SHV is committed to upholding the highest standards of ethics and integrity. As a responsible taxpayer, we understand that taxes are essential for the funding of the public services and infrastructure that are critical to well-functioning societies. SHV and its Groups contribute consistently acting on our obligation to pay the legally due amount of tax across every territory in which we operate. We pay direct and indirect taxes, in addition to collecting taxes from our employees and customers on behalf of governments. We maintain open and constructive relationships with tax authorities based on transparency, integrity and respect.

SHV exclusively employs business structures that are driven by commercial considerations, where economic substance is aligned with business activities. We also ensure that our use of tax incentives is in line with its policy intent and aligned with business activities and operational objectives, provided that these incentives are generally available to all market participants and are specified by law. In doing so, we make sure that tax always follows the business.

We pay tax on profits according to where value is created within the normal course of our business activities. We do not use aggressive tax planning strategies nor tax havens to avoid taxes. If any entity is based in a no or low tax jurisdiction, it exists for business reasons only and has proper substance in relation to its business activities. The pricing of intercompany transactions is applied consistently and done in accordance with the arm’s length principle developed by the OECD.

SHV and its Groups have over 800 legal entities in 70 countries. These companies are included in our annual country-by-country report that is filed with the Dutch tax authorities detailing the global allocation of income and taxes, as well as certain other measures of economic activity. The Dutch tax authorities then exchange this information with relevant tax authorities around the world.

Being a responsible taxpayer is also one of the reasons why SHV endorses the Tax Governance Code issued by the Confederation of Netherlands Industry and Employers (VNO-NCW). SHV’s tax strategy is aligned with the tax principles of the Tax Governance Code. This Code also requires companies to be open about their tax payments, so that people can understand how much is paid, where and why. SHV supports this as transparency can build trust. It is about putting the numbers into context, but also about demonstrating the commitment to comply with legislation and explaining a company’s approach to tax.

In 2024, SHV was obliged to prioritize the implementation of new global minimum taxation rules (Pillar 2) and the transition to IFRS. This means that we are not yet in a position to provide additional information on tax payments other than corporate income tax. We are, however, continuing to develop an action plan to provide further insight required by the Tax Governance Code in a manner that fits the diversity of our business activities.

The table below outlines the 2024 corporate income tax expenses and corporate income tax payments made to tax authorities in our 10 largest operating countries defined by the weighted average of net sales, operational fixed assets and number of employees per jurisdiction. Listed by amount of net sales, these 10 countries represent more than 60 percent of SHV’s income before income taxes.

For each country we report the amount of net sales (before the elimination of intercompany sales), profit before taxes, corporate income tax expense reported in the income statement and the amount of corporate income tax paid and received on a cash basis.

The tax expense reported in the income statement is the amount of current and deferred tax expense incurred in the financial year based on accounting rules.

Corporate income tax paid is the net amount of corporate income tax actually paid to, or received from, the tax authorities in the financial year.

The table presents tax expenses and tax payments as negative amounts. Income and refunds are shown as positive amounts. The data is derived from internal management information systems.

#

Country

Net sales

Income before income taxes

Income tax expenses

Income tax paid

1

Netherlands

2,974.8

(112.3)

(13.9)

(28.0)

2

France

2,707.9

29.8

(10.5)

(10.7)

3

Brazil

1,808.2

101.4

(46.2)

(32.3)

4

Spain

1,623.9

4.8

(3.3)

(3.2)

5

United Kingdom

1,534.7

86.9

(14.6)

7.1

6

Canada

1,458.9

28.6

(9.4)

(5.6)

7

United States

1,308.6

(1.9)

(3.2)

(8.9)

8

Italy

924.0

72.6

(21.1)

(18.7)

9

Ecuador

812.4

69.1

(7.1)

(3.1)

10

Germany

677.0

56.9

(15.4)

(17.3)

Total top 10

15,830.3

335.8

(144.7)

(120.8)

Other countries

9,904.1

220.0

(81.7)

(64.2)

All Tax Jurisdictions - SHV

25,734.4

555.8

(226.4)

(185.0)

Please refer to the tax paragraph in the financial statements of this report for a detailed explanation of the effective tax rate in 2024.