This paper sets out the tax strategy of Sunny Capital Limited (the "Company"). In making this strategy available the Company is fulfilling its responsibilities under paragraph 16, Schedule 19 of Finance Act 2016.

This tax strategy applies to all UK taxes applicable to the Company. The Board is responsible for setting and monitoring the strategy; and it will be reviewed annually and any amendments will be approved by the Board. The finance team of the Company is accountable to the Board for the implementation of the tax strategy and the management of tax and related risks.

The Company's principal activity is property investment and it operates a UK property business. Our tax strategy reflects our status as a member of an international group, which requires strong governance, protection of our reputation, and, delivering returns to our shareholders. Our tax strategy reflects our commitment to comply with local tax laws, regulations and guidance; and to be a responsible UK tax payer.

The Company's continuing approach to UK tax risk management and governance is based on the principles of reasonable care, and being a responsible UK tax payer.

The Company maintains rigorous internal controls and systems to ensure that the level of UK tax risk is low, in line with what the Board considers to be acceptable. These controls include the use of suitably qualified and experienced staff internally, oversight from the Board on tax matters, internal review and authorisation procedures and the maintenance of audit trails.

Additionally, where a transaction gives rise to a material tax uncertainty, the Company seeks professional advice both from appropriately qualified staff in its Finance department and, if appropriate, support from the Group Finance department. Advice will also be sought from the Company's external professional advisers where required, to ensure the correct tax treatment is applied to the transaction.

The transfer pricing policy for the Company is managed at a group level and seeks to ensure that all transactions with related companies will be on an arm's length basis in accordance with the OECD guidelines. Regular reviews of this are performed by its ultimate parent company, to ensure that these are appropriate for both the frequency and complexity of the related company transactions entered into by the Company.

The Company will ensure that all transactions entered into are aligned with the Company's underlying commercial objectives and are compliant with the relevant UK tax legislation. The Company will not engage in tax planning if it is not in keeping with the Company's commercial objectives, or if the arrangements are detrimental to the Company's reputation, brand, corporate and social responsibilities, or future working relationship with HMRC.

Where the underlying transactions and tax effect are non-routine the Company will seek appropriate independent external professional advice where required, to ensure compliance with all relevant statutory and legal obligations.

The Company regards tax evasion in any form, either by knowingly not declaring income or inaccurately declaring income or expenditure to be unacceptable. The Company expects all its associates to comply with the UK's Corporate Criminal Offence rules within the Criminal Finance Act 2017.

The Company will only accept a low level of UK tax risk, as it seeks to be a responsible UK tax payer.

The Company's tax risk is monitored by the finance team, with input from professional advisors where required and material issues are brought to the Board's attention. The finance team and the Board are pro-active in ensuring that UK tax risk remains low.

The Company will actively seek to work with HMRC, in order to ensure all of its statutory and legal obligations are satisfied. As such, the Company seeks to act in an open, honest and transparent manner in its dealings with HMRC.

The Company's strategic aim is to avoid disputes with HMRC, and maintain a low tax risk rating. Therefore the Company will comply with all relevant legal disclosure and approval requirements; and relevant information will be clearly presented to HMRC. The Company will also seek to ensure that filings are made and taxes are paid in a timely manner.

Where errors arise, it is our policy to disclose these to HMRC and to also ensure that appropriate remedial action is undertaken.

The tax strategy will be subject to continuous review by the Board to ensure that the Company is adhering to its strategic aims and objectives.