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Corporate Governance

Circle K Energy Limited  2018 UK Tax Strategy

Alimentation Couche-Tard Inc. and its subsidiaries (“the ACT Group”) are committed to acting with integrity and transparency in all tax matters, complying fully with tax legislation.

We are committed to compliance with tax law and practice in the UK. Compliance for us means paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to the tax authorities and claiming reliefs and incentives where available.

In compliance with the requirement outlined in paragraph 19(2) and paragraph 20(1) of Schedule 19 of UK Finance Act 2016, Circle K Energy Limited (“CKEL”) publishes this statement for the year ended 30 April 2018 on behalf of the UK companies within the Group (“the UK Group”), which include:

*Circle K Energy Limited; and *Fuel Managements Solutions Limited

Board ownership and oversight

This Tax Strategy will be owned by the Board of Directors of the UK Group (“the Board”) and will be reviewed annually with any proposed amendments ultimately discussed and approved by the Board. The Board is supported by suitably qualified finance and tax teams who have responsibility for implementing the Tax Strategy. Where required, the services of professional advisors are engaged to provide additional support.

This Tax Strategy was approved for publication by the Board on [27] April 2018 and applies thereafter until such time as it is superseded.

Risk Management and Governance

The UK Group’s finance team is responsible for the day to day management of the UK Group’s tax affairs with external tax advice and assistance as required. Ultimate responsibility rests with the Board and the Finance Director of the UK Group. In addition, the EMEA Senior Tax Manager based in Ireland and the Senior Tax Director based in Canada along with their respective tax teams support the Board to ensure that the UK Group remains compliant in all UK direct tax matters.

In addition, internal policies and procedures to support the UK Group’s tax framework are maintained. Periodic reviews are carried out to ensure that the policies and procedures are being complied with and to determine if any changes or enhancements are needed to the process.

Tax Structure

All tax structuring is undertaken as part of the overall business strategy and to support the commercial objectives of the Group and care is taken to ensure that transactions are carried out in a tax efficient manner whilst remaining compliant with the applicable tax laws.

Albeit there has been recent expansion within the ACT Group, the business of the UK Group is standardised and is relatively unchanged from year to year.

Tax Risk

The UK Group’s appetite for tax risk is low. Given the scale and nature of our business and the volume of tax obligations, risks will inevitably arise from time to time in relation to the interpretation of tax law and the nature of our compliance requirements.

Tax risks identified are assessed and a conclusion reached on how individual risks should be managed. External professional advice is sought to support the decision-making process where there is an uncertainty about how the relevant tax law should be applied.

Relationships with HMRC

The UK Group’s communication with HMRC is centred on timely tax compliance and timely responses to queries raised by HMRC. By way of example we focus on meeting the relevant filing and payment deadlines for the taxes the Group is required to pay.

We engage the services of professional tax advisors to act as our agents and in a number of instances they will liaise with HMRC on behalf of the UK Group. The Board views this as a way to maximise the UK Group’s relationship with HMRC and to reduce tax risk.