Global Corporate Income Tax Matters Policy

Updated April 2020

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, and specifically this policy, which it approved on April 29, 2020.

Adobe’s Chief Financial Officer signed this document below as an affirmation of this policy.

Adobe’s tax strategy is committed to compliance with the relevant tax laws, regulations, treaties, and other guidance based on its knowledge, 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. Moreover, Adobe strives to follow the best standards in the business community and aims to be recognized for its practices and programs on corporate and tax governance. Adobe’s risk profile 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 Company and its shareholders within a framework of support for the business strategy in the long term, while avoiding inefficiencies in the implementation of business decisions. Accordingly, and taking into account both the corporate interests of the Company and its shareholders, Adobe’s conduct in tax matters shall be governed by the following:

PRINCIPLES:

• Compliance with relevant tax laws, regulations, treaties, and other guidance.
• In accordance with relevant law, the right payment of taxes required when due.
• As part of our global tax strategy, Adobe does not enter into transactions that have no commercial rationale and only engages in tax planning where substantial legal authority exists. To the extent we secure an incentive, we comply with the requirements of such incentives.
• Implementation of a relevant arm’s‐length transfer pricing policies.
• Strive to reduce uncertainty where appropriate with regard to the interpretation of relevant laws. This may include the use of tax forums, advance pricing agreements, and other cooperative mechanisms provided by jurisdictions, as well as the implementation of relationships with local tax authorities based on trust, integrity, and transparency.
• Cooperation 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 law.
• Adobe aims to continue its practice of having adequate control mechanisms in place to ensure the fulfillment of the preceding principles, including employment of a Finance team that is staffed with qualified and competent professionals that manage matters which have tax implications.

This policy has been approved by John Murphy, Executive Vice President and Chief Financial Officer for Adobe.

Adobe UK Tax Strategy