Intrum Tax Policy

Contents:

1. Introduction

2. Key Tax Principles   

3. Tax Governance 

3.1 Key responsibilities and delegation of authority for tax matters 

3.2 Escalation of significant tax matters 

4. Responsibilities and Reporting   

5. Tax Risk Management

6. Relationships with Tax Authorities 

7. Use of Advisors

1. Introduction

Intrum is the industry-leading credit management company in Europe. We help companies prosper by offering solutions designed to improve cash flow as well as long-term profitability and by caring for their customers. Our focus is to create shared value for business and society, which both benefit from companies being paid on time and citizens getting out of debt. Intrum has around 10,000 dedicated professionals who serve around 80,000 companies across Europe. Intrum is headquartered in Stockholm, Sweden, and the Intrum AB (publ) share is listed on the Nasdaq Stockholm exchange. For further information, please visit www.intrum.com.

The purpose of this Tax Policy (the “Policy”) is to define the framework and principles regarding the tax matters within the Intrum Group and to increase focus and understanding of the Intrum Group’s approach to tax governance and risk management.

The Policy applies to all Intrum employees and covers the Intrum Group’s global business operations and activities.

2. Key Tax Principles

Intrum has a duty towards all its stakeholders, including shareholders, clients, suppliers, employees and society in general, to strive for economic value growth through a number of activities, including measures to ensure effective management of the tax position of Intrum. The long-term goal is to efficiently manage Intrum’s tax cost, similar to other business costs, and to ensure that strategic business objectives are met. Intrum’s tax risk appetite is aligned to Intrum’s overall risk appetite and looks to balance risk taking and value generation. Intrum considers tax to be an integral part of our wider sustainability work; we positively contribute to society through our tax payments and charges, and we support tax transparency initiatives.

Intrum shall comply with its obligation to pay the correct amount of tax legally due in any territory in accordance with rules set by the relevant authorities in each jurisdiction. Intrum does not aim to intentionally or deliberately violate regulatory requirements and strives for full compliance with applicable laws and regulations. Furthermore, Intrum aims to be aligned to our industry norms in relation to best practices and overall tax risk management, including for example the use of Special Purpose Vehicles and industry specific tax regimes. Nevertheless, Intrum shall not engage in aggressive or artificial transactions where the sole purpose is to generate a tax advantage. Moreover, Intrum does not facilitate nor help clients or customers engage in aggressive or artificial tax planning.

Where there is more than one way to structure a transaction, Intrum reserves the right to choose the alternative which achieves the commercial aims of the business while simultaneously managing our tax cost. However, given the nature of Intrum’s business, it is important that the potential impact to Intrum’s corporate brand and reputation is always considered in the management and evaluation of tax matters. Intrum’s tax management must always be conducted in a manner that is in accordance with Intrum’s corporate brand, values, reputation and overall risk appetite.

3. Tax Governance

Intrum aims to have a robust tax governance model with clearly defined roles and responsibilities. This Policy is approved by the Board of Directors and is owned by the Chief Financial Officer of Intrum (‘CFO’).

3.1 Key responsibilities and delegation of authority for tax matters

The key responsibilities and delegation of authority for the management of tax matters within Intrum are specified below:

Board of Directors

The Board of Directors of Intrum AB has the overall responsibility for Intrum and its operations and for supervision of Intrum’s management and activities. The Board of Directors also has the ultimate decision-making power as regards to taxes within Intrum.

Chief Executive Officer

The Chief Executive Officer of Intrum (‘CEO’) has the overall responsibility for the day-to-day management of Intrum, including tax affairs. The CEO also has the ultimate decision-making power as regards day-to-day tax management within Intrum. To support the CEO, the general responsibility of the day-to-day management of the tax affairs of Intrum has been delegated to the CFO.

CFO

The CFO has the general responsibility for the day-to-day management of the tax affairs of the Intrum Group. The CFO is assisted by the Global Tax Director and is responsible for:

i) monitoring compliance of the Policy at a global level; and

ii) management of Intrum’s tax position and payments in accordance with the Policy.

Furthermore, all external communication concerning Intrum tax matters is the responsibility of the CFO.

Local Finance Directors

The responsibility for the management of tax matters in our different countries of operations has been delegated to the local Finance Directors. The Finance Director has the responsibility for management of the tax affairs in the local Intrum reporting units on a day-to-day basis. The Finance Director is also responsible for ensuring compliance with the Policy in the Country or unit for which they are responsible.

Global Tax Director (supported by the Global Tax Function)

The Global Tax Director assists the CFO with the day-to-day management of the tax affairs of Intrum on a global level. The Global Tax Director is also the main contact and support for the Finance Directors in relation to all tax matters. The Global Tax Director shall be informed and included in all tax audits and is included in relevant global committees where tax is a pertinent topic. Moreover, the Global Tax Director is responsible for the selection of external tax advisors in cooperation with the Finance Directors. The Global Tax Director shall manage any breaches of the Policy and shall continuously monitor compliance with this Policy and related Tax Instructions.

