Figma UK Limited

UK Tax Strategy

Financial Year 2025

Introduction

Figma, Inc. is one of the world's leading collaborative design platform, empowering teams to design, prototype, and develop products together. This document sets out the UK tax strategy of Figma UK Limited (the “Company”) in accordance with paragraph 22(2) of Schedule 19 of the Finance Act 2016. It applies from the date of publication until it is superseded.

Figma is committed to operating with integrity and transparency in all markets. These principles apply equally to the way the Company manages its tax affairs.

Tax Governance

The Company's risk management relating to financial, accounting, and tax matters is led by the Chief Financial Officer (CFO) and ultimately overseen by the Audit Committee of the Board of Directors (Board) of Figma, Inc. The Board meets with management on a quarterly basis.The day-to-day management of the Company's tax affairs is led by the Global Head of Tax.

The Company engages an independent accounting firm to assist with the preparation of its UK financial statements, and a separate local accounting firm performs the statutory audit. The Company is committed to using external tax advisors to provide guidance necessary to assess tax risks and to ensure its compliance with applicable tax laws and regulations.

The tax function works to stay current with changes to UK tax law and HMRC guidance. For complex or specialist matters, the Company engages local professional advisors with appropriate expertise.

Tax Planning and Compliance

The Company is committed to complying with all UK tax legislation, filing obligations, and reporting requirements. This means paying the correct amount of tax to HMRC on a timely basis and making full and accurate disclosure of all relevant facts and circumstances. In the event of any inadvertent error, appropriate disclosure will be made to HMRC promptly.

The Company does not engage in artificial tax arrangements or transactions lacking genuine commercial substance. Any planning undertaken is grounded in commercial objectives and aligned with UK law and OECD guidelines. Where UK government-sponsored reliefs are available and applicable, the Company will claim them as intended. Intercompany transactions are conducted on an arm's-length basis in accordance with OECD Transfer Pricing Guidelines and applicable UK legislation.

In determining its approach to tax planning, the Company has regard to Figma’s broader guiding principles, including its Code of Conduct and its commitment to integrity, transparency, and respect in every market in which it operates. The Company also considers the reputational implications of its tax positions for its employees, shareholders, and the wider communities in which it operates, weighing these considerations alongside legal and commercial factors in all tax planning decisions.

Risk Management

The Company proactively seeks to identify, evaluate, manage, and monitor UK tax risks. Tax risks and associated controls are documented within Figma's internal controls framework, which is aligned with the global SOX compliance program. Accountability for individual tax processes is assigned to appropriate owners within the tax and finance functions, and controls are reviewed on a regular basis to ensure they remain effective.

The Company maintains a low appetite for UK tax risk, reflecting its focus on certainty and its wider reputational considerations. This risk appetite is set by the Board and CFO and applied by the Head of Tax through the internal controls framework described above, under which risks are assessed against defined thresholds and monitored on an ongoing basis.

Material or novel risks, and matters involving significant uncertainty or complexity, are escalated to the CFO and Board, with input sought from external advisors and, where appropriate, HMRC, before a position is finalized. This ensures that decisions reflect the views of relevant internal and external stakeholders and remain proportionate to the Company's risk appetite.

Relationship with HMRC

The Company is committed to a transparent, constructive, and cooperative relationship with HMRC. This includes timely and accurate filing of returns, full disclosure of relevant information, and responding to queries with integrity. The Company will seek to resolve any disputed matters through pro-active and transparent discussion and negotiation.