UK Tax Strategy Statement

Introduction

This UK Tax Strategy is published in accordance with the requirements of paragraph 19(2) of Schedule 19, Finance Act 2016 and applies to all UK companies within the EDF Renewables Limited Group (together referred to as “EDF power solutions UK”) for the period from 1 January 2025 to 31 December 2025.

Governance arrangements and risk management

Responsibility for determining and overseeing the Group’s approach to tax governance and risk management in the UK and Ireland rests with the EDF power solutions UK Board of Directors.

The responsibility for implementing this UK Tax Strategy is delegated to the Head of Tax, who reports to the Chief Finance Officer and works closely with other senior finance leaders across EDF power solutions UK. The Chief Finance Officer reports regularly, and where appropriate on an ad hoc basis, to the Board of Directors on tax matters.

This Tax Strategy is aligned with the EDF Group Ethics Charter and the EDF Energy Code of Conduct, applies across EDF power solutions UK, and has been approved by the EDF Energy Holdings Limited Board of Directors. It is consistent with the overall strategy of the Group’s ultimate parent company, EDF SA, which aims to create long-term value for the business and its shareholders while maintaining high standards of responsible business conduct.

The in-house tax team is responsible for monitoring and maintaining appropriate policies, procedures, and internal controls to ensure compliance with applicable tax legislation and reporting obligations. These controls are designed to be robust and proportionate to the size, complexity, and risk profile of the Group’s activities.

External professional advisers are engaged where appropriate to support the Group’s tax compliance and advisory requirements, including the preparation and review of tax computations and returns. Tax-sensitive judgements are made based on a reasonable interpretation of relevant legislation and guidance, taking account of all relevant facts and circumstances, and external advice is sought where appropriate.

Approach towards tax planning

EDF power solutions UK is one of the country’s leading renewable energy companies, specialising in wind power, solar power and battery storage technologies across England, Scotland, Wales and Ireland. The Group’s objective is to contribute to the transition to a low-carbon economy and to combat climate change.

Tax planning within EDF power solutions UK is aligned with the commercial and operational objectives of the business and is driven by genuine economic activity. The tax function works closely with the business and finance teams to understand transactions fully and to ensure consistency of approach across the Group.

EDF power solutions UK believes that paying the right amount of tax in the right place at the right time is an essential part of sustainable growth and of maintaining trust with stakeholders, including governments, regulators, investors, and local communities. The Group is fully committed to complying with all applicable legal and regulatory requirements in the jurisdictions in which it operate.

In the context of an increasingly complex domestic and international tax environment, our tax planning aims to support the commercial needs of the business by ensuring that company’s affairs are undertaken in the most tax efficient manner while remaining compliant with all relevant laws.

All intra-group transactions are conducted in accordance with the OECD Transfer Pricing Guidelines and the arm’s length principle, with appropriate documentation maintained to support transfer pricing policies.

The tax function is involved at an early stage in significant commercial transactions and business developments to ensure that tax implications are properly considered and understood as part of the decision-making process.

Where tax reliefs and incentives are available under applicable legislation, the Group may claim such reliefs in a manner consistent with both the letter and spirit of the law EDF power solutions UK does not engage in artificial arrangements or transactions that lack commercial substance, and tax considerations do not override sound commercial decision-making.

We have an experienced internal tax team to provide guidance to the business but where there is tax uncertainty or where the Group does not have the necessary internal expertise to assess the tax consequences of a particular matter, external professional advice will be sought to support the Group’s decision-making.

The tax function also participates, where appropriate, in relevant industry forums and consultation processes to remain informed of emerging tax issues and industry-related risks.

Level of risk in relation to taxation the group is prepared to accept

Tax risk is recognised as one of the commercial risks arising from the Group’s activities in the jurisdictions in which it operates. EDF power solutions UK also recognises that its renewable energy projects and operational sites can have a significant impact on local
communities and that responsible tax behaviour forms part of the Group’s wider commitment to those communities.

The complexity inherent in developing, constructing, operating, and maintaining renewable energy and battery storage assets gives rise to increased tax compliance obligations and potential tax risks. To manage these risks effectively, EDF power solutions UK maintains appropriate governance frameworks, policies, and procedures that apply across all relevant tax types.

EDF power solutions UK seeks to minimise tax risks that could expose the Group to financial loss, reputational damage, or adverse impacts on its relationships with HMRC or other tax authorities.

The Group does not operate a fixed quantitative tax risk threshold; instead, tax risks are assessed on a case-by-case basis, taking into account materiality, complexity, and uncertainty, with the objective of achieving predictable and sustainable tax outcomes.

Approach towards dealings with HMRC

EDF power solutions UK adopts an open, transparent, and constructive approach in its dealings with HMRC and other tax authorities. The Group seeks to cooperate and engage with HMRC in a timely and collaborative manner to build mutual trust. Where appropriate, we aim to deal with HMRC, on a real-time basis, maintaining regular dialogue to support mutual understanding of its business activities and tax position.

Where tax legislation is unclear or subject to interpretation, EDF power solutions UK will disclose the relevant facts and its interpretation to HMRC in a timely and proactive manner. This approach applies to both current and prospective transactions and reflects the Group’s collaborative and prudent approach to tax compliance.

EDF power solutions UK continually reviews its tax processes and controls to ensure ongoing compliance with applicable legislation. Where reviews identify the need for enhancements or corrections, these matters are addressed promptly and, where appropriate, discussed with HMRC to agree to the correct treatment and any implications for past, current, or future periods.