Governance Tax Initiatives

Policy and Basic Mindset

Based on its Founding Principles and Corporate Philosophy, the UBE Group (hereinafter the “Group”) has designated its basic behavioral standards for corporate activities under the “UBE Group Sustainability Basic Policy,” and conducts sound and impartial corporate activities in accordance with international standards and guidelines based on foreign and domestic laws and regulations while practicing respect for human rights.

Demonstrating its recognition that contributing to the development of society is one of its important duties as a company, the Group engages in the appropriate payment of taxes in each country and region in which it undertakes business activities. Further, in line with the UBE Group Sustainability Basic Policy, it thoroughly enforces the following policies.

Taxation Policy

1. Respecting Laws and Regulations

In each country and region in which the Group conducts business, it strives to ensure the proper payment of taxes in accordance with the appropriate laws and regulations as well as bilateral tax conventions, OECD Transfer Pricing Guidelines, Action Plans on Base Erosion and Profit Shifting (BEPS), and other such regulations.

2. Tax Planning

While respecting various national and regional tax-related laws and regulations, the Group utilizes favorable tax systems within a scope based on business conditions as it strives to raise its corporate value.

Moreover, the Group does not utilize tax havens, conduct tax planning that is not in line with business conditions, or engage in any action with the goal of tax evasion.

3. Addressing Uncertain Tax Positions

The Group strives to file and pay taxes in accordance with various national and regional tax-related laws and regulations and, to address tax systems that have become increasingly complex, it seeks counsel from third-party experts and utilizes advance inquiry systems provided by tax authorities when necessary, striving to thereby minimize the risk of needing to engage in such proceedings as tax litigation and the payment of additional taxes.

4. Transfer Pricing

Based on the OECD Transfer Pricing Guidelines as well as various national laws and regulations, the Group has set the price of transactions such that profit is distributed in accordance with the functions handled and risk taken on by each Group company engaging in transactions with relevant overseas entities.

Moreover, to reduce risks associated with transfer pricing, the Group solicits advice from third-party experts, prepares transfer pricing documents in line with tax-related laws and regulations, and utilizes Advanced Pricing Arrangements via tax authorities when necessary.

5. Relations with Tax Authorities

In addition to engaging in proper tax filing and payment practices in the various countries and regions in which it conducts business activities, the Group strives to build and maintain good relations with tax authorities by addressing their requests properly and in a timely manner.

Management System

The Group’s CFO is responsible for tax governance.

The Group allocates appropriately credentialed members to each company’s tax department. In addition, the Group utilizes third-party experts when necessary to build complete systems at each company for handling basic tax issues.

For issues such as dealing with transfer pricing tax systems and when addressing tax matters worldwide, UBE Corporation’s Accounting Dept. takes on a central role, ensuring that the Group responds appropriately and proceeds in cooperation with those in charge of each party’s taxes.

Through the continuous Group-wide dissemination of information and other such initiatives, the Group strives to maintain and improve its awareness of tax compliance while addressing changes due to newly established, revised or abolished tax-related laws and regulations in the various countries and regions in which it undertakes business activities in order to ensure the proper filing and payment of taxes.