Lumen September 2020

UK Tax Strategy

As required by Schedule 19 of the Finance Act 2016, this document describes the tax strategy of Lumen Technologies, Inc’s direct and indirect UK subsidiaries (“Lumen UK”).

Compliance

Lumen UK complies with all applicable UK tax laws, rules and regulations. Compliance for Lumen UK means paying the right amount of tax at the right time, and making timely and accurate tax return filings with disclosure of all relevant facts and circumstances and claiming applicable reliefs and incentives available.

Attitude to tax planning and risk management

The day to day tax affairs of Lumen UK are managed by the UK tax team who collaborate closely with other parts of the business to provide timely advice and guidance to ensure compliance with applicable UK tax laws, regulations and best practice. Lumen UK does not engage in artificial tax planning. Any tax planning or structuring undertaken by Lumen UK will be aligned with our commercial, economic and reputational goals.

Lumen UK actively seeks to identify, evaluate, monitor and manage risks to ensure we remain in line with our objective of tax compliance, as set out above and also in line with the various reporting requirements, standards and guidelines such as IFRS, US GAAP and OECD.

Where there is uncertainty as to the application or interpretation of tax law, appropriate external advice may be sought evidencing the facts, risks and conclusions taken.

Professional relationship with tax authorities

Lumen UK is committed to minimising tax uncertainties and their impact on the overall business and will therefore maintain a professional working relationship with HMRC in relation to its UK tax affairs. Our general policy is to have a transparent and proactive interaction with HMRC conducted in a collaborative, courteous and timely manner.

On matters of differing legal interpretations, the aim would be to resolve disputed matters through a proactive, open discussion and negotiation with HMRC.

Lumen UK’s strategy is aligned to the group’s code of conduct (Lumen’s Code of Conduct), and is approved, reviewed and owned by its UK Board.