Contract analysis

1. Introduction and Purpose We are pleased to provide you with the first quarterly status report on our engagement concerning the bilateral Advance Pricing Agreement ("APA") between the United States Internal Revenue Service ("IRS") and the German Federal Central Tax Office (Bundeszentralamt für Steuern, "BZSt"), together with the contemporaneous transfer pricing documentation for Halcyon Semiconductor AG ("HSAG") an

2. Engagement Progress — Work Completed to Date 2.1 Engagement Setup and Coordination Conflict Check. A comprehensive conflict check was completed on February 3, 2025, the date on which the engagement was formally opened. The conflict check was conducted in accordance with C&H's standard procedures and encompassed all current and former client relationships, adverse-party databases, and affiliations of the engagement

3. Upcoming Milestones 3.1 Pre-Filing Conference with IRS APMA — May 19, 2025 The pre-filing conference with the IRS APMA program has been scheduled for May 19, 2025 at the IRS offices in Washington, D.C. This is a significant milestone in the APA process, as the pre-filing conference provides the first opportunity for substantive dialogue with the APMA team regarding the proposed bilateral APA. Leonard Cross and Lei

4. Budget Utilization and Fee Summary 4.1 Phase 1 Fee Cap Status As set forth in the engagement letter, the Phase 1 engagement — encompassing the preparation and filing of the APA application and the preparation of contemporaneous transfer pricing documentation — is subject to a fee cap of $1,850,000. The table below summarizes the fees incurred through April 25, 2025: In addition, Meridian Economics GmbH has invoice

5. Coordination and Communication Items We wish to bring the following coordination and communication items to your attention: Internal Stakeholder Communications. We respectfully remind you that Margarethe Stein (Chief Financial Officer, HSAG) and Victor Almeida (President and General Manager, HSI) should be kept apprised of the engagement timeline, particularly the pre-filing conference scheduled for May 19, 2025 a

6. Next Quarterly Update The next quarterly status update, covering the second quarter of 2025, is expected to be delivered in late July 2025. The timing of the Q2 update is designed to follow the pre-filing conference (May 19, 2025) and to coincide closely with the formal APA application filing (target July 7, 2025), so that the Q2 update can report on both of these significant milestones. Specifically, the Q2 2025

7. Closing We appreciate the opportunity to provide this quarterly status report and trust that it gives you a comprehensive picture of the progress made during the first quarter of the engagement. Should you have any questions regarding any aspect of this letter or the engagement generally, please do not hesitate to contact Leonard Cross (responsible partner) at (212) 506-7112 or lcross@calderwoodharkness.com, or Le