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GROUP TAX STRATEGY

Graphcore Limited – Group Tax Strategy

Published in accordance with Finance Act 2016, Schedule 19.

This Tax Strategy publication applies to Graphcore Limited and all entities within the wider Graphcore Group (“Graphcore”). Graphcore was incorporated as a limited company registered in England and Wales in May 2016, and its principal activities are the research, design and development of hardware and software for AI systems that will expand and accelerate current and future machine intelligence applications.

Graphcore was acquired by the SoftBank Group Corp. (SBG) in July 2024 and is a wholly owned subsidiary of SBG. Graphcore works closely with other SBG companies and SBG group management but is responsible for its own tax governance.

Graphcore is committed to full compliance with applicable tax laws and regulations in all jurisdictions in which we operate. We aim to submit accurate and timely tax returns, make tax payments when due, and maintain transparent, constructive relationships with tax authorities. Our approach reflects our commitment to sound governance, responsible tax conduct, and a low-risk, commercially grounded approach to all tax matters.

Tax Risk Management and Governance

Graphcore maintains a structured approach to identifying, assessing, and mitigating tax risk. Tax risks are monitored through a tax risk register, which is maintained by the tax team and reviewed regularly. The tax team is involved in any significant business activities and transactions, ensuring that potential tax implications are identified at an early stage and managed appropriately.

Effective tax governance underpins our approach. We maintain a clear tax control framework designed to ensure compliance with our obligations and to give confidence in the accuracy of tax reporting. Risks are assessed for their financial, operational, and reputational significance, and appropriate controls are put in place to support tax compliance.

Graphcore ensures that tax considerations form part of business decision-making processes, with the tax team working closely alongside operational and financial stakeholders.

We invest in ongoing professional development so that our tax personnel remain informed of changes in legislation and best practice. Where specialist input is required, we engage external advisers to supplement the capability of our internal tax and finance teams.

Graphcore recognises the increasing shift toward digital tax administration and is working to ensure that our technology and reporting systems are prepared to meet more sophisticated electronic filing and data requirements in the future.

Attitude Toward Tax Planning

Graphcore adopts a zero-tolerance approach to tax evasion and aggressive or unlawful tax planning. All business activities are driven by genuine commercial purposes and reflect the economic substance of our operations, ensuring that any tax outcomes arise naturally from those activities. We do not engage in artificial or contrived arrangements, and we conduct our tax affairs in full alignment with both the letter and the spirit of applicable tax laws.

Graphcore makes use of tax incentives, reliefs, and deductions that are available in the jurisdictions in which it operates only where it is deemed appropriate and in line with commercial activities.

External advice is sought when clarity is required on specific technical matters or when changes in tax legislation may affect the business. All engagements with external advisers are managed by the VP of Finance, with oversight from the CFO, ensuring consistency with Graphcore’s values and Tax Strategy.

Tax Risk Appetite

Graphcore has a low appetite for tax risk. We act prudently in all areas of tax reporting, compliance, and planning. Responsibilities for tax matters are clearly defined, with activities undertaken by individuals who have the appropriate expertise and training. We encourage a risk-aware culture where employees understand their responsibilities and are supported by clear escalation channels for matters requiring senior attention.

Collaboration across business functions ensures that tax matters are considered in a holistic and consistent way, with the aim of reducing the likelihood of errors and ensuring compliance with internal policies and regulatory requirements.

Relationship with Tax Authorities

Graphcore aims to maintain open, honest, and transparent relationships with HMRC and other relevant tax authorities in the jurisdiction it operates in. Graphcore prepares and retains appropriate documentation to ensure compliance with regulatory requirements and to support the information submitted in tax filings. All tax compliance activities are supported by specialist tax and accounting advisers to ensure compliance with local tax laws.

We are committed to clear and accurate communication with tax authorities and to meeting all filing and payment deadlines. As part of the SoftBank Group, we have begun engaging with the wider Group’s HMRC Customer Compliance Manager and aim to continue to develop a cooperative and transparent relationship.

We proactively disclose relevant facts and provide additional explanations where appropriate to enable tax authorities to help them understand the nature and purpose of transactions. Where uncertainty exists in the interpretation of tax law, we consult external advisers and, when necessary, we aim to liaise proactively with HMRC or overseas tax authorities to achieve certainty and resolve matters collaboratively.

Approval and Publication

This Tax Strategy document wax approved by the Board of Directors of Graphcore Limited on 18 December 2025. It is published in accordance with the requirements of the Finance Act 2016, Schedule 19, and will be reviewed and updated annually.

How to contact us

If you have any questions about this policy, please contact us at:

Email: info@graphcore.ai
Phone: +44 (0) 117 214 1420
Post: 11-19 Wine Street, Bristol, BS1 2PH, UK

About us

Graphcore.ai is a site operated by Graphcore Limited (company number 10185006), whose registered office is 107 Cheapside, London, EC2V 6DN (Graphcore). VAT Number: 244987658.