AP Racing Tax Strategy

Introduction

The Tax Strategy is aimed at setting values recognized as underlying principles of tax behavior and providing guidelines in order to ensure integrity and reputation.

The rules of conduct set out in this Tax Strategy are based on the guiding principles and values underlying the AP Racing Limited Code of Ethics, and that all employees must comply with and which are also applicable to the taxation field.

The Tax Strategy enters into force after the AP Racing Limited Board of Director’s approval and is available for consultation to all AP Racing Limited employees, collaborators and stakeholders, interested persons and parties on the Company’s website (www.apracing.com).

Values in the tax risk management

The Company tax behavior is to act with honesty and integrity in every sphere of tax matters. The approach to tax risks within AP Racing Limited is consistent with the management of risk across the associated Brembo Group as a whole: indeed, the Global Tax Strategy will be applied world-wide.

AP Racing Limited complies with the tax rules applicable in countries where it operates and such rules are interpreted in such a way that leads to responsible management of tax risks, in order to satisfy the interests of all stakeholders and to ensure the AP Racing's positive reputation. In this sense, the AP Racing considers and manages taxes as a cost of the business activity, in accordance with the principle of legality in order to pursue the primary interest of creating value for shareholders.

Guidelines

Tax Planning

Regarding international taxation, the AP Racing Limited ensures the correct application of local domestic legislation, tax treaties and OECD guidance in cross-border intra-group transactions, in order to guarantee the alignment of the arm’s length allocation of the profits/losses between wider Group members and their economic value creation.

Indeed, AP Racing Limited does not enter into arrangements resulting in tax benefits not accompanied by valid economic reasons and that might be abusive.

Further, AP Racing Limited does not use tax haven jurisdictions for tax avoidance purposes and do not seek tax rulings related to harmful preferential tax regimes.

Notwithstanding, AP Racing Limited will look to benefit from available tax incentives, i.e. intended by the legislations, that require an economic substance in order to be granted by the relevant authorities and jurisdictions and when they are consistent with the business of the Company.

Transparency

AP Racing Limited maintains a co-operative and transparent relationship with the local tax administrations, ensuring that the latter, inter alia, may acquire the full understanding of the underlying facts of the application of tax rules by the Company.

Agree to disagree

In defense of both the public interest its shareholder, AP Racing Limited believes that it is legitimate to support - also through legal proceedings – the reasonable interpretation and consequently application of the rules, where there are interpretative discrepancies with the tax administrations.