Our approach to tax in the UK

This document regarding our approach to tax in the UK is published by NTT Limited on behalf of its UK affiliates as listed in the Appendix Ain accordance with the requirements of paragraphs 19(2) and 22(2) of Schedule 19 of the UK Finance Act 2016. This document is effective for the financial year ending 31 March 2024 and will be reviewed annually and updated as necessary.

Our Business Overview

NTT Ltd. is a global technology services company. We partner with organizations around the world to shape and achieve outcomes through intelligent technology solutions, which is data driven, connected, digital, and secure. As a global ICT provider, we employ more than 34,000 people and deliver services in over 200 countries and regions.

Our approach to tax risk management and governance

We are committed to highest ethical standards and compliance with all relevant laws and regulations, social standards, and internal business policies.

Our business is overseen by the Chief Finance Officer (“CFO”) of NTT Ltd who is supported by other UK affiliates’ CFOs and experienced finance teams. Each CFO’s responsibilities include risk management, governance and oversight with respect to tax. Reporting to our CFOs, our finance and tax teams ensure that robust tax administration (including timely filing of tax returns, making of tax payments and prompt dealings with any queries from His Majesty’s Revenue and Customs (‘HMRC’)) is maintained.

We maintain policies of internal control systems as approved by senior management of the business to deal with various risks including tax. Our business is subject to Senior Accounting Officer (‘SAO’) obligations, and our SAO is responsible for ensuring that our tax accounting arrangements are appropriate. Our SAO therefore plays an important role in achieving our tax strategy by having an oversight over our relevant tax processes and controls.

As part of the overall risk management and governance arrangements, our business is also supported by external advisors, where necessary.

The level of tax risk we are prepared to accept

We have a low tolerance towards tax risks, and we are committed to maintaining and enhancing our tax compliance processes and controls by ensuring that appropriate training and guidance are provided within our finance and tax teams.

Our approach to tax planning

We utilize relevant tax reliefs available to us in accordance with the legislation, with a view to maximizing the shareholder value of our business. We do not implement any tax planning measures which are artificial in nature and does not reflect our commercial reality.

Our approach to dealings with HMRC

We aim to maintain a good relationship with HMRC, and work collaboratively with them in an open and honest manner.

Approved by the board of directors of NTT Ltd, on 18 March 2024.

Appendix A

• Applicable Limited
• Dimension Data Holdings Limited
• Dimension Data Limited
• e2y Limited
• Merchants Limited
• Nocitra Limited
• NTT Cloud Communications UK Ltd
• NTT Cloud Infrastructure United Kingdom Limited
• NTT Europe Ltd.
• NTT Global Data Centers Asset Management Ltd
• NTT Global Data Centers EMEA Limited
• NTT Global Data Centers EMEA UK Limited
• NTT Global Data Centers HH4 Limited
• NTT Ltd Group Services United Kingdom Limited
• NTT Ltd Commerce Centre United Kingdom Limited
• NTT Security (UK) Limited
• NTT United Kingdom Limited
• NTT United Kingdom Holdings Limited
• Transatel UK Limited