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GoTo UK Tax Policy Statement

Last Updated: December 31, 2022

This statement describes GoTo’s UK tax policy strategy for the years ended 31 December 2018 through years ended 31 December 2022 to satisfy the reporting obligations of Schedule 19 of the Finance Act 2016. When we refer to “GoTo, “we” or the “Company” in this policy, we are referring to GoTo Group, Inc.. and its subsidiaries and affiliates, including GoTo Technologies UK Limited.

Overall Tax Strategy

GoTo is committed to corporate responsibility and conducting its tax affairs in a manner that adheres to all relevant rules and regulations. We implement responsible tax management via our internal tax policies and our approach to tax planning. We seek to align our activities in a manner that supports our business strategy. GoTo seeks external professional guidance where needed to reduce and mitigate tax risk.

Commitment to Compliance & Attitude to Tax Planning

GoTo does not have any aggressive tax planning strategies for transactions in the UK. When considering tax planning, the core business needs and goals are top priority. Although the Company many consider tax costs, incentives, credits, and relief available when making business decisions, the business objectives remain the center of focus. The Company seeks external professional guidance from tax advisors when tax treatment is unclear or complex to ensure we adhere to all the laws that are relevant and applicable. External advisors are also used to help manage the Company’s compliance in the UK and globally.

Risk Management

We strive to manage risk through the Company’s internal controls relating to tax. Our policies function to ensure compliance with tax laws and regulations both in the UK and internationally, and to ensure that we identify and mitigate tax risks to a low level of risk. Tax risks and controls are overseen by executive management. The Company’s Chief Financial Officer is the ultimate party responsible for tax matters. Day-to-day responsibility is delegated to the Vice President of Finance and Vice President of Tax who are supported by a team of qualified tax professionals.

Working with HM Revenue & Customs (HMRC)

GoTo is committed to working with HMRC in a collaborative, transparent and compliant manner as it is with all governmental tax authorities. On occasions where the Company encounters disagreements with HMRC regarding tax matters and varying interpretations of law, GoTo will collaborate and pro-actively engage in discussions with HMRC to conclude and resolve matters on a timely basis.