Global Corporate Income Tax Matters Policy
As of April 2026
Adobe’s Board of Directors oversees the management of the Company’s business, driving effective decision‐making and performance,while serving as advocates for its stockholders to protect their long‐term interests. Adobe’s Audit Committee serves to assist the Board in fulfilling its responsibilities to oversee management’s financial, accounting and reporting processes, the Company’s system of internal accounting and financial controls, the Company’s enterprise risk management program,and the Company’s compliance with related legal, regulatory and ethical requirements. The Audit Committee’s scope of responsibility includes Adobe’s global tax matters, including review and approval of this policy.
As a global technology company, our activities contribute to economic growth and tax revenues in countries and communities around the world. Adobe is committed to compliance with the relevant tax laws, regulations, treaties, and other guidance based on its knowledge. Moreover, Adobe’s tax strategy is to proactively assess leading practices and standards in the business community and aims to be recognized for its practices and programs on corporate and tax governance, in conjunction with advice from external advisors and review by external auditors, of the application of these rules in every country and jurisdiction in which it operates. Adobe’s tax riskprofile is conservative and disciplined. It is based on the implementation of prudent risk management, consistent with its commitment and obligation to protect the interests of the Companyand its shareholders within a framework of support for the business strategy in the long term.
Taking into accountboth the corporate interests of the Company and its shareholders, Adobe’s conduct in tax matters shall be governed by the following:
PRINCIPLES:
- Monitor and comply with relevant tax laws, regulations, treaties, and other guidance, herein collectively referred to as “taxrules.”
- In accordance with relevant tax rules, the right payment of taxes required when due.
- As part of our global tax strategy, Adobe will not enter transactions that have no commercial rationale or economic substanceand only engages in tax planning where substantial legal authority exists. To the extent we secure a tax incentive, we comply with the requirements of such incentives.
- Implementation of relevant arm’s‐length transfer pricing policies in accordance with applicable rules in each jurisdiction weoperate.
- Strive to reduce uncertainty where appropriate with regard tothe interpretation of relevant tax rules. This may include the use of advance pricing agreements and other cooperative mechanisms, as well as the implementation of relationships with local tax authorities based on trust, integrity, andtransparency.
- Adobe seeks to resolve tax matters in a timely, cooperative, and good-faith manner with tax authorities in their audit activities in respect of Adobe companies, recognizing the legitimate right of the Company to disagree with tax authorities and to uphold its position before Courts based on our interpretation of the tax rules.
- Adobe aims to continue its practice of having adequate control mechanisms in place to ensure the fulfillment of the global tax policy, including employment and training of a finance team that is staffed with qualified and competent professionals that manage matters which have tax implications.
This policy is approved by the Audit Committee and the Chief Financial Officer, and any amendments to this policy is subject to their approval.
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