Tax Disclosure

Earnings, Payouts, and ALL Marketplace Sales

Document Version: ALL-TD-v1.0.0 / Legal Pack Version: ALL-LP-v1.0.0

Effective Date: 26 October 2026 | Last Updated: 26 October 2026

1. Purpose and Scope

1.1 Purpose

This Tax Disclosure ("Disclosure") explains the tax responsibilities that arise in connection with earnings, payouts, and sales made through the ALL Platform, ALL360 Devices, ALL360 OS, ALL Control Tower, and the ALL Marketplace (collectively, the "Platform"), operated by All360 Technology S.A., a company incorporated in the Republic of Panama ("ALL", "we", "us", "our").

ALL360 Devices and ALL360 OS licences are sold and licensed by Allecosystem Technologies LLC, a company incorporated in the United Arab Emirates (the "Seller"). In respect of the sale, delivery, return, refund, and warranty of ALL360 Devices and the grant of ALL360 OS licences, references to "ALL" include the Seller. Invoices for ALL360 Devices and ALL360 OS licences are issued by the Seller.

1.2 Who This Disclosure Applies To

This Disclosure applies to: (a) Node Operators receiving a share of Qualifying Revenue; (b) Developers (also referred to as "Builders") receiving Builder Revenue from App sales, subscriptions, in-App purchases, or usage-based charges in the ALL Marketplace; (c) Affiliates receiving commissions or referral rewards; and (d) Customers and other Users purchasing ALL360 Devices, licences, subscriptions, Apps, or other products and services through the Platform.

1.3 Relationship to Other Documents

This Disclosure supplements Section 8.6 (Taxes) and Section 10.3 (DAC7 and Tax Reporting) of the Node Operator Master Agreement, Section 8.5 (Taxes) of the ALL Developer License Agreement, and any equivalent provisions in Affiliate or Business Customer agreements. In the event of conflict, the applicable role-specific agreement prevails. Capitalised terms not defined herein have the meanings given to them in the Terms of Use or the applicable role-specific agreement.

2. Your Responsibility for Taxes

2.1 General Responsibility

You are solely responsible for determining, reporting, and paying all taxes, duties, levies, social security contributions, and similar charges arising from your participation in the Platform, including on earnings, payouts, commissions, Builder Revenue, and any gains or losses arising from digital assets you receive. This responsibility applies whether or not ALL issues any statement, form, or report to you or to any tax authority, and whether or not any tax is withheld by ALL.

2.2 Possible Tax Treatment of Earnings

Depending on your jurisdiction and circumstances, amounts you receive through the Platform may be treated, among other things, as:

• Ordinary income, business or trading income, self-employment income, or income from independent services;
• Income subject to social security, national insurance, or similar contributions;
• Income from the supply of services or the provision of digital services that is itself subject to VAT, GST, or sales tax, where you are, or are required to be, registered for such taxes;
• Income received in digital assets, which in many jurisdictions is valued at its fair market value in local currency at the time of receipt, with any subsequent disposal, conversion, or exchange of those digital assets potentially giving rise to a separate taxable gain or loss.

ALL does not determine, and makes no representation regarding, how your earnings will be characterised or taxed.

2.3 Deductible Expenses

Whether the cost of an ALL360 Device, electricity, internet service, fees, or other expenses can be deducted, depreciated, or otherwise offset against your earnings depends on the law of your jurisdiction and your circumstances. You should retain evidence of all such expenses.

2.4 Location of Nodes

If you operate a Node located in a jurisdiction other than your jurisdiction of tax residence, or if you move a Node across borders, additional tax obligations may arise in that other jurisdiction. You must notify ALL of any change in the location of a Node as required by the Node Operator Master Agreement.