3.2 Escalation of significant tax matters

Finance Directors shall inform the CFO and the Global Tax Director about any significant tax matters or uncertain tax positions with a tax effect above EUR 100,000. In addition, other tax matters should be reported that could have material impact, e.g., a negative effect on the reputation of the Intrum Group. The potential reputational risk or damage to Intrum’s brand associated with a certain transaction or tax position shall always be considered.

The evaluation and final decision on any tax position with an estimated tax impact above EUR 100,000 must be approved by the CFO and the Global Tax Director. Moreover, if there is potential for brand or reputational impact as a result of a tax position, this must be approved by the CFO and the Global Tax Director, prior to such position being taken.

4. Responsibilities and Reporting

It is the responsibility of each Finance Director to ensure that this Policy is followed. The Global Tax Director shall monitor and control compliance with this Policy. Any breach of this Policy shall immediately be reported to the Global Tax Director.

The Global Tax Director must report any material breach of this Instruction to the CFO, CEO, Global Compliance Officer and the Audit and Risk Committee and at the same time submit a statement covering the measures taken in respect of the breach. Additionally, a quarterly summary of tax issues is to be presented to the CFO, CEO and the Audit and Risk Committee.

5. Tax Risk Management

Certain key measures have been identified for Intrum to actively manage ongoing tax risks. These key measures are monitored and evaluated on an ongoing basis and include:

Timely and accurate tax compliance

• All required tax returns or other obligatory tax reporting (Country-by-Country reports, Country-by-Country notifications, DAC6, etc.) shall be filed on a timely basis and comply with relevant tax laws and regulations
• Any detected material errors or omissions in tax filings shall be promptly reported to the relevant Tax Authorities and the Global Tax Director should be notified
• Taxes that are legally obliged to be paid shall be paid when they become payable

Transfer pricing

• Intrum is committed to applying the arm’s length principle, as defined in Article 9 of the OECD Model Tax Convention on Income and Capital and incorporated into local tax legislations, meaning that commercial and financial relations between associated enterprises shall take place on the same terms as if the transaction had taken place between independent enterprises under comparable conditions and circumstances in all cross-border transactions within Intrum
• All Intrum companies shall prepare and file transfer pricing documentation in accordance with local regulatory requirements

VAT and indirect taxes

• All Intrum companies shall have a written routine for reconciling the relevant numbers for each indirect tax return and for filing the relevant return
• The written routine shall outline the internal process for establishing the appropriate level of input VAT deduction, setting out the correct VAT treatment for new transaction flows and incidental transactions of significant relevance for VAT purposes

M&A activities

• The tax implications from establishing or acquiring any new reporting unit (including companies, branches, partnerships etc.) legal entity (or branch) or making material new investments should always be reviewed and approved by the CFO and Global Tax Director prior to any action is taken
• No transfer of business, major assets or liabilities, mergers, liquidations or other reorganisations may start prior to approval by the CFO and Global Tax Director

Changes in tax legislation

• On global level, the CFO and the Global Tax Director are responsible for monitoring changes in tax legislation (including VAT that applies in multiple countries), and for evaluating how such developments could impact Intrum
• On country / reporting unit level, the Finance Director is responsible for monitoring local legislative tax developments or other developments which influence tax matters, including VAT, and for evaluating how such developments may impact the business unit. If a change in tax legislation may lead to a material change in the reporting unit’s tax position, the Finance Director should immediately report this to the Global Tax Director.

6. Relationships with Tax Authorities

Intrum always strives to develop and foster a good working relationship with all relevant Tax Authorities. In the event of a tax audit or similar dialogue, Intrum takes great care regarding the completeness, accuracy and necessity of information provided to the tax authorities. Intrum aims to fully comply with all reasonable requests and should proactively look to cooperate with the tax authorities and shall always respond in an open, honest and timely manner.

Intrum strives to avoid disputes with tax authorities though reasonable tax risk mitigation and the use of defendable tax positions based on prudent interpretations of relevant tax regulations. Nevertheless, should a tax authority´s intrepration or position differ from Intrum’s, we reserve the right to defend our position through appropriate dispute resolution mechanisms, including legal procedures.

7. Use of Advisors

Intrum uses external advisers wherever necessary to ensure that it has the most accurate and up to date analysis in order to facilitate informed decision making by the relevant person or body within the Group. Intrum primarily seeks tax advice from large, international and reputable accounting or law firms.

In relation to significant transactions, including those in the ordinary course of business and where the tax outcome is in any way uncertain or in the event of a new cross border transaction, an external tax advisor shall be engaged to assist.