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UK TAXSTRATEGY
JUNE 2022

UK TAXSTRATEGY
The following document sets out the strategy of the UK companies within the Take-Two
Interactive Software group in relation to all UK taxation for the financial year ended
31 March 2024, in accordance with the requirements of Schedule 19 of the FinanceAct 2016(1). This policy covers not only corporate income tax but all other relevant UKtaxation (including, but not limited to, PAYE, VAT and customs duties).

Management of Tax Risks
and Governance Arrangements

1. 

All Take-Two employees, wherever located, are required to comply with our Code of Business Conduct and Ethics
which has been approved by the Board of Directors. The Code states that wherever we operate we will comply with allapplicable laws, rules and regulations. In addition, our Supplier Code of Conduct requires our suppliers to comply withall tax laws and regulations that relate to their work with us. Copies of both these documents can be found within theConduct and Social Responsibility section of the overall Take-Two investor relations website.
We are committed to compliance with all applicable tax laws. We seek to identify, evaluate, monitor and manage
tax risks to ensure that we comply with our legal obligations. We monitor changes to tax legislation and take advice
where appropriate from professional advisers to ensure we understand whether and how new or updated legislation
is applicable to our specific circumstances. Our strong commitment to tax compliance reflects our desire to minimise
tax risk.
As set out in our public filings, we operate in a wide variety of countries including the UK and it is inevitable that risks
may arise with respect to the application of tax laws that are complex and uncertain at times. Where the application oftax law to a given situation is reasonably unclear or uncertain we use outside advice to guide our response with the aimof reducing tax risks to acceptably low levels.
As a public company, we already have a variety of internal controls designed to ensure the accuracy of our financial
reporting and disclosures to shareholders. For tax matters, our procedures aim to ensure key tax decisions are madeby appropriate senior personnel who work under the overall direction of our Chief Financial Officer. In the UK this issupplemented by the work we undertake in connection with the UK’s Senior Accounting Officer legislation.

2.

Tax Planning

We aim to ensure that we comply with all applicable laws and that our intra-group arrangements reflect commercial
reality and take place on an arm’s length basis.
We may utilise relevant tax credits and incentives where these are in line with our own underlying businessobjectives. We take appropriate external advice to ensure compliance with the detailed rules that apply.

TAKE-TWO INTERACTIVE SOFTWARE, INC. n 110 W 44th Street n New York, NY 10036 n (646) 536-2842 n www.take2games.com

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JUNE 2022

3.

Working with HMRC

We engage with HMRC in an open and co-operative manner. As part of the engagement we proactively meetwith HMRC to discuss and explain our business and any relevant tax issues that may arise especially where there isuncertainty around the interpretation of tax law. We aim to resolve any differences through transparent discussions.

(1) This Strategy is published pursuant to Para 19(2), Schedule 19, FA 2016 in respect of Take-Two UK Holdings Limited (plus its UK subsidiaries), DMA Design Holdings
Limited (plus its UK subsidiaries), Hangar 13 UK Limited, Rollingmedia Limited, RDIP Limited, Rockstar Dundee Limited, Gram Games Limited and NaturalMotion Limited(plus its UK subsidiaries). and pursuant to Para 22(2), Schedule 19 FA 2016 in respect of Rockstar Leeds Limited, Rockstar Lincoln Limited, Rockstar London Limited,and Venom Games Limited.

TAKE-TWO INTERACTIVE SOFTWARE, INC. n 110 W 44th Street n New York, NY 10036 n (646) 536-2842 n www.take2games.com