#WearItForMe MTN Group Limited Tax report for the year ended 31 December 2020 Leading digital solutions for Africa’s progress 01 Tax report Contents 01 TAX REPORT 1 Salient features 2 Foreword 3 Economic contribution 4 Current tax environment (international) 6 MTN’s approach to tax 8 Continuous improved tax governance and transparency MTN is an emerging market mobile operator at the forefront of technological and digital changes. Inspired by our belief that everyone deserves the benefits of a modern connected life, we provide a diverse range of voice, data, digital, fintech, wholesale and enterprise services to more than 280m customers in 21 markets. We were established in South Africa at the dawn of Our online reports: democracy in 1994 as a leader in transformation. Since AFS CDP GRI IR then, we have grown by investing in sophisticated communication infrastructure and by harnessing the Annual Carbon Global Integrated Financial Disclosure Reporting Report talent of our diverse team of more than 19 000 people to Statements Project Initiative now offer services to communities across Africa and the KIV SR TAX Middle East. MTN is one of the top 40 companies listed on King IV™ Sustainability Tax the JSE in Johannesburg, with a market capitalisation of application Report Report R108 billion at the end of 2020. MTN Group Limited Tax report for the year ended 31 December 2020 01 Tax report Salient features Group total tax contribution LA Group revenue R35,1bn R179,4bn 2019: R30,5bn 2019: R151,5bn Group profit before tax Adjusted Group profit before tax R29,1bn R25,5bn3 2019: R17,7bn1 2019: R16,9bn Reported Group effective Adjusted Group effective tax rate tax rate 32,45% 37,78%4 2019: 38,95%2 2019: 40,89%4 Taxes on production5 Taxes on profit6 R16,6bn R7,7bn 2019: R15,9bn 2019: R8,3bn 1 Restated Group profit before tax. 2 Updated Group effective tax rate due to restated Group profit before tax. 3 Adjusted Group profit before tax represents Group profit before tax as reported excluding: Impairment of goodwill and investment in joint ventures (2020: R1,07 billion and 2019: Rnil); Non-taxable gain from sale of Ghana and Uganda Tower InterCo BV/(from Jumia dilution and sale of Amadeus and Travelstart) (2020: -R6,13 billion and 2019: -R1,04 billion); Nigeria regulatory fine and related expenses (line item includes unwinding interest on the Nigeria fine liability and the amortisation of fees related to the listing of MTN Nigeria) (2020: R0,2 billion and 2019: R0,2 billion); and Impairment loss on remeasurement of non-current assets held for sale (2020: R1,51 billion and 2019: Rnil). 4 The adjusted Group effective tax rate is calculated by dividing the Group reported tax number (after adjusting for the tax impacts of the numbers included in footnote 2 above, as applicable) by the adjusted group profit before tax. 5 Taxes on production are made up of all indirect taxes and withholding taxes collected and borne by MTN. 6 Taxes on profit are made up of corporate taxes borne by MTN, education tax borne by MTN and dividend taxes borne and collected by MTN. LA Limited assurance. Assurance report and definition available at www.mtn.com. MTN Group Limited Tax report for the year ended 31 December 2020 1 01 Tax report Foreword Tax transparency requires that companies move beyond merely providing their tax numbers and performance. In the ‘MTN’s approach to tax’ section of this year’s report we have endeavoured to provide readers with an understanding of the Company’s approach to tax, risk management, tax planning as well as our views on specific tax risks. We also give our approach to dealing with uncertain tax positions, such as transfer pricing disputes and the MTN Nigeria matter related to the Attorney General of the Federal Republic of Nigeria (AGF). Both are covered in more detail under the ‘Uncertain tax position’ section of this report. We remain committed to building and maintaining cordial relationships with all regulatory authorities, and with all stakeholders. Businesses contribute to enhancing sustainable societies in many ways, with the taxes they pay being just one of these ways. In 2020, MTN Group continued to contribute significantly to the communities in which we operate through, for example, supporting the fight against Acting Group Chief Financial Officer COVID-19 (see page 15 of our Integrated Report); Sugentharen Perumal progressing digital and financial inclusion; promoting local ownership; supporting youth employment and skills development; investing in infrastructure and network In many of the countries within which we operate, MTN is coverage; developing businesses in our supply chain; and one of the biggest taxpayers. With this comes a of course through our contribution to tax revenues. The responsibility to report thoroughly and transparently on latter goes significantly beyond the corporate income taxes our tax affairs. At MTN, this reporting is subject to our paid on