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Rule
Document Code
OO_PPPPP_XXX_YYY.ID.V
Date
01/12/2016
Total number of pages
6
Tax Strategy
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Title:
Tax Strategy
Document Code
OO_PPPPP_XXX_YYY.ID.V
Date
01/12/2016
CONTENT
1.
INTRODUCTION ..........................................................................................................3
1.1 Context ................................................................................................................................. 3
1.2 Aim ...................................................................................................................................... 3
1.3 Scope ................................................................................................................................... 3
1.4
2.
TAX STRATEGY............................................................................................................4
2.1
General overview ............................................................................................................. 4
2.2
Principles for handling tax affairs ..................................................................................... 4
3.
4.
Audience .......................................................................................................................... 3
GOVERNANCE.............................................................................................................5
3.1
Governance ...................................................................................................................... 5
3.2
Structure and organisation .............................................................................................. 5
Change tracking ..........................................................................................................6
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Title:
Tax Strategy
Document Code
OO_PPPPP_XXX_YYY.ID.V
1.
Date
01/12/2016
INTRODUCTION
1.1 Context
The main governing body of Cellnex Telecom, S.A. (referred to in this document as “Cellnex” or
“the Cellnex group”) is its Board of Directors, which manages, administers and controls its
business.
To perform these functions and in accordance with the provisions of the Spanish Corporate
Enterprises Act, Cellnex’s Board of Directors has non-delegable powers to determine its tax
strategy.
By drawing up this policy, Cellnex acknowledges the importance for the group of taking on board
the practices of good corporate governance established by law and determines the key
elements, principles and commitments of its tax strategy.
1.2 Aim
In line with the above, the aim of the tax strategy set out in this document is to establish the
main guidelines on which the Cellnex group can base its decisions and actions regarding its tax
affairs worldwide and in accordance with the laws applicable in the various countries and
territories where it does business.
1.3 Scope
This tax strategy policy of the Cellnex group will apply to all companies controlled by Cellnex
Telecom, S.A. regardless of where they are located and will apply to the group’s tax obligations
regarding direct taxes on corporate earnings, indirect taxes and taxes on employment, capital
and real estate income and any other tax obligations or obligations regarding the recording or
declaration of such taxes.
1.4 Audience
The tax strategy policy is established and approved by Cellnex’s Board of Directors and is
particularly relevant for the group’s different areas of business and organisational management
as well as its tax department.
The Cellnex group will inform its staff, shareholders or any other interested persons of this tax
strategy policy and any changes which may be made to the policy.
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Title:
Tax Strategy
Document Code
OO_PPPPP_XXX_YYY.ID.V
2.
Date
01/12/2016
TAX STRATEGY
2.1 General overview
The Cellnex group’s tax strategy policy is established in line with the basic principle of regulatory
compliance, i.e. compliance with the tax obligations which the group is required to meet in each
of the countries and territories where it does business. For this purpose, the group fosters
relationships with tax administrations based on the duties of transparency, good faith and
loyalty and mutual trust.
In its goal to gain public interest and generate value for its shareholders, it is important that
Cellnex always observes this basic principle of respecting and complying with tax regulations
when making business decisions to avoid tax risks and inefficiencies.
The aim of this tax strategy policy is therefore to support Cellnex’s business strategy and, for
this purpose, it is in line with its corporate mission of generating value for the group and its
clients and shareholders by means of an innovatory, efficient and neutral management and
quality telecommunications networking and infrastructure services provided by an enthusiastic
and experienced team of collaborators.
2.2 Principles for handling tax affairs
In line with the basic principle stated above, Cellnex’s actions regarding its tax affairs have the
following aims:
a) Comply with tax regulations in the various countries and territories where the group
does business, paying all taxes which are due and answering all requests for information
required by law.
b) Make decisions on its tax affairs based on a reasonable interpretation of applicable laws
and strictly in line with the group’s business activities.
c) Foster practices which can prevent and reduce significant tax risks, including
reputational risks, and ensure that profit-making is in line with the structure and
location of the group’s business activities, human and material resources and business
risks.
d) Transmit information to the group’s decision-making bodies on the main tax
implications of operations and matters which are subject to their approval, when they
are a major factor in decision-making.
e) View the taxes which the group companies pay in the countries and territories where
they do business as their main contribution to public revenue and, consequently, as one
of their contributions to society.
f)
Ensure that any operations which have tax implications are carried out for commercial
and business reasons, even though tax efficiency is also pursued with the operation.
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Title:
Tax Strategy
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Date
01/12/2016
g) Not operate in tax havens to evade tax obligations which would otherwise be applicable
and refrain from using opaque and/or artificial structures, processes or systems, mainly
for tax purposes, to prevent tax administrations from knowing who is ultimately
responsible for activities or owns the assets or rights involved.
h) Handle the group’s tax affairs regarding the generating and use of intangible assets,
ensuring that their location is their place of origin or due to business requirements and
that their transfer is for financial reasons and for prices which are in line with the
principle of free competition.
3.
i)
Provide information and documents regarding tax matters requested by tax authorities
in a timely manner and to the extent required, to reduce any uncertainties.
j)
Foster the implementation of good tax practices in the group which help reduce relevant
uncertainties and prevent conduct which could cause them.
GOVERNANCE
3.1 Governance
Cellnex’s Board of Directors is aware that its responsibilities include the following non-delegable
powers, which make up and define the Cellnex group’s corporate tax governance framework:

Establish tax strategy.

Establish a risk management policy, which includes tax matters, and supervise internal data
and monitoring systems.

Approve all types of investments and operations which, due to their high amount or special
characteristics, are strategic or have a special tax risk, unless they should be approved in
general shareholders’ meetings.

Approve the creation or acquisition of shares for a specific purpose or companies situated in
tax havens.

Approve any similar operations which, due to their complexity, could impair the Cellnex
group’s transparency.
The functions of the Audit and Monitoring Commission include the supervision of the
effectiveness of the monitoring and management of tax risks.
3.2 Structure and organisation
Cellnex’s tax affairs will be handled in accordance with the following guidelines:

Cellnex’s Audit Commission will be responsible for the regular reviews made of this policy
and its Board of Directors will make any observations or proposals for modifications and
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Tax Strategy
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Date
01/12/2016
improvements to the policy which it considers necessary, in line with Cellnex’s Articles of
Association and the laws applicable at all times.
In addition, the Audit Commission will monitor the application of this policy and will
regularly assess its effectiveness and adopt adequate measures to ensure that it operates
appropriately, reporting to the Board of Directors accordingly.

Cellnex’s tax department will ensure that prevailing tax laws and the principles referred to
in this policy are complied with by establishing suitable control mechanisms and internal
rules and regulations. For this purpose, it will have the necessary material and functional
human resources to achieve the aims set out in this document.
The tax department’s duties include providing advice to the Board of Directors and all other
organisational areas of the group on any decisions of a tax nature and, when required,
consulting independent experts on these matters.

4.
All of the group’s organisational and business areas should comply with this policy in the
areas which they are responsible for which have tax implications, reporting and consulting
any actions and operations which may be important for tax matters.
Change tracking
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