tax Strategy for JD Sports Fashion Plc and its subsidiaries for the period of account to 1 February 2025. The Strategy applies to all taxes across the Group and was approved by the Board of Directors on 23 January 2025. The Strategy is reviewed on an annual basis.

The JD Group is a leading multichannel retailer of sports and outdoor fashion brands. The business is a significant contributor and collector of taxes both in the UK and overseas, including employment taxes, corporate income taxes, indirect taxes and property related taxes.

The JD Group takes a responsible approach to the management of taxes and aims to work transparently and collaboratively with all stakeholders.

The purpose of this Tax Strategy is to set out the JD Group’s principles and approach to tax, in adherence with that of Pentland Group Limited, being its parent company.

Attitude Towards Tax Planning

The Group is committed to paying the right amount of tax, in the right place, at the right time. It recognises the importance of respecting the spirit and letter of the law including allocating value by reference to where it is created, managing it within the normal course of commercial activity and paying the associated tax.

When structuring commercial activities, consideration is given, along with other factors, to the prevailing tax laws in the relevant jurisdiction.

Any tax planning undertaken has commercial and economic substance and will utilise available tax incentives, reliefs and exemptions in line with, and in the spirit of, the governing tax legislation. The JD Group adopts a low risk approach to tax planning and does not engage in artificial tax arrangements.

Intra-group transactions are conducted on an arm’s length basis and comply with the obligations of the transfer pricing rules in the jurisdictions in which it operates and under global transfer pricing principles.

The JD Group does not use tax havens to manage taxes and has a zero tolerance approach to tax evasion.

If an entity in a tax haven is acquired as part of a wider acquisition, this structure will be unwound at the first available opportunity.

Level of Tax Risk Accepted

The JD Group is a multinational organisation and as such may be exposed to a variety of tax risks.

The Group has a low risk appetite and is graded “low risk” by HMRC in the UK.

Its approach is to identify, evaluate, manage and monitor tax risks on a regular basis.

Where there is uncertainty or complexity in relation to how the tax legislation is to be applied, advice will be sought from external advisors and discussed with the relevant tax authority.

Approach to Dealing with Tax Authorities

The JD Group is committed to working in an open, collaborative and transparent way with all tax authorities in the countries in which it operates to minimise the risk of challenge and dispute. It responds to all tax authority enquiries in a timely manner.

In the UK, the Group is in regular dialogue with its Customer Compliance Manager at HMRC to update them on significant transactions, changes in the business and to seek advice in respect of any tax issues/areas of uncertainty.

Governance Arrangements

The JD Sports Fashion Plc Board approves the overall JD Group Tax Strategy annually and is ultimately accountable for compliance with it.

On an operational level, accountability for ensuring compliance with the Tax Strategy is delegated to the Group Tax and Corporate Structuring Director.

This is achieved by implementing, maintaining and reviewing supporting Tax Policies to mitigate tax risks and ensure compliance.

This operational role is overseen by the Group Finance Director (“Group FD”), who is also the Group’s Senior Accounting Officer (“SAO”).

The Group Tax and Corporate Structuring Director provides regular updates to the Group FD and formally reports to the Board on a monthly basis.

The Group Tax and Corporate Structuring Director leads an in-house team of tax specialists who each hold the appropriate professional qualification(s) commensurate to their role and responsibilities.

Approach to Tax Risk Management

The Group Tax Team work collaboratively with the business on a day to day basis to provide advice across all taxes.

Global Tax Risk Registers are used to document the Group’s tax risks before and after internal controls.

These Registers calculate a risk rating based on the likelihood of occurrence (probability) and potential impact if realised.

The Registers are updated on an ongoing basis and the ratings formally communicated to the Group CFO and Group FD/SAO together with any remedial actions.

The Board are formally notified on a monthly basis of any new risks that have been graded as “high”.

As part of the continuing review of the robustness and effectiveness of financial reporting controls, the Internal Controls and Internal Audit Teams review and test the tax processes and controls that are in place.

Any weaknesses or deficiencies will be reported to the Risk and Audit Committee.

The use of available technology and automation is continuously assessed to ensure the quality and accuracy of the data that underpins the tax returns and associated declarations.