11. Taxes

Basic tax rules and tax risk management

The correct and complete fulfilment of tax obligations is an important area of attention. This concerns corporate income tax and all other taxes that apply to Enexis.

The starting points with regard to taxation and social security contributions are as follows:

• Enexis acts in accordance with the applicable tax laws and regulations, and

• Enexis' working methods are aimed at maintaining an open, constructive, and respectful working relationship with all bodies involved in taxation and social security contributions.

For Enexis, compliance with tax legislation means filing tax returns correctly, paying taxes on time, and providing accurate information to all relevant tax authorities. Enexis acts not only in accordance with the explicit tax rules and regulations, but also in accordance with the underlying intentions and principles of that legislation. Enexis is aware of the social importance of paying taxes correctly and does not engage in tax optimisation that damages our social integrity. In its publications, both internal and external, Enexis is transparent about taxes and the tax risks it runs. Enexis is open to feedback on its actions as part of its commitment to continuous improvement.

At the end of 2025, an individual Horizontal Monitoring Agreement was signed. The re-signing of the agreement means that Horizontal Monitoring has been applicable to Enexis without interruption since the beginning of 2012. In this agreement, Enexis and the Tax and Customs Administration agreed to base their relationship on transparency, understanding, and trust. Of course, the rights and obligations based on laws and regulations continue to apply in full. The 2025 agreement was concluded for a period of three years. Early termination or suspension by one of the parties is possible under certain conditions.

Tax groups

Enexis Holding N.V. forms a tax group for corporate income tax together with its subsidiaries. The companies that were members of the tax group at year-end 2025 are: Enexis Netbeheer B.V., Enexis Personeel B.V., Enexis Vastgoed B.V., Enpuls B.V., Enpuls Projecten B.V., and Mijnwater Warmte Infra B.V. Within this group of companies, the corporate income tax that Enexis Holding N.V. owes the Dutch Tax and Customs Administration is apportioned among the companies included in the tax group based on realised commercial results, taking into account the applicable exemptions, investment schemes, and non-deductible amounts. In the event of changes in the composition of the tax group, deferred tax items are settled between Enexis Holding N.V. and the relevant group company or companies.

With the exception of Mijnwater Warmte Infra B.V., the aforementioned companies also form a tax group for turnover tax (VAT). The turnover tax owed by Enexis Holding N.V. to the Tax and Customs Administration is settled with the group companies in accordance with the turnover tax owed on an individual basis. Companies are jointly and severally liable for the tax liabilities of the tax group over the period in which they belong to the tax group.

Corporate income tax

Enexis’ business activities are subject to corporate income tax. The tax on the result for the reporting period comprises current, offsetable, and deferred corporate income tax. The corporate income tax is included on the income statement, except when it relates to items recognised directly in equity.

The Dutch Minimum Taxation Act 2024 came into force on 1 January 2024. Enexis Holding N.V. and all its subsidiaries, as a domestic group, fall within the scope of this act. The act is not expected to result in an additional tax assessment for Enexis because the tax we pay on profits, expressed as a percentage of the result and calculated in accordance with the Minimum Taxation Act 2024, is much higher than 15%. In 2026, the first additional tax assessment information return, for the 2024 financial year, will be submitted.

The corporate income tax for 2025 amounted to €138 million (2024: €86 million).

The corporate income tax can be specified as follows:

The corporate income tax was calculated as follows:

The permanent differences between the calculation of the commercial result and the result for tax purposes are primarily due to the utilisation of investment schemes for tax deductions on energy and environmental investments. As a result of these investment schemes, our investments in sustainable and environmentally friendly assets provided a tax deduction of €4 million in 2025 (2024: €17 million). The deduction in 2025 was lower than in previous financial years because, with effect from 2025, some of the assets in which Enexis invests are no longer eligible for the environmental investment deduction due to stricter legislation.

There were no uncertain tax liabilities arising from previous years as of year-end 2025. Final assessments have been imposed up to and including the 2022 fiscal year. Corporation tax returns have been filed up to and including the 2024 fiscal year.

The reconciliation of the statutory income tax rate with the reported income tax rate (€138 million), expressed as a percentage of profit before tax (€538 million), is as follows: