INCOME TAXES

The following table presents a reconciliation of the Irish federal statutory income tax rate of 12.5%, the trading income tax rate of the Company’s country of domicile, to the Company’s effective income tax rate for the year ended December 31, 2025. The reconciliation is disaggregated by nature of reconciling item and by jurisdiction, where applicable.


Component	Income from continuing operations before income taxes and equity earnings	Tax Effect	Rate Effect
	(U.S. Dollars in thousands)	(U.S. Dollars in thousands)
Ireland Statutory Rate	168,223	21,028	12.50	%
Ireland
Effect of cross border tax laws
Pillar 2- income inclusion		3,356	2.00	%
Nontaxable and nondeductible items		(294)	(0.17)	%
Income not subject to income tax due to tonnage tax		(3,187)	(1.89)	%
Change in valuation allowance		275	0.16	%
Withholding taxes		745	0.44	%
Other		(20)	(0.01)	%
Foreign tax effects:
Bermuda
Nondeductible expenses		1,996	1.19	%
Other		26	0.02	%
Chile
Effect of rates different than statutory		3,449	2.05	%
Change in valuation allowance		1,788	1.06	%
Foreign currency remeasurement effects		(3,171)	(1.88)	%
Other		281	0.17	%
Costa Rica
Effect of rates different than statutory		3,355	1.99	%
Foreign currency remeasurement effects		(1,733)	(1.03)	%
Branch profits tax		1,798	1.07	%
Other		(662)	(0.39)	%
Ecuador
Effect of rates different than statutory		2,103	1.25	%
Other		271	0.16	%


Component	Income from continuing operations before income taxes and equity earnings		Tax Effect		Rate Effect
	(U.S. Dollars in thousands)		(U.S. Dollars in thousands)
Spain
Effect of rates different than statutory			4,067		2.42	%
Other			(828)		(0.49)	%
U.K.
Effect of rates different than statutory			1,658		0.99	%
Other			812		0.48	%
Honduras
Losses with no tax benefit			4,808		2.86	%
Nontaxable insurance proceeds			(5,083)		(3.02)	%
Nondeductible expenses			1,789		1.06	%
Other			984		0.59	%
Mexico
Losses with no tax benefit			1,202		0.71	%
Other			(641)		(0.38)	%
Sweden
Effect of rates different than statutory			1,328		0.79	%
Other			990		0.59	%
U.S.
State and local income taxes			1,905		1.13	%
Effect of rates different than statutory U.S. branches			(2,632)		(1.56)	%
Subpart F income net of foreign tax credit			1,526		0.91	%
Base erosion tax			2,262		1.34	%
Change in valuation allowance			19,179		11.40	%
Other			1,436		0.85	%
Canada			2,691		1.60	%
Germany			2,642		1.57	%
Other foreign jurisdiction			3,925		2.33	%
Worldwide changes in unrecognized tax benefits			(4,421)		(2.63)	%
	$	168,223	$	71,003	42.21	%

The differences between the reported income tax expense (benefit) and income tax expense (benefit) computed at the Irish statutory income tax rate of 12.5%, the trading income tax rate of the Company’s country of domicile, for the years ended December 31, 2024 and December 31, 2023, are explained in the following reconciliation:


	Year Ended
	December 31, 2024		December 31, 2023

Expense (benefit) computed at the Irish statutory rate of 12.5%	$	29,955	$	25,741
Effects of:
Foreign income taxed at different rates	35,969		26,471
Nondeductible goodwill impairment	4,526		—
Foreign currency remeasurement effects	(2,512)		(7,632)
Change in valuation allowances	(7,961)		(15,366)
Expenses not deductible for income tax purposes	7,289		3,393
Income not taxable	(1,179)		(1,962)
Interest expense not deductible for income tax purposes	830		—
Changes in unrecognized tax benefits, net of indirect effects	5,123		(2,349)
Changes in estimates made in respect of prior periods	3,609		15,307
Other items	—		(12)
Income tax expense (benefit)	75,649		43,591

The Company paid income taxes in the following jurisdictions for the year ended December 31, 2025:


	Year Ended
	December 31, 2025
	(U.S. Dollars in thousands)
Ireland	$	1,951
Foreign
Costa Rica	7,144
Chile	8,476
Ecuador	8,225
Spain	7,866
U.S. - Federal	37,144
Other	29,294
Total foreign	$	98,149
Total	$	100,100

The Company is subject to income taxation in Ireland, the United States, state jurisdictions, and various foreign jurisdictions. The following table presents income tax expense (benefit) by selected jurisdiction for each of the years ended December 31, 2025, December 31, 2024 and December 31, 2023:


	Year Ended
	December 31, 2025		December 31, 2024		December 31, 2023

Current tax expense (benefit):	(U.S. Dollars in thousands)
Ireland	$	4,636	$	657	$	(92)
U.S.	10,691		25,847		18,884
Foreign - excluding the U.S. and Ireland	42,701		66,733		37,399
	58,028		93,237		56,191
Deferred tax expense (benefit):
Ireland	(1,565)		163		(235)
U.S.	11,879		(5,916)		(4,562)
Foreign - excluding the U.S. and Ireland	2,661		(11,835)		(7,803)
	12,975		(17,588)		(12,600)
	$	71,003	$	75,649	$	43,591

Income (loss) from continuing operations before income taxes and equity earnings consisted of the following:


	Year Ended
	December 31, 2025		December 31, 2024		December 31, 2023

	(U.S. Dollars in thousands)
Ireland	$	23,526	$	120	$	(13,119)
U.S.	(4,393)		37,856		41,798
Foreign - excluding the U.S. and Ireland	149,090		201,664		177,248
	$	168,223	$	239,640	$	205,927

Deferred tax expense (benefit) expense recognized directly in other comprehensive income (loss) and equity method earnings was as follows:


	Year Ended
	December 31, 2025		December 31, 2024		December 31, 2023

	(U.S. Dollars in thousands)
Pension and postretirement benefits	$	(2,450)	$	(4,527)	$	(3,549)
Derivatives	(6,892)		(578)		(5,213)
Equity method	—		—		138
Total deferred tax (benefit) recognized in other comprehensive income (loss) and equity method earnings	$	(9,342)	$	(5,105)	$	(8,624)

The following table provides details of the principal components of our deferred tax assets and liabilities as of December 31, 2025 and December 31, 2024:


	December 31, 2025		December 31, 2024

Deferred tax assets:	(U.S. Dollars in thousands)
Other intangible assets	$	476	$	1,154
Property, plant and equipment	38,077		37,652
Operating lease liabilities	28,283		47,586
Accounts payable and accrued liabilities	37,511		30,503
Pension and postretirement benefits	27,344		27,222
Operating loss carry-forwards	131,222		121,788
Tax credit carry-forwards	2,387		1,904
Investments in unconsolidated affiliates	1,074		980
Other	23,770		18,817
Total deferred tax assets	290,144		287,606
Valuation allowances	(89,133)		(64,424)
Offset against deferred tax liabilities	(112,342)		(140,698)
Total deferred tax assets, net	$	88,669	$	82,484
Deferred tax liabilities:
Other intangible assets	$	5,264	$	7,382
DOLE® brand	76,570		76,570
Property, plant and equipment	76,238		80,737
Operating lease right-of-use assets	27,909		46,997
Accounts payable and accrued liabilities	7,869		4,294
Pension and postretirement benefits	6,569		5,923
Investments in unconsolidated affiliates	202		152
Other	1,821		3,355
Total deferred tax liabilities	202,442		225,410
Offset against deferred tax assets	(112,342)		(140,698)
Total deferred tax liabilities, net	$	90,100	$	84,712

As of December 31, 2025, Dole had approximately $1.1 billion of operating loss carryforwards expiring as follows:


	Ireland		U.S.		Foreign (excluding U.S. and Ireland)		Total

	(U.S. Dollars in thousands)
2025	$	—	$	10,299	$	10	$	10,309
2026	—		18,782		—		18,782
2027	—		23,907		150		24,057
2028	—		28,854		6,504		35,358
2029	—		20,897		2,728		23,625
2030-2045	—		491,713		6,144		497,857
Indefinite	45,224		327,608		140,637		513,469
Total	$	45,224	$	922,060	$	156,173	$	1,123,457

As of December 31, 2025, U.S. state tax credit carryforwards of $0.3 million include $0.3 million which will expire between 2026 and 2029. In addition, Dole has $2.1 million of U.S. federal foreign tax credit carryforwards. If unused, $0.7 million will expire in 2029, $0.3 million will expire in 2032, $0.1 million will expire in 2033, $0.4 million will expire in 2034 and $0.6 million will expire in 2035.

