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1、1Tax Transparency ReportTax Year 20222AXA Tax Transparency Report Tax Year 2022“The role of AXA is to be socially engaged.Our financial performance serves all our stakeholders:our customers,our employees,our shareholders and more globally the economy with more than 30Bn of investments each year and
2、more than 11Bn of taxes and social contributions”CONTENTSTHOMAS BUBERLAXA Group Chief Executive OfficerINTRODUCTION3Welcome32022 Regulatory Tax environment4GROUP TAX POLICY5Our Tax commitments6Tax risk management and internal governance7Tax aspects in relation to AXA as a multinational company8Tax a
3、spects of the Groups activities9Tax aspects of products offered by the Group10TRANSFER PRICING11Clarifying key concepts12AXA locations worldwide13AXA presence in low-tax countries and EU black/grey lists at year end 202214TOTAL TAX CONTRIBUTION15Total tax contribution by type of tax16Total tax contr
4、ibution by flagship country17IFRS corporate income tax figures -Clarifying key concepts18IFRS corporate income tax figures 2022 Breakdown19Other taxes by flagship country20COUNTRY-BY-COUNTRY INFORMATION21Country-by-Country Report Clarifying key concepts22Glossary23AXA 2022 Country-by-country informa
5、tion24-273AXA Tax Transparency Report Tax Year 2022In 2022,despite an uncertain environment,AXA continuedto have solid performance and to deploy its sustainabilitystrategyineachoftheEnvironmental,SocialandGovernanceareas.Through our investments and products,AXA breeds benefits for society.Throughour
6、 business,commitments,and taxes,we strive to contribute to overcomingmajor environmental and societal challenges.Our Tax commitments and our Taxpolicy reflect our companys very purpose and values:act for human progress byprotecting whatmatters.As a global insurance company operating in many countrie
7、s around the world,AXAbelieves it is important to pay itsfair share of tax where they are due and where itsbusiness generates economic value.The Group is committed to being a responsible taxpayer that works closely andcontinuously with experts,auditors and tax authorities to take into account bothth
8、e letter and the spirit of the law and to ensure it pays the right amount of taxesin the right place and at the right time.AXAs Tax commitment prevents any use ofnon-cooperative jurisdictions toavoid taxes on activities performed elsewhere.ALBAN DE MAILLY NESLEGroup Chief Financial OfficerWELCOME202
9、2 Group Activity HighlightsAfter the pandemic crisis,the world has entered into anew era with new economic and geo-political turmoil:thewar in Ukraine,the energy crisis,inflation,and the rise ininterest rates have impacted the insurance sector as awhole.AXA has nevertheless been able to show a sound
10、performance,confirming its strength and its ability toachieve its“Driving progress 2023”plan.AXA continued itsactions to protect and finance the economy investing infuturegrowthandcontributingtosustainabilitydevelopment actions.In 2022,our performance and our solvency show that ourstrategy and trans
11、formation journey were effective,andthat our repositioning was successful despite naturalcatastrophes and war in Ukraine.Since2022,inlinewithourtransformationandsimplification journey,AXA SA has become the Groupsinternal reinsurer.The Group finalized the sales of itsinsurance operations in Singapore
12、 and Malaysia.It alsoannounced exclusive negotiations to acquire the Spanishactivities of Groupe Assurances du Credit Mutuel andstrengthenits presence in Spain.INTRODUCTIONCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION“Our Tax commitments and our Tax policy are fully aligned wi
13、th our companys purpose and values”AXA GROUP TAX POLICYIn 2022,AXA Groups worldwide total tax contributionamounted to 11.7 billionToday I am proud to share with you AXAs fifth Tax Transparency Report.Webelieve this report gives you with more context and further develops theinformation provided in ou
14、r Annual Report.Last year,AXA achieved the highestrating in the insurance sector in the S&P Global Corporate with a 100/100 taxsection score thankstoourconsistent tax transparency efforts.Building on the reports structure,as of last year AXA took the initiative to publishthe Country-by-country data
15、for EU member states,our non-EU flagship countries,and countries listed by the EU as non-cooperative before the European Uniondirective topublish theCountry-by-CountryReport(CbCR)goes into effect in 2025.In charting our path to greater tax transparency with the public,we also decidedto continue prov
16、iding additional details about our presencein low-taxjurisdictions a presence thatis alwaysdriven by operational purposes.In 2023,AXA will take further steps to prepare the implementation of the PillarTwo Global Minimum Tax published by the OECD,due to be transposed intoFrench Law.4AXA Tax Transpare
17、ncy Report Tax Year 20222022 Regulatory Tax EnvironmentIn 2022,The two-pillar OECD BEPS 2 project significantly progressed after many political discussions and EU member-states came to an agreement allowing the publication of the EU directive on December 2022.Pillar 1 addressesthe re-allocation of t
18、axing rights in countries where the business is performed whereas Pillar 2 addresses a 15%minimum taxation of multinational groups in each and every country where they operate.Insurance and financialservices are outofscope forPillar 1.In addition,theE.U directive fora Public Country-by-CountryReport
19、(CbCR)wasadopted in November 2021 and shouldbe transposed into theFrench taxlegislation before end ofJune 2023.EU directive-Public Country-by-Country ReportOECD-Pillar 2 Minimum tax The public CbCR was endorsed by an E.U directive effective from 1stDecember 2021.EU memberStates have until 22ndJune 2
20、023 to transpose the directive into domestic legislation.The rule willapply for the first financial year starting on or after 22ndJune 2024 at the latest.The details of therequirement arestillpending.The report should include the following:name of the ultimate parent company,financial yearconcerned,
21、currency used,list of all the companys subsidiary undertakings consolidated in thefinancial statement(established in the EU or in tax jurisdictions listed on the EUs black and greylists),a brief description of the nature of their activities,number of employees(on a full-timeequivalent basis),revenue
22、s as per IFRS,profit or loss before income tax,current income taxaccrued during the year,current income tax paid(cash basis),and accumulated earnings at theend of therelevant financial year.This information is to be broken down by individual EU Member State,on a disaggregated basisfor the EUs blackl
23、ist and relevant EU grey list countries(see lists in appendix 1),and on anaggregated basis forotherthirdcountries.As early as 2021,AXA decided to anticipate this mandatory requirement and to publish theCbCR in its Tax Transparency Report.In December 2021,the OECD issued the Global Anti-Base Erosion(
24、GLOBE)Model Rules that provided the framework for thecalculation of a 15%minimum tax.This initiative sets out to ensure that all multinational groups pay a minimum tax of 15%in all countries in which they operate.These rules together with the March 2022 comments and examples,define the mainprinciple
25、s of the computation of the minimum tax.In most cases,this minimum tax is to be paid by the Ultimate ParentEntity(UPE)of the Group.For AXA Group,it will be AXA S.A.,registered in France.When implementing the GLOBE rules,mostgovernments around the world are likely to implement a Local minimum tax tha
26、t will allow a“tax credit”at the UPE level solong asthistax is recognized as a“qualified OECDtopuptax”.In December 2022,an E.U directive was finally adopted.It is due to be transposed into the French law in thefirst half of 2023and implemented as of 1stJanuary 2024.In December 2022,OECD also issued
27、some“safe harbours rules”to simplifycompliance during the 3-year transitional period(2024-2026).If the“adjusted“Effective Tax Rate based on the CbCR ishigher than 15%for 2024,then no detailed calculation will be required.At the same time,the OECD launched a consultationon theGlobe Information Return
28、.In March 2023,thepublication ofadministrative guidance provided furtherimplementation information.AXA supports the OECD initiative preventing tax competition between states and is currently working on implementing thenew rules and assessing their impacts together with the first application of IFRS1
29、7 and IFRS9,both of which are likely totrigger changes in thepresentation oftheconsolidated accounts starting 2023.INTRODUCTIONCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONAXA GROUP TAX POLICY5AXA Tax Transparency Report 2022Group Tax Policy6AXA Tax Transparency Report Tax Yea
30、r 2022Our Tax commitmentsCCONTRIBUTEMMONITOROOPERATEIINCLUDEMMANAGETTESTIFYour fair part by paying our taxes at the right time and at the right placeas a transparent and collaborative partner with tax authorities and statesa tax organization to ensure full tax compliancelimited appetite for tax risk
31、 with adequate governance and appropriate processestax as a key contributor to the ESG Group Policyto transfer pricing compliance with taxation of profits where activities are performedINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION7AXA Tax Transp
32、arency Report Tax Year 2022Tax risk management and internal governanceTo ensure effective tax risk management,a number of measures and processes are in placethroughouttheGroup toidentify,assessand monitor taxrisks suchas:Handling tax-related topics by highly qualified in-house tax experts who arepro
