Mitsui & Co., Ltd. ("Mitsui", Head Office: Tokyo, President and CEO: Kenichi Hori) submitted an undertaking to the Republic of India in pursuit of securing tax relief for Earlyguard Limited ("Earlyguard"), its wholly owned UK subsidiary.

In April 2007, Earlyguard sold all its shares in Finsider International Company Limited ("Finsider"), a UK company, which in turn held shares of the Indian iron ore company Sesa Goa. Earlyguard treated the capital gain according to the tax laws at that time, however, in May 2012 the Indian Finance Act was amended and gain on transfer of shares in a non-Indian company which derives value from underlying Indian assets was deemed taxable. Subsequently, Earlyguard was served with a tax demand, and in February 2021, Earlyguard brought an investment treaty arbitration against the Republic of India under the UK-India Bilateral Investment Treaty in order to dispute the validity of the tax demand.

Thereafter, the Republic of India enacted the Taxation Laws (Amendment) Act 2021 (the "Act") in August 2021 and the Income-Tax (31st Amendment) Rules 2021 (the "Rules") in October, and it became possible to secure tax relief by fulfilling certain procedures. Mitsui and Earlyguard are conducting necessary procedures under the Act and the Rules in pursuit of securing tax relief, and as part of such procedure, Mitsui submitted an undertaking and the Republic of India has accepted the same. Please refer to the attached file for details of the submission.