our profits. In this report, in the ‘total tax system controls and internal financial controls. We contribution’ section we endeavour to quantify this maintain this in line with our standard processes and contribution, which includes (but is not limited to) corporate procedures on enterprise risk management and taxes, indirect taxes, withholding taxes, payroll taxes, governance. operating licence fees and other payments to government authorities. In the year our total tax contribution amounted In 2020, we prepared and submitted our country-by- to R35,1 billion. country report to the South African Revenue Service for 2019. In their Building Public Trust report published Integrity is one of MTN’s core values: we are committed to in February 20217, PricewaterhouseCoopers (PwC) used transparency, and complete candour is one of our vital extracts from our 2019 tax report as an example of good behaviours. This voluntary report is testament to our tax transparency. This was after an independent review values. It is an effort to explain our tax affairs clearly, panel of the PwC Building Public Trust report commended demonstrate our business’s value creation, and in so doing MTN as the company that best demonstrated consistent improve our business reputation and build and maintain performance in tax reporting8 among the top 100 listed trust with our many stakeholders. We appreciate your companies by market capitalisation on the JSE Limited at interest. 31 December 2019, in the multinational companies’ category. This recognition was for MTN’s clear communication of detailed information on tax-related matters, as well as the positioning of these disclosures Sugen Perumal to demonstrate the Group’s contribution to the societies Acting Group Chief Financial Officer to which we are accountable. Fairland April 2020 7 https://www.pwc.co.za/en/assets/pdf/building-public-trust-through-tax-reporting-2021.pdf 8 https://www.pwc.co.za/en/publications/building-public-trust.html MTN Group Limited Tax report for the year ended 31 December 2020 2 01 Tax report Economic contribution As one of the largest mobile operators in our markets, we MTN, as a leading brand in the markets in which we acknowledge that our activities have significant operate, believes we have a key role to play in assisting to implications for the communities in the regions in which we minimise the likelihood of transmission of COVID-19 and its operate. It is vital that we understand exactly who is impact on society. The Group provided essential support affected by our activities so that we can ensure their through the MTN Global Staff Emergency Fund for interests are promoted when strategic business decisions employees and Y’ello Hope packages for our customers, are made. MTN has identified the following as our most communities and other stakeholders. The Group material stakeholders: governments and regulators; civil contributed R107 million through its foundations towards society; the investment community; subscribers/ healthcare and government relief efforts in support of the customers; and MTN people. fight against the pandemic. This support consisted of R58 million donation to six countries as government VALUE DISTRIBUTION relief funds, R40,5 million donated in personal protective Our activities drive economic value within each of the equipment and healthcare support, and R8,4 million jurisdictions in which we operate. This value is distributed contributed towards food security supporting 120 000 to our stakeholders in a multitude of ways only some of people. which are measurable. These include: Our digital inclusion investments continued to lead digital 1. Business solutions for Africa’s progress to broadly span the financial, During 2020, MTN spent R118,0 billion (2019: R119,6 billion) health, education, enterprise and public sector categories, with suppliers and contractors. among others. More detail on MTN’s digital inclusion initiatives can be found in the 2020 MTN Group sustainability We committed capital expenditure of R28,6 billion report in the integrated reports link on our website, (R26,3 billion in 2019). MTN South Africa’s share of capital www.mtn.com. expenditure (capex) amounted to R7,2 billion (R7,6 billion in 2019); and MTN Nigeria’s capex amounted to R12,7 billion 4. Governments (R8,0 billion in 2019). In 2020 we made a significant contribution to government revenues in the regions where we operate. This information In 2021 we will continue to invest in our networks to ensure is detailed in the ‘total tax contribution’ section of this we are ready for the digital revolution and plan to increase report. We are often the largest taxpayer in the markets our capex spend to R29,4 billion (in 2020: R28,5 billion). within which we operate. 2. Employees 5. Digital inclusion In 2020, MTN had 19 295 (19 288 in 2019) employees MTN delivered another solid operational and financial representing 58 different nationalities.