Amsterdam, 19 May 2025

Pfizer Netherlands International Finance B.V

Rivium Westlaan 142

2909 LD Capelle aan den IJssel

The Netherlands

London

Luxemburg

New York

Rotterdam

a.   drafts of documents reviewed by us will be signed in the form of those drafts, each copy of a document conforms to the original, each original is authentic, and each signature is the genuine signature of the individual purported to have placed that signature;

b.  if any signature under any document is an electronic signature (as opposed to a handwritten (“wet ink”) signature) only, it is either a qualified electronic signature within the meaning of the eIDAS Regulation, or the method used for signing is otherwise sufficiently reliable;

c.   the Registration Statement has been declared effective by the SEC in the form reviewed by us;

d.  (i) no internal regulations (reglementen) have been adopted by any corporate body of the Dutch Company which would affect the validity of the resolutions recorded in the Resolutions and (ii) the Articles of Association are the Dutch Company’s articles of association currently in force. The Extract supports item (ii) of this assumption;

e.   the Dutch Company has not (i) been dissolved (ontbonden), (ii) ceased to exist pursuant to a merger (fusie) or a division (splitsing), (iii) been converted (omgezet) into another legal form, either national or foreign, (iv) had its assets placed under administration (onder bewind gesteld), (v) been declared bankrupt (failliet verklaard), been granted a suspension of payments (surseance van betaling verleend), or started or become subject to statutory proceedings for the restructuring of its debts (akkoordprocedure) or (vi) been made subject to similar proceedings in any jurisdiction or otherwise been limited in its power to dispose of its assets. The Extract and our inquiries of 16 May 2025 with the Insolvency Registers support the items (i) through (v) (except for any statutory proceedings for the restructuring of debts (akkoordprocedure) that have not, or not yet, been filed in the Insolvency Registers) of this assumption. However, this information does not constitute conclusive evidence that the events set out in items (i) through (v) have not occurred;

f.   the resolutions recorded in the Resolutions are (and were at all relevant times) in full force and effect, and the factual statements made and the confirmations given in the Resolutions are (and were at all relevant times) complete and correct; and

g.  the issuance of the Notes, to the extent made in the Netherlands, has been, is and will be made in conformity with the Prospectus Supplement, the Prospectus Regulation, the PRIIPS-Regulation and the rules promulgated thereunder.

Incorporation and Corporate Status

1.  The Dutch Company has been duly incorporated and is validly existing as a besloten vennootschap met beperkte aansprakelijkheid.

Corporate Power

2.  The Dutch Company has the corporate power to enter into the Opinion Documents, to offer and issue the Notes, and to perform its obligations thereunder. The Dutch Company does not violate any provision of its Articles of Association by entering into the Opinion Documents or performing its obligations thereunder.

Corporate Action

3.  The Dutch Company has taken all corporate action required by its Articles of Association and Dutch law in connection with entering into the Opinion Documents and the offer and issue of the Notes.

Valid Signing

4.  The Opinion Documents have been validly signed on behalf of the Dutch Company.

A. As Dutch lawyers we are not qualified or able to assess the true meaning and purport of the terms of the Opinion Documents under the applicable law and the obligations of the parties to the Opinion Documents and we have made no investigation of that meaning and purport. Our review of the Opinion Documents and of any other documents subject or expressed to be subject to any law other than Dutch law has therefore been limited to the terms of these documents as they appear to us on their face.

B. The opinion expressed in paragraph 1 (Incorporation and Corporate Status) of this opinion letter must not be read to imply that the Dutch Company cannot be dissolved (ontbonden). A company such as the Dutch Company may be dissolved, inter alia by the competent court at the request of the company’s management board, any interested party (belanghebbende) or the public prosecution office in certain circumstances, such as when there are certain defects in the incorporation of the company. Any such dissolution will not have retro-active effect.

C. The Extract does not constitute conclusive evidence of the facts reflected therein.

D. Pursuant to Article 2:7 DCC, any transaction entered into by a legal entity may be nullified by the legal entity itself or its liquidator in bankruptcy proceedings (curator) if the objects of that entity were transgressed by the transaction and the other party to the transaction knew or should have known this without independent investigation (wist of zonder eigen onderzoek moest weten). The Dutch Supreme Court (Hoge Raad der Nederlanden) has ruled that in determining whether the objects of a legal entity are transgressed, not only the description of the objects in that legal entity’s articles of association (statuten) is decisive, but all (relevant) circumstances must be taken into account, in particular whether the interests of the legal entity were served by the transaction.

E.  The opinions expressed in this opinion letter may be limited or affected by:

a.   rules relating to Insolvency Proceedings or similar proceedings under a foreign law and other rules affecting creditors’ rights generally;

b.  the provisions of fraudulent preference and fraudulent conveyance (Actio Pauliana) and similar rights available in other jurisdictions to insolvency practitioners and insolvency office holders in bankruptcy proceedings or creditors;

c.   claims based on tort (onrechtmatige daad);

d.  sanctions and measures, including but not limited to those concerning export control, pursuant to European Union regulations, under the Dutch Sanctions Act 1977 (Sanctiewet 1977) or other legislation;

e.   the Anti-Boycott Regulation and related legislation; and

f.   any intervention, recovery or resolution measure by any regulatory or other authority or governmental body in relation to financial enterprises or their affiliated entities.

1.  the Indenture;

2.  the Global Notes; and

3.  the Registration Statement.

EXHIBIT C

LIST OF CORPORATE DOCUMENTS

1.  the Deed of Incorporation;

2.  the Extract; and

3.  the Resolutions.