Last reviewed & updated: 10 September 2025

EXA Infrastructure Tax Strategy

1 Remit

This policy statement covers EXA Infrastructure’s (“EXA” or the “Company”) UK business and is intended to satisfy the UK tax strategy publication requirement under Schedule 19 to the Finance Act 2016. This statement is made for the financial year ending 31 December 2025 and was approved by the Executive Board of Cube Telecom Europe BidCo Limited under a board resolution dated 10 September 2025.

2 EXA Group’s approach to risk management and governance arrangements in relation to UK taxation

EXA is committed to (i) complying with tax laws in a responsible manner; and (ii) building and maintaining professional and constructive working relationships with tax authorities based on principles of mutual transparency and trust. These commitments, which are explained in more detail below, apply to all countries and all employees.
How EXA measures and manages tax risks:

  • EXA’s tax department proactively manages, reviews and regularly reports to the Chief Financial Officer on tax risks and employs an experienced tax team that is part of the central finance function reporting to the Chief Financial Officer (“CFO”).
  • Day to day responsibility for these functions sits with the VP of Tax who reports to the CFO.
  • An important element of managing risk is maintaining an experienced and well-resourced tax function that can manage current and anticipate future tax risks. The tax team is accountable for the day-to-day management of the Group’s tax affairs, unless accountability is clearly devolved and accepted elsewhere.
  • Any decisions to be made in respect of uncertain tax issues are subject to diligent professional care and judgement by the tax team but also after consulting with and justifying the decision with local and international management teams.
  • In those situations where the level of uncertainty is high, the tax department will utilize outside advisors to help evaluate the risks.
  • The Company manages tax costs through maximizing the tax efficiency of business transactions. This may include taking advantage of available tax incentives and exemptions.
  • This is done in a way that is aligned with the Company’s commercial objectives and meets its legal obligations and ethical standards.
  • This is also done in a way that the Company reasonably believes is not contrary to the clear intentions of the legislation concerned..

3 The Group’s view of tax planning as it relates to UK taxation

  • EXA recognizes that it is responsible for calculating and paying an appropriate amount of tax in the UK.
  • Against this, EXA must balance its responsibilities to maximize its sustainable returns to shareholders.
  • Tax planning that EXA undertakes is designed to support business operations and financing, acquisitions and sales in a tax efficient manner.
  • EXA will not undertake any tax planning that cannot be sustained by the commercial requirements of the group and does not have economic substance.
  • EXA will not undertake any tax planning unless EXA believes that the strategy is compliant with tax legislation and more likely than not to succeed.

4 The level of risk in relation to UK taxation that the EXA Group is prepared to accept

Measuring and managing tax risks:

  • EXA is not prescriptive in terms of the levels of acceptable risk; however, the Company complies with legal requirements in a manner that ensures it pay the required amount of tax.
  • This is underpinned by a professional, co-operative and open relationship with HMRC.
  • EXA maintains a register of known and potential UK tax risks that the Group may face. This is reviewed and updated periodically.
  • The levels of acceptable tax risks are set by the VP Taxes and agreed with the CFO and are not influenced by external stakeholders..

5 The approach of the EXA Group towards dealings with HMRC

Meeting the requirements to work with HMRC:

  • The Company is committed to building constructive working relationships with HMRC based on a policy of full disclosure to remove uncertainty in its business transactions and to allow the authorities to review possible risks.
  • The main formal platform for engagement with HMRC is the BRR+ process and the Annual Conversation, where the Group updates HMRC with the events of the past year and any known future events.
  • Other than this, there are regular verbal and e-mail discussions where required by either party.

    Interpreting the law:

  • Tax advice will be sought from external advisors in relation to material uncertain transactions or where the tax department does not have the level of expertise required in a particular area.
  • Any tax opinions received are an aid to, not a replacement for, professional judgement to be exercised by the team.
  • Where appropriate, best practice solutions will be sought or such issues may be discussed with HMRC, as the best way to avoid costly disputes is to reach a consensus on issues in advance.