U.K. Tax Strategy

Wabash National Corporation and Subsidiaries’ Approach to Taxation

Headquartered in Lafayette, Indiana, Wabash National Corporation (NYSE: WNC) is a diversified industrial manufacturer and North America’s leading producer of semi-trailers and liquid transportation systems. Established in 1985, the company manufactures a diverse range of products including: dry freight and refrigerated trailers, platform trailers, bulk tank trailers, dry and refrigerated truck bodies, truck-mounted tanks, intermodal equipment, aircraft refueling equipment, structural composite panels and products, trailer aerodynamic solutions, and specialty food grade and pharmaceutical equipment.

Wabash has permanent establishments in the United States, Mexico, the United Kingdom and Singapore. Due to our presence in these countries and business activities with customers and suppliers in other countries, our activities incur a variety of business taxes. We pay corporate income taxes, employment taxes, customs duties and other business taxes in all jurisdictions where applicable. In addition, we collect and remit, to various taxing authorities, employee and indirect taxes such as sales, excise and value added tax (VAT).

Wabash National’s Code of Conduct is the foundation for our values and how we operate our businesses, including our approach to taxation. We are committed to compliance with all applicable tax laws in the jurisdictions in which we do business and support initiatives to increase public trust and transparency.

To fulfill the new requirements under UK law and demonstrate transparency of our approach to taxation, this document discloses:

• Our approach to risk management and governance in relation to UK taxation
• Our approach to tax planning
• The level of risk we are prepared to accept in relation to UK taxation
• Our approach to dealing with UK taxing authorities

Risk management and governance in relation to UK taxation

As with all jurisdictions where Wabash National operates, our policy, as emphasized in our Code of Conduct, is to operate with integrity by doing what is honest, fair and in the company’s best interest.

With respect to managing UK tax risks, our policy is to comply with all applicable regulatory requirements, taking into account operational, economic and reputational factors.

We maintain policies, procedures and processes to ensure accuracy and compliance of our tax returns and tax payments in all countries in which we operate. We ensure our professional tax staff has the necessary training and education to properly determine and manage our tax responsibilities. These policies, procedures and processes are reviewed annually by our internal audit department.

Tax planning

Business transactions, such as acquisition, divestments and intragroup trade, and the associated business purpose of these transactions determine our approach to tax planning and related tax liabilities.

We access government sponsored tax incentives where appropriate and aligned to our business activities. We apply OECD guidelines and local country legislation to our intercompany transactions.

Level of risk we are prepared to accept in relation to UK taxation

Our approach to tax risk is integral to our broader business risk management and compliance framework. We manage tax risk in the context of the business purpose of transactions.

Our processes, policies, and governance operate to ensure compliance with tax laws and regulations in the jurisdictions where we operate and are designed to identify and mitigate material tax risks. Wabash National associates are required to comply with all relevant laws and regulations and conduct business in accordance with our Code of Conduct.

Approach to dealing with UK tax authorities

We seek to develop and maintain professional, cooperative and transparent relationships with all tax authorities. We ensure there is access to relevant information demonstrating the integrity of our tax processes, compliance and payments.