Common use of Other cases Clause in Contracts

Other cases. 0 Treaty Partners (de minimis rule applies) Cases in 2022 start inventory - Cases started in 2022 Cases closed in 2022 The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. MAP Outcomes - TP cases denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted n.a. resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Outcomes - other cases 33% 67% Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Total MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) category of cases no. of pre-2016 cases in MAP inventory on 1 January 2022 number of pre-2016 cases closed during the reporting period by outcome: no. of pre- 2016 cases remaining in on MAP inventory on 31 December 2022 average time taken (in months) for closing pre- 2016 cases during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome 2022 MAP Statistics - Guernsey (Bailiwick of).xlsx Page 4/9 MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for Attribution/Allocation Cases Table 1: Attribution / Allocation MAP Cases Treaty Partner no. of post- 2015 cases in MAP inventory on 1 January 2022 no. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome: no. of post- 2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for other Cases Table 2: Other MAP Cases Treaty Partner no. of post- 2015 cases in MAP inventory on 1 January 2022 no. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome no. of post-2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Row 1 Total n.a. n.a. n.a. n.a. Notes: Row 1 Treaty Partners (de minimis rule applies) 5.18 3.84 3.13 2.05 Total 5.18 3.84 3.13 2.05 Notes: Row 1 Total Average Time 5.18 3.84 3.13 2.05 Notes: Total MAP Caseload Start inventory on Cases started 01.01.2021 Cases closed End inventory on

Other cases. Cases started as from 1 January 2016 Start to End Receipt to Start to Milestone 1 Start Milestone 1 to End Note: the average times to close MAP cases that started as from 1 January 2016 were computed according to the MAP statistics reporting framework available at xxxx://xxx.xxxx.xxx/tax/dispute/mutual-agreement-procedure-statistics-reporting- Transfer pricing cases 8.45 1.15 8.15 0.30 framework.pdf Other cases 6.68 2.30 1.74 13.77 18 8 6 4 2 0 Transfer pricing cases Cases in 2018 start inventory + cases started in 2018 Cases closed in 2018 Other cases 30 25 20 15 10 5 0 29 11 0 0 Belgium Treaty Partners (de minimis rule appliesOthers) Cases in 2022 2018 start inventory - Cases + cases started in 2022 2018 Cases closed in 2022 2018 0 0 0 1 The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. The label "Treaty Partners (Others)" applies to treaty partners that are not reporting MAP Outcomes - TP cases statistics for the reporting period. The relevant MAP statistics are aggregated under this category. denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted n.a. 6% 6% resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Outcomes - other cases 336% 675% 11% Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Total MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) category of cases no. of pre-2016 cases in MAP inventory on 1 January 2022 number of pre-2016 cases closed during the reporting period by outcome: no. of pre- 2016 cases remaining in on MAP inventory on 31 December 2022 The average time taken to close pre-2016 cases was computed by applying the following rules: (i) start date: the date of reception of the MAP request. For MAP cases submitted in monthsthe other State, the Portuguese competent authority accepted the date that the other State communicated as "start date"; and (ii) for closing pre- 2016 cases during end date: the reporting period denied date of the notification to the taxpayer on the outcome of the MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome 2022 MAP Statistics - Guernsey (Bailiwick of).xlsx Page 4/9 MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for Attribution/Allocation Cases Table 1: Attribution / Allocation MAP Cases Treaty Partner nocase. of post- 2015 cases in MAP inventory on 1 January 2022 no. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome: no. of post- 2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for other Cases Table 2: Other MAP Cases Treaty Partner no. of post- 2015 cases in MAP inventory on 1 January 2022 no. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome no. of post-2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Row 1 Total Spain 8.45 1.15 8.15 0.30 Row 2 Treaty Partners (de minimis rule applies) n.a. n.a. n.a. n.a. Notes: Row 3 Treaty Partners (Others) n.a. n.a. n.a. n.a. Total Average Time 8.45 1.15 8.15 0.30 Row 1 Belgium 5.11 3.45 3.25 21.44 Row 2 Treaty Partners (de minimis rule applies) 5.18 3.84 3.13 2.05 7.39 1.77 1.44 12.24 Row 3 Treaty Partners (Others) n.a. n.a. n.a. n.a. Total 5.18 3.84 3.13 2.05 Notes: Average Time 6.68 2.30 1.74 13.77 Row 1 Total Average Time 5.18 3.84 3.13 2.05 6.78 2.23 2.66 11.85 Notes: Total MAP Caseload Start inventory on Cases started 01.01.2021 Cases closed End inventory on50 40

