Last reviewed & updated: October 12, 2021

EXA Infrastructure Tax Strategy

1. Tax Strategy

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 2021.

2. Approach to Tax Risk Management and Governance

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.

EXA’s tax department proactively manages, reviews and reports 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 Director of Tax who reports to the CFO.

The tax team, which is led by the Director of Tax, is accountable for the day-to-day management of 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 includes 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 Approach to Tax Planning

EXA recognizes that it is responsible for paying an appropriate amount of tax in the UK. Against this EXA must balance its responsibilities to maximize its sustainable returns to shareholders. 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. Approach to Building and Maintaining Relationships with Tax Authorities

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.

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 issue may be discussed with HMRC, as the best way to avoid costly disputes is to reach a consensus on issues in advance.