Trinseo’s UK Tax Strategy

Introduction

In the Finance Act 2016, the UK Government introduced legislation requiring large businesses, such as Trinseo, to publish their tax strategy. The following information is published in compliance with paragraph 16(2) of the Finance Act 2016. This legislation specifically relates to a Group's UK tax strategy and UK taxes, this tax strategy applies to the Group's operations in all jurisdictions in which it operates for all financial years up to and including 2023.

We operate in an industry that is stringently regulated. Trinseo is committed to a culture of compliance, including a culture that promotes the prevention, detection and remediation of conduct that does not comply with applicable laws, rules, and regulations.

Trinseo’ s Code of Business Conduct requires that all its books and records accurately and fairly reflect its transactions, and our approach to tax aligns to that code.

Our tax approach is based on the following principles:

1. Tax Risk Management and Governance

The Board of Directors is committed to ensuring that Trinseo meets all its objectives and is responsible for governance, oversight, and risk management.

The Chief Financial Officer has delegated responsibility for the Company tax approach. Day to day responsibility is delegated to the Chief Tax Officer and its Global Tax Department. The Chief Tax Officer directly reports to the Chief Financial Officer.

The Audit Committee provides appropriate and regular oversight. Through this forum, the Chief Financial Officer and Chief Tax Officer regularly update and engage Board members on crucial tax matters. The Chief Tax Officer prepares regular tax updates for the Audit Committee on corporate income tax compliance, the status of any ongoing tax audits and litigation, any tax planning opportunities, and any other tax affairs of significance.

Our tax risk management follows Trinseo’ s Delegation of Authority and applicable internal control processes. We have established robust governance arrangements to manage our tax affairs. These arrangements include clear lines of responsibility, regular tax risk assessments, and continuous training and development for employees involved in tax matters. We are dedicated to identifying, assessing, and managing tax risks in UK taxation and each country we operate in.

Our Global Tax Department is staffed with qualified and experienced individuals. Due to the complexity of both UK and international tax legislation. Trinseo uses external tax consultants where specific expertise is required, as well as for mitigating tax risks and complying with all tax laws.

2. Tax Planning

Our tax arrangements are derived from the commercial needs of our business operating model, which minimizes tax risk regarding compliance, uncertainty, cross-border transactions, and disputes.

Trinseo operates through legal entities established in countries where we undertake business operations or financing activities. All transactions between group companies are conducted on an arm’s length basis by OECD guidelines or other applicable principles and supported by appropriate documentation and studies.

Trinseo aims to responsibly utilize available tax incentives and exemptions provided by governments or tax authorities in the regions where we operate. We will actively engage with local tax authorities to establish a mutually agreed understanding of the criteria and legitimacy underpinning our claims for tax incentives or exemptions whenever possible.

3. Transparency and Relationships with Tax Authorities

Trinseo fully supports the moves towards greater transparency with tax authorities and the initiatives being introduced to enable this. We recognize the needs of society to raise taxes, and we are fully committed to meeting our legal obligations in this respect.

We believe in being proactive with tax authorities, both in terms of early communication and to obtain agreement on areas which reduce uncertainty for both Trinseo and the tax authorities. Our relationship with tax authorities is based on respect for the function they are performing and the legal framework in which we operate.

3. Review

We review and update this annually. It was last updated on 28th December 2023.