Other cases. Note: although one transfer pricing case was closed in 2018, Pakistan did not report any time taken to close this MAP case. n.a. Transfer pricing cases 0 0 Treaty Partners (de minimis rule applies) Treaty Partners (Others) Cases in 2022 2018 start inventory - Cases + cases started in 2022 2018 Cases closed in 2022 2018 Other cases 0 0 0 Treaty Partners (de minimis rule applies) Treaty Partners (Others) Cases in 2018 start inventory + cases started in 2018 Cases closed in 2018 The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. The label "Treaty Partners (Others)" applies to treaty partners that are not reporting MAP Outcomes - TP cases statistics for the reporting period. The relevant MAP statistics are aggregated under this category. denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted n.a. resolved via domestic remedy remedy a. agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Outcomes - other cases 33% 67% Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Total Notes Para 1 of Article 24 (MAP) of Double Taxation Treaty with the treaty partner stipulates that the case for MAP Statistics Reporting for must be presented within three years from the 2022 Reporting Period first notification of the action resulting in taxation. Request was made after the expiry of the three years. Row 2 Treaty Partners (1 January 2022 to 31 December 2022de minimis rule applies) category of cases non.a. of pre-2016 cases in MAP inventory on 1 January 2022 number of pre-2016 cases closed during the reporting period by outcome: non.a. of pre- 2016 cases remaining in on MAP inventory on 31 December 2022 average time taken n.a. n.a. Row 3 Treaty Partners (in monthsOthers) for closing pre- 2016 cases during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome 2022 MAP Statistics - Guernsey n.a. n.a. n.a. n.a. Total Average Time n.a. n.a. n.a. n.a. Row 2 Treaty Partners (Bailiwick of).xlsx Page 4/9 MAP Statistics Reporting for the 2022 Reporting Period de minimis rule applies) n.a. n.a. n.a. n.a. Row 3 Treaty Partners (1 January 2022 to 31 December 2022Others) for Attribution/Allocation Cases Table 1: Attribution / Allocation MAP Cases Treaty Partner non.a. of post- 2015 cases in MAP inventory on 1 January 2022 non.a. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome: non.a. of post- 2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for other Cases Table 2: Other MAP Cases Treaty Partner non.a. of post- 2015 cases in MAP inventory on 1 January 2022 noTotal Average Time n.a. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome non.a. of post-2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome n.a. n.a. Row 1 Total Average Time n.a. n.a. n.a. n.a. Notes: Row 1 Treaty Partners (de minimis rule applies) 5.18 3.84 3.13 2.05 Total 5.18 3.84 3.13 2.05 Notes: Row 1 Total Average Time 5.18 3.84 3.13 2.05 Notes: Total MAP Caseload Start inventory on Cases started 01.01.2021 Cases closed End inventory on:

Other cases. 0 Treaty Partners (de minimis rule applies) Cases in 2022 start inventory - Cases started in 2022 Cases closed in 2022 The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. n.a. MAP Outcomes - other cases n.a. MAP Outcomes - TP cases denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted n.a. resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Outcomes - other cases 33% 67% Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Total MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) category of cases no. of pre-2016 cases in MAP inventory on 1 January 2022 number of pre-2016 cases closed during the reporting period by outcome: no. of pre- 2016 cases remaining in on MAP inventory on 31 December 2022 average time taken (in months) for closing pre- 2016 cases during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome 2022 MAP Statistics - Guernsey (Bailiwick of).xlsx Page 4/9 MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for Attribution/Allocation Cases Table 1: Attribution / Allocation MAP Cases Treaty Partner no. of post- 2015 cases in MAP inventory on 1 January 2022 no. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome: no. of post- 2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation eliminated / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome MAP Statistics Reporting for the 2022 Reporting Period (1 January 2022 to 31 December 2022) for other Cases Table 2: Other MAP Cases Treaty Partner no. of post- 2015 cases in MAP inventory on 1 January 2022 no. of post- 2015 cases started during the reporting period number of post-2015 cases closed during the reporting period by outcome no. of post-2015 cases remaining in MAP inventory on 31 December 2022 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy agreement fully eliminating double taxation / fully resolving taxation not in accordance with tax treaty agreement partially eliminating double taxation / partially resolving taxation not in accordance with tax treaty agreement that there is no taxation not in accordance with tax treaty no agreement including agreement to disagree any other outcome Row 1 Total n.a. n.a. n.a. n.a. Notes: Row 1 Treaty Partners (de minimis rule applies) 5.18 3.84 3.13 2.05 Total 5.18 3.84 3.13 2.05 n.a. n.a. n.a. n.a. Notes: Row 1 Total Average Time 5.18 3.84 3.13 2.05 n.a. n.a. n.a. n.a. Notes: Total MAP Caseload Start inventory on Cases started 01.01.2021 Cases closed End inventory on