33、vided withongoing training and access toexternal advice whenneededEnsuring consistent practices on technical matters as well as adherence to guidelinespertaining to tax risks and tax audits.An International Tax Committee and anInternational Tax conference gather various senior tax executives through
34、out thedifferent entities of the Group.Thelast conference held in September 2022was thefirstphysical conference afterCOVID-19 pandemicImplementing a uniform and well-established reporting of the uncertain taxpositions thelocal entities regularlyprovide totheGroupTax DepartmentMonitoring changes in t
35、ax laws and theirimpacts on AXAand theindustryUpdating the Group Audit Committee of the Board of Directors on the significant taxrisks on a regularbasisIncluding internal controls on tax processes in the Groups internal finance controlprogram and operational risk processMaintaining a limited tax ris
36、k appetite through efficient controls and external advice,whenneededSeeking,when necessary,certainty in advance from tax authorities to confirm anapplicable tax treatment based on full disclosure of all relevant facts andcircumstancesDefining Group standards for tax compliance,and ensuring their ful
37、l satisfaction,particularly for cross-border life business,and more globally for compliance with taxregulationsThe Group is additionally actively involved in tax regulation discussions through itsmembership in various national and international business and insurance associations inthe countries whe
38、re it operates.These memberships allow the Group to ensure an ongoingtransparent exchange on tax-relatedmatterswitha variety ofstakeholders.The Group Tax Department of the AXA Group is part of the central Financefunction and is therefore under the responsibility of the Group Chief FinancialOfficer.I
39、t is led by the Group Head of Tax who directly and regularly reports totheGroupChief Financial Officer tokeep himabreast oftax-relatedmatters.TheGroup Tax Department is accountable and responsible fortheGroups:taxpositions and group-leveltaxstrategytaxpolicies,controls,and instructionsglobal transfe
40、rpricing modelThe local entities tax teams are accountable and responsible for taxcompliance and the day-to-day tax matters under the Group Tax Departmentsguidance.AXAGrouphas a strong corporate tax Governance inspired by the best existingstandards(GRI,B-Team Principles)as laid out in the AXA Group
41、Tax Policy.This Policy is validated annually by the Group CEO and published in theUniversalRegistrationDocument.Weconsidertaxriskmanagementfundamental to maintaining efficient and effective operations,as well as toensuring fullcompliance withtax regulations.Government authorities may offer tax incen
42、tives to support business sectors,create employment or foster their economic development.AXA carefullyconsiders these incentives and only claims those that are aligned with ourbusiness operations and fit with our investment or business strategy.Werefrain fromdiscretionary tax arrangements.In additio
43、n,the current AXA Group whistleblowing procedure allows allstakeholders(employees,business partners,etc.)to share their concernswithout any delay and/or to report any practice,action,or behaviour that theyconsider inappropriate,illegal,or unethical(speak-).INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-
44、COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION8AXA Tax Transparency Report Tax Year 2022In the countries where it operates,AXA is both a taxpayer and a taxcollector,given that many specific taxes are levied on insuranceandreinsurance policies and collected from our customers as part of th
45、einsurance,reinsurance and asset management revenues while others areremitted tothevarious stateand federal administrations aroundtheworld.The tax function is organized within the Group to ensure full compliancewith all tax legislation in the countries where AXA operates.In addition tothe Group Tax
46、Department based in France,all key operationalentities/countries/geographic zones have a tax team in charge of ensuringthattax regulationsare wellunderstoodand satisfied by theentities.As part of the global internal risk assessment,a specific tax internal controlprogramisimplemented.Thesecontrolsmus
47、tbereportedanddocumented by each teamin scope toensurefullcompliance.A Tax Code of Ethics,agreed between the Group Tax Department and localtax teams,highlights the key principles guiding the actions of the varioustaxteams:toremain uptodate withrespect toapplicable lawsand regulations;tocomply withta
48、xlawsand regulations;tomaintain agood relationship with thelocal taxauthorities;andnot to engage in aggressive tax-driven transactions that couldcompromise thegood reputation oftheGroup.The satisfaction of this Code of Ethics is a prerequisite of the activitiesperformed by all AXA tax teams and give
49、s rise to an annual certification byeach head of tax,which is provided to the Group tax team.ln addition,a bi-annual tax review process of each key entity or business line is performedby the Group Tax Department in connection with each local team.Duringthese reviews,specific attention is given to ta
50、x audits and associated taxrisks as wellas market positions on tax matters that may impact AXA.Thesereviews offer a global framework for the tax teams to identify,analyze,control,and report taxrisks.Lastly,an International Tax Committee composed of various senior taxexecutives within AXA tax teams m
51、eets every quarter to ensure consistencyin approach on some technical topics,as well as agreements on guidelines,whennecessary,connected tospecific itemsTax aspects in relation to AXA as a multinational companyINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CO
52、NTRIBUTION9AXA Tax Transparency Report Tax Year 2022The Groups activities are subject to strict regulations andrigorous control in each territory in which AXA operates.ln addition to these regulations,AXA has developed a setof detailed internal standards that applies to all Groupentitiesthataremanag
53、edorcontrolledbyAXA,regardless of the activities undertaken by the entity or itsownership structure.According to these internal standards,Chief ExecutiveOfficers must ensure that staff are fully conversant,and comply with applicable laws,mandatory Codes ofConduct,rules and regulations(including appl
54、icabletax laws and regulations)relevant to their area ofoperations.Thismeansthatlocalseniormanagementmustappreciate the tax implications of the activities in theirentity.Themain considerations are:compliance with the taxation of employees in theterritoryin whichtheyareemployed;compliance with thetax
55、ation of business undertakenin the territory(including levies and sales taxes);andcross-border taxissues.Aspecificfocusontransferpricingismadeinapplication of these standards,to ensure that the pricingof our intra-group activities is consistent with the OECDarms length principle as well as with loca
56、l transferpricing rules to pay adequate tax on profits where thevalueis created.ln particular,Chief Financial Officers must ensure thatinsuranceandreinsurancepoliciesenteredintorepresent a true transfer of risk and that their status asinsurance or reinsurance contracts could not be subjecttochalleng
57、e.Business between Group companies must be transactedat market prices where a market price exists,or in theabsence of market prices,must be supported by formallydocumented justification forthecharge made.Tax aspects of the Groups activitiesINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATI
58、ONTRANSFER PRICINGTOTAL TAX CONTRIBUTION10AXA Tax Transparency Report Tax Year 2022AXA products are not designed to allow or encourage tax evasion.Tax aspects of products offered by the GroupThe Group has set up a validation framework toensure that new products undergo a thoroughapproval process bef
59、ore theygotomarket.The local decision to launch a new product mustresult from a documented approval process thatcomplies with the AXA Groups standards in termsofproductfeatures,pricing,assetliabilitymanagementandaspectsrelatedtolegal,compliance,regulatory,accountingandreputation.Moreover,AXA has est
60、ablished strict policiesregardingitscross-borderactivitiesandknowledge of its customers,in order toensure thatour products and services are not misused for moneylaunderingortaxevasionpurposesandaregoverned by specific rules according to which cross-border life insurance proposals must be presented t
61、othe Group Tax and Compliance Departments forvalidation.While all Group entities must in any case complywith local regulations,the Group Tax Departmentcan veto a product if this product is not compliantwithinternal rules.Pursuant to Directives(EU)2014/107,2018/822 andUSlegislationregardingForeignAcc
62、ountTaxCompliance Act(FATCA),AXA may,asa company anda provider of investments and savings products,have tax reporting obligations with respect tocertaincross-border products it designs or implements.lnparticular,certain investments and savings productswith no particular tax motive may be reportableu
63、ndertheabove-mentioned Directive.INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONResource:AXA 2022 Integrated report11AXA Tax Transparency Report 2022Transfer Pricing12AXA Tax Transparency Report Tax Year 2022Clarifying key conceptsWhat istransferp
64、ricing?Transfer pricing refers to the terms and conditions of transactions within a multi-nationalcompany.It concerns the prices charged for inter-company transactions(i.e.transfer of goodsand services)between associated enterprises establishedin different countries.Since the prices are set within c
