UK Tax strategy

Tax Strategy

This UK tax strategy document applies to all AMG UK-based companies (“AMG UK Group”) of the NYSE Euronext Amsterdam listed AMG Critical Materials N.V. (“AMG”). This UK tax strategy is owned and approved by the Board of Directors and covers all UK taxes relevant to the AMG UK Group. The UK Group regards this publication as complying with Paragraph 19(2) of Schedule 19 of the Finance Act 2016 and it is effective for the financial year ending 31 December 2025.

This document sets out AMG UK Group’s policy and approach to conducting its tax operations and managing its tax risk.

This Tax Strategy and our tax culture align with AMG’s core values of honesty, integrity, and accountability, and support the success of our business operations.

1.1 Tax Objectives

This statement is made on behalf of the AMG UK Group pursuant to Section 10 of the Act and fulfils the UK Group’s duty to publish a UK tax strategy. Consistent with the UK Group’s finance team objectives, when managing the AMG UK Group’s tax position, the goal is to support the AMG Group’s overall tax strategy whilst ensuring compliance with local tax laws and filing obligations. Tax performance is measured in the following ways:

• Paying the amount of tax legally due according to HMRC due dates;
• Submitting all UK tax returns on a timely basis, with appropriate detail to allow HMRC to understand the filing;
• Ensuring UK tax processes are adequately resourced, supported, and that key personnel are trained and retained to manage compliance issues promptly;
• Reviewing all tax filing positions and supporting them with appropriate documentary evidence;
• Making relevant claims, elections, and incentives to minimise the tax cash paid by the UK Group;
• Implementing and maintaining controls and procedures relating to all taxes to ensure the correct tax is paid;
• Ensuring that where a tax liability arises in another territory, the correct amount of tax is paid in a timely manner.

1.2 Tax Risk Management and Governance Approach

AMG promotes a culture of sound risk management. Effective tax risk management is paramount for the UK Group and underpins the strategy for continued growth. The UK Group strives to reduce the level of tax risk arising from its operations as far as reasonably practicable by applying reasonable care in relation to undertakings which could materially affect compliance with tax obligations.

The tax strategy is aligned with the AMG Code of Business Conduct, which can be found on the AMG website. AMG also publishes its own policy on taxation, available at AMG Tax Policy (PDF). The UK Group applies OECD guidelines to intercompany transactions and seeks to operate at arm’s length and with transparency in dealings across the AMG Group.

1.3 Acceptable Level of UK Tax Risk

The Finance Director, Head of Finance, and Financial Controller, with support as needed from the Board, AMG tax and financial personnel, and third-party advisors, will endeavour to understand tax risks and opportunities regarding ongoing compliance, tax planning, and future transactions. These individuals are integrally involved in the planning, implementation, and documentation of all tax compliance matters, significant business transactions, and tax processes.

Appropriate training, resourcing, and support are provided to those involved in managing and executing tax activities. Where uncertainty arises in the application of tax law, third-party advisors will be consulted to provide opinions, risks, and alternatives with supporting documentation.

Final approval is required from the Finance Director, and for material transactions, approval must also be confirmed by the Board of Directors.

The AMG UK Group’s tax risk tolerance is low, as it is our goal to pay the appropriate amount of taxes in the jurisdictions in which we operate on a timely basis.

1.4 Attitude to Tax Planning

The AMG UK Group fundamentally believes it should pay the amounts of tax legally due in the UK and will not engage in transactions where the main purpose is avoidance of UK taxation. The UK Group has a zero-tolerance approach to tax evasion and the facilitation of tax evasion by employees or third parties.

Parameters defined by the UK Board are used in assessing and concluding tax planning initiatives. Where uncertainty arises in the interpretation of tax law and alternatives exist, the most tax-efficient option will be preferred.

Tax planning assessments consider business purpose, reputational and financial impact, and professional tax advice as needed. Transparency and an open working relationship with HMRC are also maintained.

Tax planning requires authorisation by the Finance Director. Any material planning requires advice from third-party tax professionals, approval by the Board of Directors, and prior approval from the AMG Group Lead.

1.5 Working with HMRC

The AMG UK Group strives to develop collaborative, communicative working relationships with HMRC based on mutual respect and understanding. Personnel maintain an open and transparent dialogue with HMRC whilst operating in a professional, courteous, and timely manner.

When a Customer Relationship Manager (CRM) is appointed, the UK Group fosters ongoing open dialogue regarding relevant business changes, aiming for early agreement on uncertain matters to minimise risk.

During HMRC visits, enquiries, or audits, the UK Group adopts a proactive approach in providing information to support prompt resolution. The Group complies with all local document retention requirements to ensure necessary records are available.

Date: 19 December 2025

Footnote

This tax strategy applies to the following AMG UK Group companies: AMG Chrome Limited, AMG Alpoco UK Limited, AMG Aluminum UK Limited, and AMG UK Group Pension Trustee Limited.