Galmarley Tax Strategy

In accordance with the requirements set out in para 17, Schedule 19 of the Finance Act 2016 (the 'Schedule'), this statement sets out the approach of Galmarley to conducting our tax affairs, and the management of tax risk. This statement is effective for the accounting period ending 31 October 2025.

Definition of 'tax'- References to 'UK Taxation' are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to 'tax', 'taxes' or 'taxation' are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which Galmarley has legal responsibilities.

References to 'tax risk' are to the possibility that an action or inaction in relation to our tax affairs could lead to financial cost, penalties, or reputational damage. These could crystallise via different routes, such as differences of interpretation of tax law, or business changes.

This strategy applies to Galmarley Limited and its subsidiaries, collectively referred to as 'Galmarley' or 'we/us'.

Galmarley was founded and continues to offer cost effect, secure and easily accessible access to the precious metals market. Our reputation is important to us, and ethical considerations underpin all of Galmarley's decisions. Our strategy is to ensure full compliance with tax legislation and that a fair amount of tax is paid, in line with the spirit of the tax legislation.

Our approach to managing UK tax risk

Our appetite for tax risk is low. We aim to minimise exposure to tax risk by applying the tax rules consistently and conservatively, and by ensuring our tax positions are supported by appropriate analysis and documentation.

We manage our UK tax risk in the following ways.

In line with our general business approach, we consider our corporate and social responsibilities when considering our tax affairs.
Ultimate responsibility for Galmarley's tax position and compliance rests with the Finance Director/Company Secretary, who is also on the Board.
Galmarley looks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect compliance with its tax obligations.
Tax returns are either prepared by employees with appropriate relevant experience, or outsourced to external advisers. In each instance they are reviewed by an appropriate qualified senior member of staff.
Galmarley ensures that those involved in these processes receive training appropriate to their roles and responsibilities, as well as ensuring any changes in legislation or guidelines are considered promptly with any necessary updates to process implemented immediately.
Senior staff members have a full understanding of all areas of the business and review processes on a monthly basis. In addition, external auditors monitor the robustness of the financial reporting system, internal controls and risk management framework.
Tax services are outsourced to established and appropriately skilled professional services firms where appropriate. These specialist advisors are utilised when additional skills are required that are not available internally within Galmarley.
Where the correct tax treatment is uncertain, external professional advice is taken and where appropriate, we engage directly with HMRC to obtain clarity.

Our attitude towards tax planning and acceptable levels of UK tax risks

As outlined above, our approach to tax risk follows the wider corporate approach of integrity and fairness that is embedded within the business.
We structure our operations in alignment with our commercial and economic values, and in doing so consider all relevant factors, including taxation as part of the decision-making process.
When undergoing more complex transactions, or where there are areas of uncertainty, we will obtain external tax advice in order to ensure compliance with our taxation obligations and will not compromise our values when determining an appropriate way forwards.
As part of this Galmarley seeks to utilise available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation, for example entering into HMRC approved employee incentive plans.
Galmarley does not enter into uncommercial or contrived tax planning schemes or strategies that exploit gaps and mismatches in tax rules or are against the spirit of the legislation.

Dealing with HMRC

Whilst there are limited instances of dialogue with HMRC (since we do not have a Customer Compliance Manager), all interactions with HMRC are conducted in an open, collaborative and professional manner.
Any conclusions drawn from such dialogue are actively followed within the business.
To the extent they occur, any inadvertent errors in submissions are fully disclosed as soon as reasonably possible after they have been identified.

Approved by the Board: 4th September 2025.

Companies in scope

Galmarley Limited
BullionVault Clients Limited
BullionVault Limited