65、onnected entities belonging to the same group,these may fail toreflect an independent marketprice.What isthe arms-lengthprinciple?Under international standards,any transaction operated by an entity with another connectedentity belonging to the same worldwide group,must be done as if it were done wit
66、h a third party.This is what is usually named as the“arms length principle”defined by the provisions of article 9of the OECD model Tax convention.It states that the price of a transaction between connectedentities cannot in principle differ from one between third parties and must thus be documentedf
67、orthatpurpose.What arethe main crossborderintercompany transactionsin AXA Group?Usual company cross-border flows such as:IT,management expenses,loans andguarantees,trademark fees.Insurance-specific business cross-border flows:reinsurance is a mechanism throughwhich insurers can manage insurance risk
68、 by shifting or ceding one or more insured risks toreinsurers in exchange for payment of premiums and commissions.It is an insurersfundamentalrisk management tool.What isthe documentation requiredfortransferpricing?Following the OECDs recommendations,especially in its BEPSaction 13,many countries ha
69、veadopted the three-tiered transfer pricing documentation requirementsthat include:The Master file presenting the companys business,its organizational structure,an overviewof the companys business processes,its intangibles,and a description of its intragroupfinancial transactions.The Local file,in c
70、ompliance with Local Transfer Pricing Regulations,presenting abreakdown ofintragroup transactions withforeign jurisdictions.TheCountry-by-countryReportingpresentingaggregatedtaxjurisdiction-wideinformation on various KPIs such as current tax indicators(i.e.,tax paid and accrued)and alist of the cont
71、rolled entities registered in each tax jurisdiction where the Group operates.TheCbC report is to be filed by the parent company of a Group to its local Tax Authority which,according to information exchange agreements,is in charge of sharing it with other foreigntaxauthorities.More details on CbC Rep
72、ort areavailable on page 22.AXA Group is committed to complying with the regulations of every tax jurisdiction in which itoperates regarding theTransferPricing documentation and notification requirements.INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBU
73、TION13AXA Tax Transparency Report Tax Year 2022more than 50countrieswhere AXA Group operatesExisting AXA locationsNot present in this location10 flagship countries representing nearly 86%of AXA Group third-party revenues in 2022France,Belgium,Germany,Hong Kong,Italy,Japan,Spain,Switzerland,the Unite
74、d Kingdom and the United StatesAXA locations worldwideFlagship countriesAXA has no licensed insurance or operatingbusiness activities in the countries specificallyidentifiedasnon-cooperativejurisdictionsunder French and European rules(1),except inPanama(see details page 14).The presence inthis juris
75、diction is purelydriven by operationalpurposes.Moreglobally,AXAdoesnotusenon-cooperative jurisdictions to avoid taxes onoperational activities performed elsewhere.Any presence in countries in which AXAoperates with tax rates lower than France aredriven bybusiness operations.(1)The French list of Non
76、-Cooperative States which is,in principle,updated each year,has been updated on March 16,2022(MinisterialOrder dated March 2,2022 published onMarch 16,2022.and amending ministerial order dated February 12,2010)andmore recently on February 5,2023(Ministerial Order dated February 3,2023 published on F
77、ebruary 5,2023 and amendingministerial order dated February 12,2010).It applies to such States and jurisdictions as from the first day of the third monthfollowing the publication of the order(arrt)including such States and jurisdictions on the list of Non-Cooperative States.Itincludes the United Sta
78、tes Virgin Islands,the American Samoa,Anguilla,the British Virgin Islands,Fiji,Guam,Palau,Panama,Samoa,Seychelles,Trinidadand Tobago and Vanuatu.As from May1st,2023 it willalso include in addition to the territories listedTurksandCaicosIslandsandtheBahamas.Any presence in countries in which AXA oper
79、ates is driven by business operationsINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION14AXA Tax Transparency Report Tax Year 2022(1)EU grey and black list as of December 31,2022.See detail on the list on page 13.THAILAND(EU Grey List)TURKEY(EU Grey
80、List)MALAYSIA(EU Grey List)BERMUDA(low-tax country)According to the French and European Union laws at the end of 2022Bermuda is not considered a non-cooperative jurisdiction.It is a low-taxjurisdiction,a center of expertise,and one of the key locations of theworldwide reinsurancemarket.Since acquiri
81、ng XL Group in September 2018,AXA has had a materialpresence and substance in Bermuda with more than 150 AXA XLemployees based there.Our presence is mainly driven by Bermudaslocal capital management regulation that enables flexibility on therequired capital for(re)insurance activities.AXA supports t
82、he EconomicSubstance legislation enacted in this country.BARBADOS(EU Grey List)PANAMA(EU Black list)Turkey is maintained on the October 2022 EU Grey list as thecountry has not exchanged financial account information with allEU Member States.At the end of 2022,AXA holds several operating entities in
83、Turkeyproviding:-General insuranceservices(P&C)-Life Insurance(L&S)-Credit Lifestyle Protection-Assistance.Malaysia has remained in the EU Grey list because of its harmfulforeign-source income exemption(FSIE)regime that it has pledgedto amend or abolish.In August 2022,AXA completed the sale of its i
84、nsurance operationsin Malaysia.AXA does continue to operate a Malaysia-based assistance andreinsurancebusiness through AXA Assistance and AXA XL.Thailand is maintained on the October 2022 EU Grey list becausethe country has yet to ratify the OECD Multilateral Convention onMutual Administrative Assis
85、tance in Tax Matters.At the end of 2022,AXA holds one consolidated general insurancecompany,and holds 50%of a life insurance company in a jointventure with a Thai bank.As per IFRS accounting standards,thiscompanyisaccountedundertheequitymethodinAXAsconsolidated financial statements.Panama has remain
86、ed on the October 2022 EU Blacklist due to itslack of commitment to repealing or amending its harmful foreign-source income exemption(FSIE)regime.AXA still holds two non-consolidated operating companies inPanama(one providing assistance services to local customers,andthe other delivering health clai
87、m services)employing circa 40people at the endof 2022.Barbados is included in the EU Grey list according to the October2022 update on non-cooperative jurisdictions.One investment company was liquidated in 2022.At the end of 2022,AXA holds a Barbados-based reinsurance entity it inherited from the2018
88、 acquisition of XLGroup.It is to be liquidated in 2023.AXAs presence in low-tax countries and EU black/grey lists(1)at year end 2022INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION152022 Total tax contribution16AXA Tax Transparency Report Tax Year
89、20222022 tax contributions worldwideCorporate income tax paidInsurance premium tax collectedSocial charges(Borne both by employees and by employers)VAT/GST paidOther taxes(i.e.Stamp duties,property taxes,financial transactions taxes)Total tax contribution by type of tax11.7Bn1.7Bn5.2Bn2.4Bn2.0Bn0.4B
90、n93 MillionCustomers worldwide110 ThousandEmployees(Open-ended and fixed-term contracts)8.9 BillionProfit before tax102 BillionGross revenuesINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION17AXA Tax Transparency Report Tax Year 2022France:4.2 BnUni
91、ted Kingdom:1.1 BnGermany:1.5 BnSpain:0.4 BnBelgium:0.9 BnJapan:0.6 BnSwitzerland:0.7 BnItaly:0.7 BnAXA Group total tax contribution in its 10 flagship countries amounted to 10.4Bn in 2022These figures include corporate income tax paid,the insurance premium tax collected,social charges borne both by
92、 employees and employers,VAT/GST paid and other taxes(i.e.,transactional taxes,property taxes,excise taxes,financial taxes)Hong Kong:0.04 BnTotal tax contribution by flagship countryUnited States:0.3 BnINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTI
93、ON18AXA Tax Transparency Report Tax Year 2022IFRS corporate income tax figures-Clarifying key concepts What isincome tax accrued?In IFRS,according to IAS 12,income tax accrued encompasses current and deferred income tax.Italso integrates the repercussions of tax disputes and any penalties and intere
94、sts for late paymentsarising fromsuchdisputes.Current income tax refers to the amount of income tax payable or receivable for a givenperiods taxable profit or loss.Its assessment is based on the countrys applicable local taxlegislation forthatperiod.Deferred income tax is recognized when the reporti
95、ng period for income or expenses differsforfinancial statements and thetaxreturn.What isthe effectivetaxrate?It is the ratio of corporate income tax accrued(current and deferred tax)compared with the IFRSprofit(or loss)before tax.Every year,the theoretical tax rate and the effective tax rates reconc
96、iliationfiguresin theAnnualReports Tax Note(Note19 oftheConsolidated Financial Statements).Why do the taxbasis and theaccounting basis oftendiffer?It is because they are built on different principles,meaning that,if the difference is temporary,therecognition of a tax and its accounting occur in diff
97、erent periods.In this case,a deferred income taxasset or liability is booked in the IFRS consolidated accounts.Deferred tax hence allows to reconcilethe tax and accounting basis in the same financial period and prevents volatility in the financialstatements.Why isthe currentincome tax accrueddiffere
98、nt fromcurrentincome tax paid?Current income tax accrued corresponds to the tax amount impacting an accounting periods results.Current income tax paid represents all the(in or out)cash flows between the company and the TaxAdministration in an accounting period.Thesetwoamounts areoften disconnected a
99、s:in most countries,entities pay instalments based on the prior years taxable results and abalance payment occurs theyear after.after a tax audit or a claim,the Tax Administration can either refund or require an additionalpayment on prior years accounting periods.Why does theeffectivetax ratediffer
100、fromthe corporatetaxrate?The effective tax rate differs from the corporate tax rate any time an IFRS income/expense is either non-taxable or non-deductible according to the local tax regulation(called a permanent difference).Alljurisdictions have theirownrulestriggering specific permanent difference
101、s.In an insurance company,financial transactions represent a significant part ofthe results and therefore,themain permanent adjustments come from:dividends thatare partially ortotallynon-taxablenon-taxable capital gains/non-deductible capital lossesINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY
102、INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION19AXA Tax Transparency Report Tax Year 2022The table below provides an overview of the 2022 IFRS income tax figures for our significant countries-representing 90%of the total-and for the Group as reported in our IFRS Group Financial Statements.Sign co
103、nvention:Income(+)/Expense(-)IFRS Corporate Income Tax Figures 2022 BreakdownThe differences between the applicable corporate income tax rate and the effective tax rate(ETR)mostly stem fromincomes or expenses that are either treated as non-taxable or non-deductible according to the countries taxregu
104、lations.Thedetails below explain whytheETR in thefollowingjurisdictions differsfromthestandard corporate tax rate:Belgium:the lower effective tax rate is mainly due todisposal of equity shares for which a specific taxregime witha lowertaxrateis applied.Bermuda:corporate tax does not exist in Bermuda
105、,sothe profits do not generate any taxation.The taxburden booked corresponds to foreign withholdingtax.Germany:the lower effective tax rate is mainly due tothe positive settlement of the 2014-2017 tax audit and,toa lesserextent,duetonon-taxable capital gains.Hong Kong:the taxable profits of a life i
106、nsurancebusiness are deemed tobe 5%ofthenet premiums.Ireland:the lower effective tax rate is primarily due tothe foreign losses of AXA XL,which,according to theworldwide tax regime,can offset Irish profits anddecrease thetaxdue in Ireland.United Kingdom:the lower effective tax rate mainlycomes from
107、the recognition of deferred tax assets onprior years tax losses,after better than anticipatedtaxable results.Rest of the world:the effective tax rate is due to thecountry mix with some losses in low tax rate countriescombined with profit in higher rate countries.Themain contributors of the net profi
108、t before tax areAustralia,Canada,Colombia,China,Morocco,theNetherlands,and Luxembourg.INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONMProfit before taxIncome tax accrued(Current and deferred)Effective tax rateCorporate income tax rateCorporate inc
109、ome tax paidFrance1 145(293)25.6%25.8%(271)Belgium632(103)16.3%25.0%(54)Bermuda156(6)4.0%0.0%(6)Germany1 162(315)27.1%32.0%(257)Hong Kong558(26)4.6%16.5%(24)Ireland410(23)5.6%12.5%(46)Italy435(127)29.2%30.8%(84)Japan757(217)28.7%28.0%(370)Mexico141(37)26.4%30.0%(13)Spain172(64)37.1%25.0%25Switzerlan
110、d1 766(309)17.5%18.0%(209)Turkey82(22)26.7%25.0%(50)United Kingdom357(49)13.7%19.0%(40)United States694(151)21.7%21.0%(167)Rest of the world385(114)29.6%N/A(112)TOTAL8 851(1 855)21.0%N/A(1 677)20AXA Tax Transparency Report Tax Year 2022VVVInsurance premiumtaxes collectedAccrued Social Chargesborne b
111、y AXA and its employeesValue Added Taxes(VAT)and Gross Sales Taxes(GST)paid Figures reported in millionThe Insurance Premium Tax(IPT)is an indirecttax levied in some countries on gross premiumwritten issued by insurers and allocable to thecountry where the risk is located.The IPT isusually charged t
112、o the policyholder and remittedtothelocal tax administration.The applicable IPT rate depends on the type ofinsurance contract,the risk covered and thecountry.In most countries where AXA Group operates,insurance products are exempted from VAT andGST.When the Group cannot fully recover its VATand GST,
113、the non recoverable VAT/GST paid is acost thatfullyimpacts theP&L oftheGroup.Thesesocialcontributionsarepaidtothegovernment where entitles employees reside togive them access to future social benefits such asunemploymentinsurance,pensions,medicalservices.Contributions are levied on both employees an
