TAX STRATEGY

Think Academy International Education Limited

For the year ended 31 December 2021

1.Business overview

Think Academy International Education Limited (‘the Company’) is a wholly owned subsidiary of TAL Holding Limited incorporated in Hong Kong. TAL Education Group is the ultimate parent company, listed on the New York Stock Exchange (NYSE: TAL) and registered with U.S. Securities and Exchange Commission (SEC).

TAL Education Group, along with its affiliates (“the Group”) hold the core development goals of integrating technology with education, promoting innovation, and leading development within the Industry. The core business of the company is to offer education technology related products and services to help students improve academic results in Key Stage 1, Key Stage 2 and SATs Tests.

The Company is publishing this UK tax strategy statement pursuant to the requirements of the United Kingdom Finance Act 2016, Schedule 19, Large Businesses: Tax Strategies and Sanctions, paragraph 22(2).

This tax strategy has been reviewed and approved by the board of directors of the Company.

2.UK tax risk management and governance

The Company has a strong risk reporting and risk governance system in place to ensure effective management of UK tax risks.

The tax function of the Company is managed by the finance manager of the Company, subject to the approval and oversight of the tax team and the Chief Financial Officer (“CFO”) of the Group. The Audit Committee of the Group also continually monitor significant business activities within the Group to ensure the governance of all areas of financial, operational and regulatory risks.

Where appropriate, we obtain external expert advice to reduce or eliminate potential tax exposures. External professional advisors have been appointed to manage all UK tax compliance obligations on behalf of the Company, overseen by the tax team and the CFO of the Group.

3.Attitude towards tax planning

We strive to comply with all relevant laws, rules and regulations and only carry out tax planning that aligns with the substance of the underlying business operations and is consistent with the law. We will not engage in or promote tax planning transactions, structures or arrangements that might be perceived as aggressive. The company also seeks tax advice in areas of complexity and uncertainty.

4.Tolerance of UK tax risks

The level of risk that the Company accepts when it comes UK tax risks is low. The tax team of the Group and the Centre of Expertise (COE) team consistently evaluate our tolerance for tax risk while complying with UK tax obligations for the company and global tax obligations. We also regularly engage external tax professionals to advise on various tax matters.

5.Approach to dealing with HMRC

The company was established in February 2020 and is committed to building transparent, honest and collaborative relationships with HMRC. The company will endeavour to respond in a timely manner and as accurately and completely as possible to requests for information from the HMRC.

Publish Month: November 2021