The following table presents the movement in the valuation allowance for the years ended December 31, 2025, December 31, 2024 and December 31, 2023:


	Amount
	(U.S. Dollars in thousands)
Balance as of December 31, 2022	$	90,945
Increase recognized in the income statement	8,036
Decrease recognized in the income statement	(23,402)
Translation adjustments	(117)
Balance as of December 31, 2023	75,462
Increase recognized in the income statement	1,156
Decrease recognized in the income statement	(9,117)
Translation adjustments	(3,077)
Balance as of December 31, 2024	64,424
Increase recognized in the income statement	25,077
Current Year Reclass from Discontinued Operations	4,065
Decrease recognized in the income statement	(5,157)
Translation adjustments	724
Balance as of December 31, 2025	$	89,133

The valuation allowance increased by $24.7 million in the year ended December 31, 2025 and decreased by $11.0 million in the year ended December 31, 2024, and $15.5 million in the year ended year ended December 31, 2023. The 2025 increase includes a net increase of $19.9 million recognized in the consolidated statements of operations, a $4.1 million increase from discontinued operations and $0.7 million increase of exchange rate translation adjustments.

Dole is an Irish holding company that operates a significant number of foreign subsidiaries. As of December 31, 2025, the Company had not recognized a deferred tax liability on approximately $719.7 million of undistributed earnings for certain foreign subsidiaries, because these earnings are intended to be indefinitely reinvested. If such earnings were distributed, some countries may impose additional taxes. The unrecognized deferred tax liability (the amount payable if distributed) is approximately $75.1 million. Dole recognizes deferred tax assets on potential foreign tax credits expected to be generated by the repatriation of undistributed earnings only when the repatriation has occurred or is apparent to occur in the foreseeable future.

A reconciliation of the beginning and ending amount of unrecognized tax benefits (excluding interest and penalties) is as follows:


	Amount
	(U.S. Dollars in thousands)
Balance as of December 31, 2022	$	10,733
Decreases due to lapse of statute of limitations	(2,952)
Translation adjustments	212
Balance as of December 31, 2023	7,993
Increases due to tax positions taken in the current year	5,488
Decreases due to lapse of statute of limitations	(2,992)
Translation adjustments	(267)
Balance as of December 31, 2024	10,222
Decreases due to settlements	(124)
Decreases due to tax positions taken in the current year	(360)
Decreases due to lapse of statute of limitations	(3,170)
Translation adjustments	349
Balance as of December 31, 2025	$	6,917

The total of unrecognized tax benefits was $6.9 million and $10.2 million as of December 31, 2025 and December 31, 2024, respectively. If recognized, it is estimated that Dole’s effective tax rate would be affected by additional income tax benefit of $6.9 million and $8.9 million as of December 31, 2025 and December 31, 2024, respectively. The Company recognizes interest and penalties related to income taxes within income tax expense in the income statement. Dole recognized a benefit of $2.4 million for interest and penalties for the year ended December 31, 2025, an expense of $1.6 million for the year ended December 31, 2024 and a benefit of $0.4 million for the years ended December 31, 2023. A liability was recognized for accrued interest and penalties of $3.1 million and $5.5 million as of December 31, 2025 and December 31, 2024, respectively.

The tax years 2021 to 2024 remain subject to examination by taxing authorities in the United States. The tax years 2020 to 2024 remain subject to examination by taxing authorities in the U.K. The tax years 2020 to 2024 remain subject to examination by taxing authorities in Ireland, Costa Rica, Ecuador, Germany and Guatemala. The tax years 2019 to 2024 remain subject to examination by taxing authorities in Sweden and Denmark.

About Income Taxes Disclosures

The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.

Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.

Dole plc Income Taxes Disclosure

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