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REPORT ON THE IMPLEMENTATION OF THE TAX STRATEGY FOR THE FISCAL YEAR 2020

KAN Sp. z o.o.
(hereinafter referred to in the document as the Company)

the report was prepared and made public to comply with the obligation under Article 27(c) of the Corporation Tax Act.

Group KAN

The Company acts as the headquarters of the Group KAN, which is an experienced and recognised in Poland and Europe manufacturer and supplier of modern KAN-therm installation solutions and systems - complete installation multisystems for the construction of internal water supply, heating and technological installations. Within the Group, the Company is primarily responsible for the production and distribution of KAN-therm installation systems on the Polish and international markets either directly or through the network of foreign distribution companies belonging to the Group. Foreign distribution companies are located in Russia, Ukraine, Belarus, Germany and Hungary.

Processes and procedures regarding the management of the performance of obligations under tax law.

With regard to the execution of tax-related tasks and obligations, the Company operates based on prepared and implemented procedures and processes, the application of which in practice allows for the proper and timely fulfilment of tax obligations resulting from the law. The Company shows a low susceptibility to take tax risks. The Company's actions are aimed at continuous review of the Company's wide range of activities in terms of compliance with applicable regulations and the presence of tax risks. The Company shows a high susceptibility to cooperate with the tax authorities, which is confirmed, among other things, by the fact that it has been certified as an Authorised Economic Operator AEO (since 2010).

All transactions with contractors are verified to ensure that the circumstances of the transactions and the contractor's data are correct. Bank accounts are checked in the "white list" and additionally in the e-banking module before making a transfer. The Company obtains certificates of residency from foreign contractors. Moreover, contractors are checked to ensure that they are actually in business. The Company's contractors are checked in the VIES system, and additional verification in this system is carried out using specialised software to check the SAF-T form before it is sent.

The Company has an electronic workflow implemented. All invoices according to the procedure are accepted using the electronic workflow, by the persons indicated in the responsibility matrix.

Other procedures implemented and used by the Company:

The Company focuses on continuously improving the qualifications of its accounting services. Training in the accounting department takes place periodically based on an ongoing partnership with a training company. Moreover, thematic training is provided as required and to address changes in tax legislation.

For cases requiring additional consultation or analyses the Company uses professional support of advisers and specialists.

Forms of voluntary cooperation with the authorities of the National Revenue Administration

In the fiscal year 2020, the Company did not engage in any forms of voluntary cooperation with the authorities of the National Revenue Administration.

Fulfilment of tax obligations

The Company settles its tax accounts in line with the applicable tax and balance sheet laws, and the amounts of tax liabilities are paid within the periods  specified by law. In the fiscal year 2020, the Company fulfilled its tax obligations for the following taxes:

The Company conducts part of its production activities in the Suwałki Special Economic Zone (Białystok Subzone), and therefore income generated from its activities in the above zone is exempt from corporate income tax in line with the applicable regulations.

Identification of tax schemes

In the fiscal year 2020, the Company did not identify any tax scheme and therefore had no obligation to provide information in this regard to the competent tax authorities.

Transactions with affiliated companies

Below is presented information on homogeneous transactions with affiliated parties, the value of which, counted separately for each transaction, exceeded 5% of total balance sheet assets within the meaning of the accounting regulations.

AFFILIATE

COUNTRY OF TAX RESIDENCE

TYPE OF TRANSACTION

KANEX Sp. z o.o.

Poland

sale of products, services and goods

OOO KAN-R

Russia

OOO KAN-therm UA

Ukraine

KAN-therm HU Kft.

Hungary

VSH Fittings B.V.

Holland

purchase of goods

The total value of the affiliate transactions listed in the table above amounts to PLN 176,950.81 thousand. .

Restructuring activities

In fiscal year 2020, the Company did not undertake restructuring activities that could affect its tax liabilities or those of related parties. The company also does not plan to undertake such activities in the near future.

Tax applications submitted by the Company

Below is the information of the applications filed by the Company as a taxpayer in the 2020 tax year.

APPLICATION FOR:

FILED (YES - number/ NO)

general tax interpretations

NO

tax law interpretations

YES -1 (*)

binding rate information

NO

binding excise information

NO

other decisions or interpretations relating to tax settlements

NO

(*) – interpretation on 0% taxation of export of goods

Tax settlements in territories or countries with unfair tax competition

In the fiscal year 2020, the Company did not settle taxes in territories or countries with unfair tax competition.

The Company also complies with regulations on anti-money laundering and anti-terrorist financing. The prohibition of cooperation with countries under embargo or other international sanctions is expressed explicitly in the General Sales Conditions employed by the Company.

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