July 28, 2021
Name of company: Nippon Paint Holdings Co., Ltd. Representative: Yuichiro Wakatsuki
Representative Executive Officer & Co-President
Wee Siew Kim
Representative Executive Officer & Co-President Contact: Yukiko Yamamoto
General Manager of Public Relations
Email: nphd-kouho@nipponpaint.jp

Notice regarding Japan-U.S. Bilateral Consultations Agreement Involving Correction Notice Based on Transfer Pricing Taxation

Nippon Paint Holdings Co., Ltd. (Head Office: Chuo-ku, Tokyo; “NPHD”) and Nippon Paint Automotive Coatings Co., Ltd. (Head Office: Hirakata-shi, Osaka; “NPAC”) received a correction notice based on transfer pricing taxation from the Osaka Regional Taxation Bureau on June 25, 2020 regarding transactions* between NPHD and NPAC and the Nippon Paint Group’s US subsidiaries for the period from the fiscal year ended March 31, 2014 to the fiscal year ended December 31, 2017 (announced on June 25, 2020). NPHD and NPAC paid additional tax payable totaling about 700 million yen based on the correction notice.

NPHD and NPAC filed a request with the National Tax Agency of Japan in September 2020 for bilateral negotiations with the U.S. tax authorities based on the tax treaty in order to eliminate double taxation. We have received a notification of agreement on bilateral consultations from the National Tax Agency on July 21, 2021. Based on this agreement, we will receive a refund of corporate taxes. This refund will not have a material impact on our consolidated earnings for the year ending December 31, 2021.

* Transaction period: fiscal years ended March 31, 2014 and 2015 for NPHD; fiscal year ended March 31, 2016 to the fiscal year ended December 31, 2017 for NPAC