Contract analysis

1. Engagement and Matter Description Calderwood & Harkness LLP ("C&H") has been retained by Halcyon Semiconductor AG ("HSAG"), a corporation organized under the laws of the Federal Republic of Germany, and its wholly-owned U.S. subsidiary, Halcyon Semiconductor Inc. ("HSI"), a Delaware C-Corporation, to pursue a bilateral Advance Pricing Agreement ("APA") between the Internal Revenue Service of the United States of A

2. Covered Transactions Summary The bilateral APA application covers the following categories of controlled transactions between HSAG and HSI: (a) Tangible Goods — Semiconductor Wafer and Die Sales HSAG fabricates semiconductor wafers and die at its facilities in Dresden, Germany, and sells such products to HSI on an intercompany basis. HSI receives the wafers and die at its facility in Austin, Texas, where it perfor

3. Proposed Transfer Pricing Methods The APA application will propose the following transfer pricing methods for each category of covered transaction: (a) Tangible Goods (Wafer/Die Sales): Transactional Net Margin Method ("TNMM") / Comparable Profits Method ("CPM"), with HSI as the tested party. The profit level indicator will be the operating margin or Berry ratio, benchmarked against comparable uncontrolled compani

4. Co-Applicant Parent Entity The co-applicant to the bilateral APA is the taxpayer's parent company: Halcyon Semiconductor AG Halcyon-Allee 12 01099 Dresden, Saxony Federal Republic of Germany Steuernummer (German Tax Identification Number): 203/118/04527 Umsatzsteuer-Identifikationsnummer (VAT Identification Number): DE 814 723 956 HSAG will file a corresponding application with the BZSt through its German counsel.

5. German Counsel The BZSt filing and coordination with the German competent authority is being handled by: Kettner Pflüger Rechtsanwälte Bockenheimer Landstraße 72 60323 Frankfurt am Main Federal Republic of Germany Responsible Partner: Dr. Tobias Kettner Telephone: +49 (69) 9055-2400 Email: kettner@kettner-pflueger.de Dr. Kettner and the Kettner Pflüger team are coordinating with C&H on the preparation of the bilat

6. APA User Fee The applicable user fee for a large case bilateral APA as of 2025 is $113,500. This user fee will be submitted with the formal APA application package (IRS Form 14661 and supporting documentation) by check payable to the United States Treasury, in accordance with Revenue Procedure 2015-41, Section 4.12.

7. Filing Target The formal APA application, consisting of IRS Form 14661, the supporting economic analysis, functional analysis, proposed APA terms, and all required documentation, together with this executed Form 2848 and the applicable user fee, is targeted for filing with the IRS Advance Pricing and Mutual Agreement Program (APMA) on or before July 7, 2025.

8. Proposed APA Term • Prospective Period: January 1, 2025 through December 31, 2029 (five taxable years) • Rollback Period: January 1, 2022 through December 31, 2024 (three taxable years) • Total Covered Period: Eight taxable years (2022 through 2029, inclusive) The rollback is contingent upon mutual agreement of the U.S. and German competent authorities and the taxpayer's consent to the application of the agreed-up

1. Original Filing: The original executed Form 2848 (together with Attachment A — Supplemental Statement) shall be submitted to the Internal Revenue Service as part of the formal APA application package. The cover letter accompanying the APA application shall be addressed to: Director, Advance Pricing and Mutual Agreement Program (APMA) Large Business & International Division Internal Revenue Service 1111 Constitutio

2. Copy — Calderwood & Harkness LLP: A copy of the executed Form 2848 and Supplemental Statement shall be retained by Calderwood & Harkness LLP in C&H Matter Number 1032-00006 files, in accordance with the firm's document retention policies.

3. Copy — Halcyon Semiconductor Inc.: A copy of the executed Form 2848 and Supplemental Statement shall be provided to Halcyon Semiconductor Inc. for the taxpayer's corporate tax records, care of: Priya Raghavan Vice President, Tax Halcyon Semiconductor Inc. 8700 Parmer Lane, Building 4 Austin, TX 78729 Email: praghavan@halcyonsemi.com

4. Copy — Halcyon Semiconductor AG: A copy of the executed Form 2848 and Supplemental Statement shall be provided for information purposes to the parent company's Group Tax function, care of: Dr. Erwin Fassbinder Senior Vice President, Group Tax Halcyon Semiconductor AG Halcyon-Allee 12 01099 Dresden, Saxony, Germany Email: e.fassbinder@halcyonsemi.de PRIVACY ACT AND PAPERWORK REDUCTION ACT NOTICE: Section 6109 of th