3. Tax Information and Documentation

3.1 Information You Must Provide

To comply with tax reporting, withholding, and verification obligations, ALL or its PSP/VASP may request, and you must provide accurately, completely, and on a timely basis:

• Your full legal name or entity name, date of birth or date of incorporation, and residential or registered address;
• Your country or countries of tax residence and your taxpayer identification number (TIN), VAT number, or equivalent identifier in each such country;
• For legal entities, business registration details and, where required, information on controlling persons;
• Self-certification forms or tax forms required by applicable regimes, including IRS Forms W-9 or W-8 series where US tax rules apply, and equivalent forms under other regimes;
• The location of each Node and the countries in which you provide services through the Platform;
• Bank account or digital-asset wallet details used for payouts, as required for reporting purposes.

3.2 Accuracy and Updates

You must ensure that the information you provide remains accurate and must update it within thirty (30) days of any change, including any change in your tax residence. You are responsible for any tax, penalty, or interest resulting from inaccurate, incomplete, or outdated information.

3.3 Consequences of Failure to Provide Information

If you do not provide required information, or if information provided cannot be verified, ALL may, in accordance with the applicable role-specific agreement and applicable law: (a) withhold tax at the highest applicable rate; (b) place a hold on payouts until the information is provided; (c) suspend access to earnings features; and (d) report you to competent tax authorities as required by law.

4. Tax Reporting by ALL

4.1 Reporting Regimes

ALL may be required to collect, verify, and report information about you and the amounts paid or credited to you to competent tax authorities under applicable reporting regimes, which may include, depending on your circumstances and ALL's obligations from time to time:

• The EU Directive on Administrative Cooperation as amended by Council Directive (EU) 2021/514 ("DAC7") and equivalent platform reporting rules adopted under the OECD Model Rules for Reporting by Platform Operators with respect to Sellers in the Sharing and Gig Economy;
• Reporting regimes for crypto-asset transactions, including the OECD Crypto-Asset Reporting Framework ("CARF") and Council Directive (EU) 2023/2226 ("DAC8"), where applicable to ALL or to the PSP/VASP;
• US information-reporting rules, including Form 1099 series reporting, where applicable to ALL or to the PSP/VASP;
• Any other reporting regime applicable in a jurisdiction in which ALL operates or in which you are resident.

4.2 Information Shared with Tax Authorities

Where required, ALL may report your identity, TIN, address, the amounts paid or credited to you, the fees and commissions deducted by ALL, the number of transactions, and payout account identifiers. ALL processes such personal data as described in the ALL Privacy Policy. Where required by law, ALL will provide you with a copy of the information reported about you.

4.3 Annual Statements

ALL will make available through the Platform dashboard or Developer Portal statements showing amounts credited, fees deducted, taxes withheld, and payouts made during each billing period and calendar year. These statements are provided for your convenience and do not constitute tax forms unless expressly identified as such. You remain responsible for maintaining your own records.

5. Withholding Tax

5.1 Withholding Where Required

ALL may withhold taxes from earnings, Builder Revenue, commissions, or payouts where it is required to do so by applicable law, including where you have not provided valid tax documentation. Amounts withheld are remitted to the relevant tax authority and are treated as paid to you for the purposes of the applicable agreement.

5.2 Treaty Benefits

Where you claim a reduced rate of withholding under a tax treaty, you must provide all documentation required to support that claim. ALL is not responsible for determining your eligibility for treaty benefits and may apply the default rate where documentation is incomplete or cannot be verified.

5.3 Documentation of Withholding

Where tax is withheld, ALL will provide documentation of the amount withheld to the extent required by law, which may be used by you to claim a credit or refund from the relevant tax authority. ALL does not process refunds of taxes withheld; any such refund must be claimed from the relevant tax authority.

6. Taxes on ALL Marketplace Sales

6.1 Indirect Taxes on App Sales

Sales of Apps, subscriptions, in-App purchases, and usage-based charges through the ALL Marketplace may be subject to value added tax (VAT), goods and services tax (GST), sales tax, digital services tax, or similar indirect taxes ("Indirect Taxes") in the jurisdiction of the User.

