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Niantic UK Tax Strategy

Niantic UK Group Tax Strategy for the Financial Year Ended December 31, 2024

Introduction

This document outlines the approach to tax strategy, tax risk, and planning for the UK subsidiaries and affiliates within the UK Group, covering all applicable taxes including corporate tax, payroll taxes, and VAT. It is published in accordance with the requirements under Part 2 of Schedule 19 of the Finance Act 2016 for the financial year ended December 31, 2024.

This strategy is reviewed and approved by authorized representatives.


Risk Management and Governance

As outlined in our Code of Conduct, the UK Group and its employees are committed to conducting all operations in a manner that is responsible, ethical and fully compliant with applicable laws and regulations across all jurisdictions in which we operate. We diligently monitor applicable tax laws and regulations to ensure that UK tax is paid appropriately and timely, tax reporting and disclosure requirements are met, and that tax risk is minimized.

Due to the complexity and constant changes in global tax, we may seek guidance from outside advisors to inform our decision making and strategy. Key tax decisions are made at the appropriate levels and in consultation with senior leadership.


Tax Planning

We aim to ensure compliance with applicable laws in keeping with our Code of Conduct, and that tax planning aligns with the natural state of business expansion and operating objectives. We may utilize relevant tax credits and incentives where these are in line with our own underlying business objectives. We seek external advice to ensure compliance with the detailed rules that apply.


Level of Tax Risk

The level of tax risk is assessed as a global organization. The UK Group is focused on proactively assessing the relevancy and applicability of tax legislation to maintain low levels of tax risk or uncertainty of tax positions. External tax advisors are consulted as needed.


Engaging with HMRC

The UK Group engages with HMRC, with honesty, integrity, respect and fairness. In the event of any inadvertent errors in submissions made to HMRC or in interpretation of relevant legislation, appropriate disclosures will be made as soon as possible after they are identified. The UK Group will seek to resolve any disputed matters through pro-active and transparent discussion and negotiation.