Moderna Biotech UK Limited – Tax StrategyIntroduction
This Tax Strategy is published in compliance with paragraph 16(2) of Schedule 19 of the UK FinanceAct 2016 with respect to the financial year ending 31 December 2022.
References to “tax” or “taxes” are to the UK taxes and duties set out in paragraph 15(1) of Schedule
19, which includes income tax, corporation tax, PAYE, NIC, VAT, Insurance Premium Tax and Stamp
Duty Land Tax, and to all similar worldwide taxes for which Moderna UK has legal responsibility.
References to Moderna are to Moderna, Inc. References to Moderna UK are to Moderna Biotech UK
Limited and its UK affiliates.
This document sets forth the approach of Moderna UK towards the management and control overits tax affairs as well as the general framework within which Moderna UK operates when
considering tax related issues. It applies to all Moderna UK companies and covers all applicabletaxes.
About Moderna
Moderna is a global biotechnology company pioneering a new class of medicines made ofmessenger RNA (mRNA). Our platform builds on continuous advances in basic and applied mRNAscience, delivery technology and manufacturing, providing us the capability to pursue in parallel arobust pipeline of new development candidates. We are developing therapeutics and vaccines for
infectious diseases, immuno-oncology, rare diseases, autoimmune diseases, and cardiovasculardiseases, independently and with our strategic collaborators. Our mission is to deliver the greatest
possible impact to people through mRNA medicines.
Moderna UK is involved in research and development, including collaboration with various research
institutions, healthcare organizations and government bodies. Moderna UK is involved in thedistribution of the company’s COVID-19 vaccine and is currently building a manufacturing facility
for future production of respiratory vaccines.
Risk Management and GovernanceAt the highest level, responsibility for taxes resides with Moderna’s Global Tax Department basedin Moderna’s headquarters in the United States. The Senior Vice President, Tax reports toModerna’s Chief Financial Officer. The Senior Vice President, Tax, along with the global tax
leadership team have oversight over the material tax matters of Moderna’s worldwide businessand supply chain. Day to day management of Moderna UK’s taxes is delegated to the InternationalTax Director responsible for the UK.
Compliance with tax rules is critical to managing our tax risk. Moderna UK has implemented
standardized and automated compliance processes to ensure we meet all compliance, disclosure,and regulatory obligations, including filing all relevant tax returns and making required tax
payments on time. We engage with tax authorities in a timely manner to disclose all relevant facts
and circumstances to maintain a transparent and constructive relationship based on trust.

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Tax Risk
Moderna UK is committed to acting with integrity and transparency in all tax matters, including
compliance with all relevant laws, rules, regulations, and reporting requirements. Our approach isto manage tax risks and costs in a manner consistent with applicable regulatory requirements,
considering operational, economic, and reputational factors.
Tax Planning
Moderna UK’s approach to tax planning is aligned with, and in furtherance of, its commercial
business operations, together with its research, development, and supply chain needs, consistent
with the approach adopted by the global Moderna group of companies. We do not engage inaggressive tax planning or in artificial tax planning schemes that lack economic substance and havea principal purpose of obtaining a tax advantage. We may, however, make use of statutorily
available reliefs such as research and development credits.
Relationship with Her Majesty’s Revenue & Customs (HMRC)
Moderna UK seeks to have a transparent and constructive relationship with all tax authorities,including HMRC, through regular meetings and communications in respect of developments in theGroup’s business, current, future, and retrospective tax risks, and interpretation of the law inrelation to all relevant taxes. When submitting tax computations and returns to HMRC, Moderna
UK discloses all relevant facts and identifies any transactions or issues where it considers that there
is potential for the tax treatment to be uncertain. We recognize that that there may be situations
where Moderna UK and HMRC hold differing legal interpretations that drive different tax outcomes.
In such cases, Moderna UK will actively engage in discussions with HMRC to resolve conflicts as
rapidly as possible. Moderna UK recognizes, however, that not all differences can be resolved andas a last resort Moderna UK would consider litigation to reach a conclusion on an issue.

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