AP Moller Maersk : Tax information

Separation and official listing of Svitzer Group

One share became two

Upon the separation and official listing of Svitzer Group, the shareholders of A.P. Moller - Maersk automatically became shareholders in Svitzer Group with a number of shares determined based on the shareholders' holding of shares in A.P. Moller - Maersk.

For each share in A.P. Moller - Maersk with a nominal value of DKK 1,000 (both A and B shares), two shares in Svitzer Group were received, and for each share in A.P. Moller - Maersk with a nominal value of DKK 500 (both A and B shares), one share in Svitzer Group was received. There is only one share class in Svitzer Group and all shareholders will have equal rights, including voting rights.

General meeting

The separation and official listing of Svitzer Group was subject to the demerger of A.P. Moller - Maersk, which was approved at the extraordinary general meeting of A.P. Moller - Maersk on 26 April 2024.

The last day of trading in A.P Moller - Maersk shares including Svitzer was 29 April 2024. The first day of trading in the Svitzer Group share on Nasdaq Copenhagen was 30 April 2024 under the ticker symbol SVITZR and the ISIN code DK0062616637.

Taxation

The Danish Tax Agency (in Danish: Skattestyrelsen) has approved the demerger of A.P. Moller - Maersk as a tax-exempt transaction for Danish shareholders. A.P. Moller - Maersk and Svitzer Group do not provide tax advice and the information below is only guidance for shareholders who are fully taxable to Denmark. Non-Danish shareholders are encouraged to seek advice from their own tax advisors. A.P. Moller - Maersk and Svitzer Group assume no responsibility for the information contained herein.

Following the completion of the demerger, a ratio is calculated that allocates the original purchase price between your A.P. Moller - Maersk shares and your new Svitzer Group shares. You should use this allocation of the original purchase price when calculating any gains or losses on any subsequent sale of your shares.

For tax purposes, the shareholders are deemed to have acquired the shares in Svitzer Group at the same time as the original shares in A.P. Moller - Maersk. The Danish National Tax Board (in Danish: Skatterådet) has confirmed that the calculation of the new purchase price for tax purposes shall be based on the average quoted value of the two companies during the first 20 trading days on Nasdaq Copenhagen from 30 April 2024 - i.e. up to and including 30 May 2024.

Calculation of new purchase price for tax purposes
		A.P. Moller - Maersk	A.P. Moller - Maersk
		A share with a	B share with a
		nominal value of DKK	nominal value of DKK
	Ref.	1,000	1,000	Comment
Volume weighted average
share price for the A.P.
Moller - Maersk share	(A)	DKK 10,638.41	DKK 11,017.68
after 20 days of trading
following demerger
Volume weighted average
share price for the Svitzer
Group share after 20 days	(B)	DKK 236.87	DKK 236.87
of trading following
demerger

Calculation of adjustment to original purchase price

Adjustment (factor) to

original purchase price for (C) 0.9574 one A.P. Moller - Maersk

share

Adjustment (factor) to

original purchase price for (D) 0.0213 one Svitzer Group share

Example: Calculation of new purchase prices

Original purchase price

(DKK) for one A.P. Moller -	(E)	DKK 12,300
Maersk share
New purchase price for
one A.P. Moller - Maersk	(F)	DKK 11,776
share
New purchase price for	(G)	DKK 262
one Svitzer Group share

0.9588		Calculation: C = A / (A + B x 2)
0.0206		Calculation: D = B / (A + B x 2)
		Assumption for calculation of
DKK 12,800		new purchase price for tax
		purposes
DKK 12,272		Calculation: F = E x C
DKK 264		Calculation: G = E x D

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