Adyen’sResponsible
Approach to Tax

2Adyen’s Responsible
Approach to Tax
At Adyen, our commitment to responsible tax practices is fundamental.
By integrating this as a tax policy into our broader business strategy,
we want to fulfill our duties and pay our fair tax share, upholding ourresponsibility to stakeholders and the communities we serve.
This approach1 reflects our dedication to transparency and responsible
corporate (tax) behavior across Adyen N.V. and all legal entities,
branches and (representative) offices within the Adyen group.

This document is published in accordance with the Tax standard 207 of the Global Reporting Initiative (GRI), the VNO-NCW Tax Governance Code,VBDO Tax Transparency Benchmark, as well as the requirements set out in paragraph 22 (2) Schedule 19 of the UK Finance Act 2016.

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Our tax policy
This tax policy has been laid down by the Board of Managing Directors(hereafter the Management Board). It is guided by a conservative tax
strategy and underpinned by a low-risk appetite. We prioritize sustainable
and scalable practices that enable the business over aggressive tax
planning and aim to avoid double taxation.
More specifically, our tax policy consists of 5 interconnected tax principles
of conduct.

4Tax Principles of conduct
1. Our attitude to tax planning
Our business set-up is fully driven by commercial, sustainable and scalable
considerations and is aligned with the business activities we have. We pay
our fair tax share in all countries where we operate and do not seek refuge
in tax havens.2 Understanding how and where the different companies inour group create value is therefore key. Adyen’s tax team is tracking this inclose collaboration with all stakeholders involved. In line with this, we only
set up entities in countries where we actively do business, highlighting that
we do not create entities solely for the purpose of gaining tax advantages.
This also means that we will not enter into set-ups or transactions,
including arrangements with employees, merchants and contractors,
that are not aligned with our business model solely to obtain a tax benefit
or subsidy.
We make limited use of tax incentives or subsidies. When applying forthem, we ensure compliance aligning with our principles and values.
2. Tax compliance & risk appetite
We strive for full compliance with tax laws and regulations. This isunderpinned by a robust tax risk management strategy that proactively
identifies potential risks through top-down and bottom-up risk
assessments. This comprehensive approach ensures that we are aware ofand responsive to business changes and the evolving tax landscape.
We ensure that all tax filing positions are supported by documentation andthorough analysis. Members of the tax team participate in relevant external
training to ensure their knowledge is up to date and if specific knowledge is
not available in-house, we seek external advice.
We have a transfer pricing strategy in place which ensures that the charges
between our affiliated companies are at arm’s length, benchmarked andwell-documented in our transfer pricing documentation.
We support the principles of the OECD’s work on Base Erosion and Profit
Shifting (BEPS), including country-by-country reporting. We also value theimportance of taking the spirit and purpose of the law into account when
making tax decisions, and complying with the Environmental, Social andGovernance (ESG) framework.
Under our Whistleblowing Policy, anyone within Adyen can report concerns
about unethical or unlawful tax behavior. Tax evasive behavior is notaccepted. Adyen takes full responsibility for paying the right amount of tax,
at the right time, in the country where value is created.

2Adyen follows the EU list of non-cooperative jurisdictions to determine which country qualifies as'tax haven'.

53. Relationship with tax authorities & governments
We strive to maintain a balanced relationship with tax authorities andengage in regular dialogues, fostering a climate of mutual respect andunderstanding. We are open to participating in cooperative complianceagreements. This may result in Adyen concluding tax agreement(s) with tax
authorities to get upfront certainty on material tax implications that mayarise. Where disagreement arises, we are committed to be transparent andcollaborative with tax authorities to solve this.
Adyen intends to refrain from public policy advocacy on tax and tax
lobbying activities. We have no active involvement in the development oftax legislation. However, Adyen is willing to provide feedback to legislatorsor other stakeholders with the goal of achieving clear laws and guidance,ensuring efficient tax compliance processes and maintaining a levelplaying field.

