Tax Strategy

EXA Infrastructure Tax Strategy

1 Remit

This policy statement covers EXA Infrastructure’s (“EXA” or the “Company”) UK business and is published in accordance with 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 2026 and was approved by the Executive Board of Cube Telecom Europe BidCo Limited at the 20 October 2026 board meeting.

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; & (ii) building and maintaining professional and constructive working relationships with tax authorities based on principles of mutual transparency and trust. These commitments (explained in more detail below) apply to all countries and all employees. EXA measures and manages tax risks as follows:

• 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 utilise external 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.
• Furthermore, 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 the correct 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 seeks to adopt tax positions which it reasonably believes are consistent with the intent of applicable legislation and which can be robustly supported based on the relevant facts and law.
• EXA seeks to ensure that transfer pricing outcomes are aligned with the economic activities undertaken by the Group and with applicable OECD principles and local tax laws.

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

Measuring and managing tax risks:

• EXA has a low tolerance for tax risk and does not undertake transactions where the tax outcome is uncertain unless appropriate analysis has been performed and the resulting risk is acceptable to management.
• 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 Tax 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 tax team and EXA Management generally.
• 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.