Subject:

Information on receipt by the Company of an individual tax ruling concerning corporate income tax regulations

Legal basis:

Art. 17 sec. 1 MAR – inside information.

Content:

The Management Board of R22 S.A. with its registered office in Poznań (the “Company”, the “Issuer”) hereby announces that Vercom S.A. (“Vercom”), a subsidiary of the Issuer, received an “Individual Tax Ruling” concerning corporate income tax regulations and matters related to preferential taxation of income generated by intellectual property rights (the “IP Box Relief”).

In the ruling issued, the Director of the National Revenue Information Service (the “Authority”, “KIS”) confirmed the correctness of the Company’s position with respect to all matters presented in Vercom’s application for the ruling.

KIS considered the Company’s position to be correct with respect to determining that:

– Vercom’s activities in which it created and develops the Redlink Platform and EmailLabs Platform Products meet the conditions for recognition as research and development activities referred to in Article 4a(26)-(28) of the Corporate Income Tax Act (the “CIT Act”);

– the Redlink Platform and EmailLabs Platform Products constitute qualified intellectual property rights within the meaning of Article 24d(2)(8) of the CIT Act, in respect of which Vercom is and will be entitled to apply preferential taxation, the so-called IP Box relief;

– Vercom correctly calculates and will calculate the Nexus ratio referred to in Article 24d(4) of the CIT Act in relation to the Redlink Platform and EmailLabs Platform Products;

– Vercom correctly recognises and calculates income from qualified intellectual property rights.

The Company notes that the facts presented in the application concerned the Redlink communication platform (including the Mobile Push solution) and EmailLabs.

The application of preferential taxation at the rate of 5% to income generated by intellectual property rights will have a material impact on Vercom’s financial results and the consolidated financial results of the R22 Capital Group. With respect to the results for the 12 months of 2019, the Company estimates this impact at PLN 1,2 million in tax savings. The Company notes that the IP Box Relief has not been applied in its financial statements to date and will be reflected in the next financial statements for the period ended 31 March 2020, scheduled for publication on 19 May 2020.