FISCAL TRANSPARENCY

The Fiscal Approach

Comer Industries operates through Companies based in different countries around the world, contributing to the development of their respective economies. An economic contribution that is also expressed at a fiscal level and takes the form of various types of taxes, which can be grouped into the following categories: income tax, corporate profits tax;

• property taxes, collections on property, sale or lease of real estate;

• employment taxes, including taxes collected and paid to the tax authorities on behalf of employees; indirect taxes collected on the turnover and production and consumption of goods and services such as VAT, customs duties, etc.

• local taxes related to corporate social responsibility.

According to the Code of Ethics, the Company is committed to operating in each of its entities with honesty and integrity in all tax matters and with a transparent and sustainable long-term tax approach. It complies with the laws of the jurisdictions it operates in and works closely with tax authorities, advisors, and auditors to ensure that taxes due are paid.

Note that as of tax year 2022 and effective December 31, 2023, the Company is subject to the so-called country-by-country reporting rules defined in Article 1, paragraphs 145 and 146, of Law no. 208 of December 28, 2015, and Council Directive 2016/881/EU of May 25, 2016, amending Directive 2011/16/EU, as well as its implementing provisions. The results of compliance will therefore be the subject of next year's reporting.

Tax Planning

Consistent with the Company values and principles of the Code, the Company does not pursue tax planning strategies or schemes, nor does it engage in conduct or domestic or transnational operations that result in constructions that do not reflect economic reality and from which undue tax benefits can reasonably be expected.

For tax purposes, intra-group transactions are governed by the so-called arm's length principle as defined by the OECD (Model Tax Convention and Transfer Pricing Guidelines), and aim to align transfer conditions and prices as correctly as possible with the places where value is created within the Group.