UK Tax Strategy

Introduction

This document is prepared to satisfy the requirement under Para 19(2), Schedule 19 of the Finance Act 2016 to publish a tax strategy for Cleveland Potash Limited (“CPL”), and the other ICL Group entities located in the UK (ICL UK (Sales) Ltd.; Everris Ltd.; Amega Sciences Ltd.; Nutrient Sciences Ltd., Fibrisol Service Ltd. and ICL Europe BV (UK Branch). ICL Group Limited, a listed company on both the Tel Aviv and New York Stock Exchanges is the ultimate parent company of the aforementioned UK companies.

This document, sets out the tax strategy and approach undertaken by the ICL Group companies (and branch) domiciled in the UK, which are all mentioned above, in relation to how they conduct their tax affairs and deal with tax risks. This disclosure relates to the year ended 31st December 2024.

Managing tax risks

ICL Group entities are committed to complying with UK tax obligations, in addition to the obligations of the various tax jurisdictions across the globe in which we operate. Our business activities generate a substantial amount and variety of taxes worldwide. We pay corporate income taxes, VAT, royalties on natural resources excavation, business rates, climate change levy, stamp duties, employment and national insurance and other taxes such as excise duties.

The taxes we pay and collect form a significant part of our economic contribution to the countries in which we operate. ICL is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities. Compliance for us means paying the right amount of tax at the right time, completing accurate returns whilst also recognising available legislative concessions and reliefs. ICL supports efforts to increase public trust in tax systems. ICL’s code of conduct sets out what is expected of everyone at ICL and our approach to tax aligns with that.

The level of risk in relation to UK taxation that the group is prepared to accept

We identify, assess and manage tax risks and account for them appropriately. We implement risk management measures including controls over compliance processes and monitor their effectiveness. We report on a periodic basis to the group management on how tax risks are managed, monitored and assured and on improvements that are being made.

The acceptable nature of tax risk we are prepared to take is inextricably linked to the level of business risk we are prepared to take, which in itself is aligned to ICL’s commercial, reputational and business practices. In this regard, various factors will always be considered including, but not limited to, the financial impact, the impact on corporate reputation / brand and the impact on relationships with external stakeholders.

Tax planning

We engage in efficient tax planning that supports our business and reflects commercial and economic activity. We do not engage in artificial tax arrangements. We adhere to relevant tax law and we seek to minimize the risk of uncertainty or disputes. We conduct transactions between ICL group companies on an arms-length basis and in accordance with current OECD principles.

Tax incentives and exemptions are sometimes implemented by governments and fiscal authorities in order to support investment, employment and economic development. Where they exist, we seek to apply them in the manner intended. We establish entities in jurisdictions suitable to hold our overseas investments, giving consideration to our business activities, the prevailing regulatory environment available, and as appropriate in line with joint venture requirements.

Relationships with Authorities

We seek to build and sustain relationships with governments and fiscal authorities that are constructive and based on mutual respect. We work collaboratively wherever possible with fiscal authorities to resolve disputes and to achieve early agreement and certainty. We engage with governments on the development of tax laws either directly or through trade associations and other similar bodies as appropriate.

Our aim is to be considered as a low risk tax payer from HMRC’s perspective.

Transparency

We support the principle behind multilateral moves towards greater transparency that increase understanding of tax systems and build public trust.

Governance

The group head of tax owns and implements our approach to tax which is approved by the Global Executive Committee. The group head of tax is also responsible for ensuring that policies and procedures that support the approach are in place, maintained and used consistently around the world and that the global tax team has the skills and experience to implement the approach appropriately.

Further information

Our approach to tax is applicable across the whole ICL Group.