Corporate

CALLAWAY GOLF EUROPEAN HOLDING COMPANY LTD

1. Introduction
In compliance with UK legislation requirements of paragraph 19(2) Schedule 19 Finance Act 2016, the company is publishing its tax strategy for the year ending 31 December 2022, applicable to Callaway Golf European Holding Company Ltd. and all related Callaway UK based affiliated entities. This strategy is also applicable to Jack Wolfskin UK Ltd., Topgolf UK Holdings, LP and Golf Entertainment International Ltd. under the Finance Act 2016, Schedule 19 paragraph 22(2), 25(2) and 19(2) respectively. These entities are represented in this tax strategy disclosure, which are collectively described throughout as the “Callaway UK group”.

Our global business activities incur a variety of taxes, including corporate income taxes, stamp taxes, and in the UK, employer’s national insurance. In addition, we collect and pay employment taxes and indirect taxes such as Value Added Tax (VAT).

2. Commitment to compliance
The Callaway UK group is committed to complying with the UK tax law and practice. Compliance for the Callaway UK group means paying the right amount of tax at the right time. It involves disclosing all relevant facts and circumstances to the UK tax authorities and claiming reliefs and incentives where available. We see responsible administration and payment of taxation as a responsibility of our business.

3. Overall tax strategy

• Meet all legal requirements and to make all appropriate tax returns and tax payments.
• Seek to utilize available tax reliefs and incentives where available in a manner which is consistent with the government’s policy objectives.
• Consider the tax impact in major or complex business decisions.
• Operate in an environment where we consider tax in the context of our reputation and brand.
• Comply with appropriate tax risk processes, and ensure there is management oversight into this compliance in the UK and across the globe.

4. Tax risk management
We want our tax affairs to be transparent and compliant with tax legislation, and recognize that managing tax compliance is increasingly complex. We have established policies and processes in place to ensure the integrity of our tax filings and other tax compliance obligations in the UK and worldwide, and our tax processes are subject to the same level of internal controls, review and external audit as the rest of the business. Where there is significant uncertainty or complexity in relation to a risk, external advice may be sought. We have relationships with professional advisers that allow us to seek expert advice on specialist areas of tax.

Management sees compliance with tax legislation as key to managing our tax risk.

5. Responsible attitude toward tax planning
The Callaway UK group will undertake tax planning as part of our overall business strategy. We do not undertake aggressive tax planning and have a responsibility to minimize tax risk and exposure to negative publicity through non-compliance. We regularly review changes in tax legislation and assess their impact on our business.

6. Relationship with HM Revenue & Customs (HMRC)
The Callaway UK group seeks to ensure that our communication with HMRC is professional and focused on timely tax compliance. We do not take positions on tax matters that may create reputational risk or jeopardize the group’s good standing with the UK Tax Authorities, however, we are prepared to respectfully contest any ruling or decision of the UK Tax Authorities with which the Callaway UK group disagrees.

7. Board ownership and oversight
This tax strategy is aligned with the Callaway Golf Company Code of Conduct. Day to day execution of the tax strategy is the responsibility of the tax department.