Orano - Annual Activity Report 2024 81 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN 3 Risk factors 3.3.5.3 Tax issues Description of the risk The group, comprising entities located in different countries, regularly faces controls by local tax and customs authorities. Several audits and tax-related proceedings or disputes have been initiated or are currently being conducted by those authorities or in the courts. However, none are expected to give rise to, or has given rise to, a material tax expense that could have a significant impact on the financial statements. The group considers that it has sound means of defense and that it employs the legal procedures available to it to prevent any unfavorable outcome. [A description of the most significant ongoing litigation is provided in Note 34 to the consolidated financial statements as of December 31, 2024] Risk management measures In every country and region where it does business, the group ensures that it complies with the applicable tax laws and that, in accordance with the applicable regulations, the right amount of tax is paid. It further ensures that the principles enunciated by the OECD, as written into national legislation, are observed whenever it undertakes cross-border transactions. The group does not use structures that are opaque or lack real economic substance, nor entities in tax havens in order to conceal useful information from the tax authorities. It applies a policy based on compliance and transparency in tax matters. This policy is implemented by a Tax Department located in France, which relies on the Finance Departments supported, as necessary, by local experts in the countries where the group operates. The management of tax risks that may arise from differences in interpretation of the applicable rules is part of the overall risk management process. Internal control procedures and whistleblowing mechanisms ensure the correct application of ethical principles, including tax principles. The group’s companies submit their tax returns and pay their taxes on time. Each year, the group informs and declares its country-by-country tax returns (CbcR) to the French tax authorities. Each year Orano Mining publishes separately the payments made to foreign governments according to the EITI (Extractive Industries Transparency Initiative) standard. In this context, the group specifies that it holds, following the acquisition of Uramin, all the capital of a holding company established in the British Virgin Islands, a country with a preferential tax system. This holding company only holds shares in the group’s Namibian subsidiaries, which it does not finance or manage. In October 2023, the British Virgin Islands were removed from the European Union’s blacklist, then on February 18, 2024, from the French list of non-cooperative States or Territories. As a result, the group no longer holds subsidiaries established in a non-cooperative state.
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