Liberty Częstochowa Sp. z o.o. (the “Company”), fulfilling its obligations under Article 27c of the Corporate Income Tax Act of February 15, 1992 (Journal of Laws of 2021, item 1800), hereby publishes information on the implemented tax strategy for fiscal year 2021.

As part of the tax strategy implemented in 2021, the Company applied internal processes and procedures for managing the fulfillment of its obligations under the tax law, which ensured their proper implementation. In particular, in 2021, the Company carried out the following activities:

a. Prepared all required tax returns, which were subject to additional internal verification, filed returns with the relevant authorities, and made timely payments of tax receivables,

b. issued sales invoices, with due verification of the data included and the status of contractors,

c. made purchases, with observance of the internal rules for approval of expenses, execution of payments and proper settlement of purchase documents,

d. accounted for personal income tax, including preparing, signing and sending tax returns and making timely payment of such tax,

e. Resolved all tax doubts, including, in particular, the admissibility of recognizing tax expenses and deducting input VAT, after internal consultations, as well as using the recommendations of specialized external tax advisors,

f. performed duties related to countering the failure to comply with the obligation to provide information on tax schemes (MDR),

g. carried out obligations related to withholding tax, including, in particular, verifying whether the prerequisites for applying a reduced rate or exemption from withholding tax are met,

h. Carried out statutory obligations in the field of transfer pricing, including preparation of relevant documentation and submission of required statements,

i. constantly monitored the amendments to the tax law and the rules of implementation of new statutory obligations,

j. adhered to the internal rules of participation in tax proceedings, including the rules of cooperation with the tax authority in the case of verification activities or tax inspection,

l. in the case of potential violations related to tax settlements, each employee was required to report the identified violation; however, in 2021, no information on violations related to tax matters was reported, archived documents related to the tax settlements made, primarily in paper form and partially electronically, and kept them for the period required by law; access to the archived documents was restricted to a designated administrative employee only.

The aforementioned tax activities carried out by the Company take into account the specifics of the company’s operation and ensure reliable and timely fulfillment of tax obligations, as well as minimize the risk of irregularities of a tax nature. Within the framework of the indicated activities, the Company has additionally defined the scope of responsibility of individual employees for the proper performance of duties related to tax settlements.

The Company performs its tax obligations in the territory of the Republic of Poland, in particular, by timely filing of appropriate tax returns, payment of tax dues, payment of all other due public and legal dues, keeping appropriate documentation related to tax settlements and archiving it for the required period of time, as well as fulfilling obligations related to the maintenance of transfer pricing documentation.

In 2021, the Company was a taxpayer on account of:

a. corporate income tax,

b. goods and services tax,

c. real estate tax,

d. excise tax.

In 2021, the Company was a taxpayer for personal income tax.

In 2021, the Company carried out the following transactions with related parties (including entities that are not tax residents of the Republic of Poland), the value of which exceeded 5% of the balance sheet total assets, determined on the basis of the Company’s last approved financial statements:

1. Liberty Ostrava A.S. (a company incorporated under Czech law):

– transactions of sale of steel processing services – PLN 1,118,536,448.38,

– offset for settlement of miscellaneous expenses – PLN 88,031,140.22,

– advance received – PLN 98,729,400.00,

2. Liberty Galati S.A. (company under Romanian law):

– advance received – PLN 99,132,390.00,

3. Infrabuild Recycling Sp. z o.o. (formerly: Liberty Metal Recycling Europe Sp. z o.o.):

– scrap purchase transactions – PLN 127,970,559.11.

In 2021, the Company did not make tax settlements in territories or countries with harmful tax competition.

In 2021, the Company did not apply for a general tax interpretation, individual tax interpretation, binding rate information or binding excise information.

In 2021, the Company did not provide the Head of the National Tax Administration with any information on tax schemes within the meaning of Article 86a § 1 item 10 of the Tax Ordinance Act of August 29, 1997 (Journal of Laws of 2021, item 1540). At the same time, the Company has implemented a procedure for the implementation of obligations related to the prevention of non-compliance with the obligation to provide information on tax schemes (MDR), which is implemented, among other things, by performing periodic internal verification of events occurring in the Company that could potentially result in the obligation to provide information on tax schemes.

In 2021, the Company did not undertake or plan any restructuring activities that could affect its tax liabilities or the tax liabilities of related parties.