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4. Accountability & Governance
The Management Board through its (co)CEO, CFO and other board
members ensure due observance of the tax principles of conduct set forthin this tax policy.
Within Adyen we have defined the roles and responsibilities when it comesto managing tax risks and ensuring that the compliance requirements aremet. This responsibility lies primarily with the Head of Tax and the tax leads
within the tax team.
Tax control framework
Adyen utilizes a tax control framework to manage and control Adyen’s
global tax risks. Having a robust governance, control, and tax risk
management system ensures that Adyen’s tax principles of conduct areproperly embedded within the organization.
Compliance with the tax control framework is effectuated through internal
controls for which evidence is documented and collected on a regularbasis. The internal control team monitors and tests effectiveness of the tax
control framework. We continuously seek new ways to embed automation
across all our tax processes, including tax control.
Adyen’s Head of Tax, Head of Group Finance and CFO are active membersof the Risk Committee and report on tax risks to the Risk Committee, butalso to the Audit and Risk sub-committee of the Supervisory Board (atleast yearly).
Adyen's independent Internal Audit function performs various audits.
Our external auditor annually audits our consolidated financial statements
which includes tax provisions following our tax risks.
The tax policy, i.e. Responsible Approach to Tax, is updated at least
annually or in case of significant changes by the Tax team. The Risk
Committee reviews this document before submitting it to the Management
Board for their approval.
5. Transparency
We maintain transparency regarding our tax management approach andthe amount of taxes we pay in the countries where we have a presence.
To do so, Adyen publishes a total tax contribution report as part of theannual report that covers both the corporate income taxes paid and thetaxes collected, such as: value added tax and payroll tax.

Final words
This document is approved by Adyen’s Risk Committee and Management
Board. It outlines the daily management of the tax function and reflects ourdedication to transparency and responsible corporate (tax) behavior.
Adyen’s tax team, the Head of Group Finance and CFO are responsible for
ensuring compliance with this tax policy.

Appendix 1: Compliance with VNO-NCW Tax Governance CodeTGC Section

Reference (publicly available)

A. Approach to Tax: Tax Strategy & Tax Principles
1. Tax strategy and approval

Responsible Approach to Tax on website

2. Board reporting

Responsible Approach to Tax on website

3. Tax strategy applicable to all group entities

Responsible Approach to Tax on website

4. Applicable for employees, customers, and contractors

Responsible Approach to Tax on website

B. Accountability & Tax Governance
1. Board accountability

Responsible Approach to Tax on website

2. Tax Control Framework

Responsible Approach to Tax on website

3. Internal and external audit

Responsible Approach to Tax on website

C. Tax compliance1. Complete, accurate and timely compliance

Responsible Approach to Tax on website

2. Responsible tax planning

Responsible Approach to Tax on website

3. Reasonable interpretation of tax laws

Responsible Approach to Tax on website

4. Use of tax incentives

Responsible Approach to Tax on website

5. Use of rulings from tax authorities

Responsible Approach to Tax on website

D. Business Structure
1. Tax havens

Responsible Approach to Tax on website

2. Tax on value creation

Responsible Approach to Tax on website

3. Arm's length principle

Responsible Approach to Tax on website

E. Relationships with Authorities and Other External Stakeholders
1. Cooperative relationships with authorities

Responsible Approach to Tax on website

2. Constructive dialogue

Responsible Approach to Tax on website

3. Disputed issues and controversy

Responsible Approach to Tax on website

F. Tax Transparency & Reporting
1. Tax policy and tax risk management policy published

Responsible Approach to Tax on website

2. List of entities owned

Total Tax Contribution in Annual Report

3. CIT paid and accrued per country

Total Tax Contribution in Annual Report

4. Taxes borne and collected

Total Tax Contribution in Annual Report

5. Tax incentives

Total Tax Contribution in Annual Report

6. Advocacy approach

Responsible Approach to Tax on website