Tax strategy

Governance

Responsibility for Nynas tax strategy and its supporting governance framework rests within the responsibility of the Board of Directors to ensure effective systems are in place for follow-up and control. This is monitored by the Audit Committee, representing the Board of Directors, thru regular reporting of the management of taxes by the Chief Financial Officer (CFO). The external audit and the audit report include taxes and is reported to the Audit Committee and the Board of Directors. The day to day responsibility for each of these areas rests with the Tax Manager, who reports to the Finance Director who in turn reports to the CFO. The tax strategy is supported by a tax governance framework, which aligns with Nynas' wider risk and control framework. Independent monitoring and reporting of tax risks and controls is governed by the Tax Central Team and Local Management. Key exposures and issues related to tax are reported to and considered by the Audit Committee as needed but minimum annually with written minutes of meetings being kept.

Management of tax exposure

As a large multinational organization, with operations in more than 30 countries, Nynas is exposed to a variety of taxes and related risks. These can be grouped under the following headings:

1. Tax compliance and reporting, covers risk associated with compliance failures such as submission of late and inaccurate tax returns, the failure to submit claims within the stipulated timeframe or where finance or operational systems and processes are not sufficiently robust to support tax compliance and reporting requirements.
2. Transactional risks, arise where transactions are carried out or actions are taken without appropriate consideration of the potential tax consequences or where advice taken is incorrectly implemented.
3. Reputational risk looks beyond the financial risks to the wider impact tax risk may have on Nynas' relationship with its stakeholders, including shareholders, clients, tax authorities and the general public.

• Nynas looks to manage its tax risk in a similar way as other areas of its operational risk. A local General Manager/Finance Manager will generally take the lead in identifying, managing and monitoring tax risks within the respective business. Local management is supported by the Tax Central Team.
• The Tax Central Team consists of the Finance Director, the Tax Manager, the VAT Manager and the Transfer Pricing Specialist, all based in Stockholm, Sweden. In addition to their oversight role, they provide advice to Nynas Group companies on tax related issues, undertake or assist with tax filings, manage the relationship with tax authorities and assist with tax audits and various forms of tax and financial reporting. Internal controls are put in place with the aim of identifying, quantifying and managing key risks. The Tax Central Team is also responsible for the Transfer Pricing documentation of the transactions within Nynas Group.
• Where appropriate, Nynas looks to engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions. The subjective nature of many tax rules does however mean that it is often impossible to mitigate all known tax risks. As a result, at any given time, Nynas may be exposed to financial and reputational risks arising from its tax affairs.

Tax compliance and relationship with tax authorities

• Nynas seeks to comply thru its tax filing, tax reporting and tax payment obligations globally.
• Nynas strives to maintain an open and transparent relationship with the tax authorities in the countries where Nynas operates. This may take the form of disclosing and seeking to resolve a known issue prior to filing the relevant tax return.
• From time to time, Nynas view (or that of its advisors) on the appropriate tax treatment in any given case may differ from the view of the tax authorities. Where such circumstances arise, Nynas will work constructively and proactively with the tax authorities in question with a view to achieve a resolution to any matters arising.

Tax planning

• If implementing tax optimization measures, those shall be within the law, including the spirit of the law.
• Nynas recognizes that it has a responsibility to pay an appropriate amount of tax in each of the jurisdictions in where it operates. Nynas aims to balance this with its responsibility to shareholders and clients to structure its affairs in an efficient manner.
• External advice may be sought in relation to tax planning or areas of complexity or uncertainty to support Nynas in complying with its tax strategy.
• Nynas does not tolerate tax evasion, nor does Nynas tolerate the facilitation of tax evasion by any person(s) acting on Nynas' behalf.