6.2 ALL as Collecting Party

Where applicable law treats ALL as the supplier, deemed supplier, marketplace facilitator, or otherwise liable to collect Indirect Taxes on App sales made through the ALL Marketplace (including under rules applicable to electronically supplied services facilitated through electronic interfaces), ALL will calculate, collect from the User, and remit such Indirect Taxes. In such cases, Indirect Taxes collected by ALL are excluded from the gross amount used to calculate Builder Revenue, and the Builder must not separately charge or account for the same Indirect Taxes on those sales.

6.3 Builder Responsibility

Where ALL is not required to collect Indirect Taxes on a sale, the Builder remains responsible for determining whether Indirect Taxes apply to its supplies and for registering, charging, reporting, and paying any such taxes. In addition, Indirect Taxes may apply to the Platform Fee charged by ALL to the Builder, and the Builder is responsible for accounting for any such taxes under the reverse-charge mechanism or otherwise as required by applicable law.

6.4 Builder Income Taxes

Builder Revenue is the Builder's income and is subject to the Builder's own income tax, corporate tax, or other direct tax obligations. The Builder must not represent to Users or tax authorities that ALL is the seller of the App, except where ALL is treated as the supplier under Section 6.2.

6.5 Prices Displayed to Users

Prices displayed in the ALL Marketplace may be shown inclusive or exclusive of Indirect Taxes depending on the User's location and applicable law. Where prices are shown exclusive of Indirect Taxes, the applicable amount will be displayed before the User completes the purchase.

7. Taxes on Device and Service Purchases

7.1 Purchases by Customers

The purchase price of an ALL360 Device, any OS licensing or platform access fee, and any subscription or other service purchased from ALL may be subject to Indirect Taxes, customs duties, import VAT, and handling or brokerage charges in the jurisdiction of delivery. Unless stated otherwise at checkout, such taxes, duties, and charges are payable by the purchaser, and they may be collected by ALL at checkout or by the carrier or customs authority upon delivery. ALL360 Devices are shipped from China; deliveries into the European Union, the United Kingdom, and other jurisdictions are therefore imports that may be subject to import VAT, customs duties, and clearance charges, unless the checkout states that such amounts are included in the price.

7.2 Business Purchasers

Business purchasers who provide a valid VAT, GST, or equivalent registration number may, where applicable law permits, be supplied without Indirect Taxes and must self-account for such taxes under the reverse-charge mechanism.

7.3 Invoices

ALL will issue invoices or receipts for purchases in the form required by applicable law. Requests for corrected or additional tax invoices must be submitted to [email protected] within the period required by applicable law.

8. Tax Events Relating to Digital Assets

Where payouts are made in digital assets, the following may each give rise to separate tax consequences depending on your jurisdiction: the receipt of the digital asset; its conversion into fiat currency or another digital asset; its use to purchase goods or services; and its transfer between wallets. Blockchain network fees and PSP/VASP fees may or may not be deductible. You are responsible for recording the fair market value of each digital asset received at the time of receipt and for tracking your cost basis.

9. Record-keeping

You should keep complete and accurate records of all amounts earned, credited, withheld, and paid out, all fees deducted, all expenses incurred, and all transactions involving digital assets received through the Platform, for at least the period required by the law of your jurisdiction. ALL's retention of records is described in the ALL Privacy Policy and may not cover the full period required of you.

10. Changes in Tax Law

Tax laws, reporting obligations, and withholding requirements may change at any time, including with retroactive effect. ALL may update its tax processes, documentation requirements, and this Disclosure to comply with any change in law without prior notice where immediate compliance is required. Any change in ALL's tax obligations may affect the net amount you receive.

11. Indemnity

To the extent permitted by applicable law and as provided in the applicable role-specific agreement, you will indemnify ALL against any tax, penalty, interest, or cost incurred by ALL as a result of your failure to comply with your tax obligations or your provision of inaccurate or incomplete tax information.

12. Contact Information

This Disclosure should be read together with the ALL Platform Terms of Use, the Node Operator Master Agreement, the ALL Developer License Agreement, the Earnings Disclaimer, and the Privacy Policy, all of which are available on the Platform website.