TravelPerk Group Tax Strategy

In accordance with the requirements of Paragraph 19(2) and 22(2) of Schedule 19 of the Finance Act 2016, the TravelPerk Group (and specifically TK Operations Ltd.) has published its Group tax strategy, applicable for the Group’s UK sub-group headed by TK Operations Ltd, in respect of its financial year ended 31 December 2024. This strategy applies to all UK subsidiaries of TravelPerk, Inc. and of TK Operations Ltd, and will be periodically reviewed and updated.

Tax Strategy and Objectives

The TravelPerk Group (and its UK sub-group specifically) is committed to:

• Following all applicable laws and regulations relating to its tax activities, both in the UK and all the countries in which it operates;
• Refraining from using tax avoidance schemes or aggressive tax planning;
• Maintaining an open and honest relationship with HMRC and other tax authorities;
• Ensuring that the tax strategy adopted is consistent with the Group’s overall strategy;
• Ensuring that the Group’s tax governance is appropriate, relative to the size of the business and nature of the tax risks; and
• Implementing appropriate tax risk management and maintaining an appropriate controls environment.

Risk Appetite and Management

The Group has a low tolerance to tax risk and regularly considers the tax consequences of its commercial activities. Tax risks are assessed on a case-by-case basis, allowing the Group to reach appropriate conclusions on how each individual risk should be managed. When evaluating a tax matter, consideration will be given to the level of risk, the ease of governance implementation (including the necessary controls) and consideration of any tax relief available within the legislation and related guidance from the respective tax authorities. Where there is material uncertainty in how a relevant tax law should be applied, external advice may be sought to support the Group’s decision-making process.

Governance

The Board is responsible for overseeing the overall Group Tax Strategy. Appropriate accounting and financial oversight are exercised through the Group’s finance team with the Group CFO, having oversight responsibility for the Board. For UK entities, the designated SAO’s main duty is to take reasonable steps (relative to the scale of the business and nature of the tax risks) to ensure that the UK sub-group establishes and maintains appropriate tax accounting arrangements. These include the on-going application of governance with internal controls to substantially reduce tax risk to materially acceptable levels.

The Board is briefed quarterly by the CFO, providing updates on key issues, including tax and compliance matters. It is the responsibility of the SAO to implement the tax strategy and to ensure all UK taxation issues are promptly reported to the Group CFO as soon as they become aware of them. The SAO is supported by the Group’s Head of Tax.

Approach Towards Dealings with HMRC and other tax authorities

The Group is committed to the principles of openness and transparency in its approach towards dealings with HMRC and other tax authorities. More specifically, the TravelPerk Group (and its UK sub-group) is committed to:

• Adopting open and honest dialogue at all times with HMRC and other tax authorities;
• Making accurate and timely disclosure for all required tax returns;
• Paying all taxes on time;
• Resolving issues with the respective tax authorities in real time and before returns are filed if possible; and
• Interpreting all relevant laws and guidance in a reasonable way.