114、demployers.Other taxes by flagship countryINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONFrance2 033 Belgium496 Germany939 Hong Kong-Italy361 Japan18 Spain233 Switzerland135 United Kingdom627 United States107 Rest of the world217 TOTAL5 165 France
115、1 141 Belgium168 Germany213 Hong Kong20 Italy55 Japan106 Spain57 Switzerland207 United Kingdom180 United States42 Rest of the world183 TOTAL2 371 France580 Belgium77 Germany139 Hong Kong-Italy189 Japan94 Spain116 Switzerland122 United Kingdom256 United States-Rest of the world381 TOTAL1 953 212022 A
116、XACountry-by-Country information22AXA Tax Transparency Report Tax Year 2022Country-by-Country Report-Clarifying key conceptsINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONWhat isthe Country-by-CountryReport?In 2013,the OECD and G20 adopted a BEPS(
117、Base Erosion and Profit Shifting)action plan tocountertax avoidance and profit shifting by multinational corporate groups.This plan is made of 15 actionpoints in order to achieve the goal of preventing tax-aggressive structures;Action 13 is theimplementation of a Country-by-Country report.In May 201
118、6,the European Union modified itsdirective DAC 4in order toimplement within the EUtheOECD BEPS Action 13 CbCR requirement.InDecember 2016,the CbCR requirement is transposed into French tax law through the adoption of2016 Finance bill.Large multinationals(“MNE”)must file tothe tax authority of the co
119、untry of the headquarters a CbCreport that will provide a breakdown of financial and tax indicators of economic activities for eachtax jurisdiction in which the MNE group does business.It only applies to MNE groups with annualconsolidated grouprevenues of750 millions or more in thepreceding fiscal y
120、ear.The CbC Report includes three tables which contain information on the global activities andfinancial characteristics ofthegroup:Table 1 sets out the global allocation by tax jurisdiction of an MNE groups third-party revenues,related party revenues,profit before tax,current tax paid,current tax a
121、ccrued,stated capital,accumulated earnings,numberofemployees,and tangible assets.Table 2 lists all constituent entities of the MNE group by tax jurisdiction,together with theirmain business activities.Table 3 allows for the provision of additional information by the MNE group in the form of freetext
122、 tofacilitate theunderstanding of theinformation contained in Tables 1 and 2.IsAXA preparingaCountry-by-Countryreport?As a Multinational Group with a consolidated revenues of more than 750 million,AXA is required toprepare a Country-by-Country report and to file it to the French Tax Authorities sinc
123、e 2017(based on 2016data).Accordingly,in December 2022 AXAprepared and filed its sixthCbCR.Isthe Country-by-Countryreportapublic document?In compliance with the OECD guidelines and with the French tax code(article 223 quinquies C),theCountry-by-Countryreportfiled totheFrench taxauthoritiesis not a p
124、ublic document.Nevertheless,an EU Directive on public CbCR has been adopted in November 2021(Directiven2021/2101)which provides for the compulsory disclosure,starting from 2025,of the CbCR data relatingto activities conducted in the EU Member States and in the countries which are part of a so-called
125、“greylist”and“black list”of non cooperative jurisdictions(NCSTs)for at least twoyears.The CbCR data relatedtothird countries,non-NCSTs,willhavetobe publishedon an aggregated basis.IsAXA makingits Country-by-CountryReport public?For several years,and particularly since the publication of its first ta
126、x transparency report in 2019,AXA hascommitted togreater tax transparency.In this journey,AXAhas started topublish its CbCR data since 2021on a voluntary basis,two years ahead of the entry in force of the EU Directive requiring it.AXA is going astep further,publishing also its CbCR data for some fla
127、gship countries which are not part of themandatorycountry disclosures required by the EU directive.AXA continues on this path and publishes its 2022 CbCRdata in thepresent report.23AXA Tax Transparency Report Tax Year 2022Glossary1.StatedCapitalIt is the stated capital of all ConstituentEntitiesresi
128、dentfortax purposesinarelevant taxjurisdiction.The stated capital of Constituent Entities isaggregated so the stated capital investedthrough a sequence of companies can becounted morethanonce.5.Income tax accrued(current)Current tax accrued only reflects operationsin the current year,irrespective of
129、 whether ornot the tax has been paid.The basis of thecurrent tax is the taxable result,that isusuallydifferent fromtheIFRS one.Itdoesnotincludedeferredtaxesorprovision foruncertain taxliabilities.2.RevenuesIn the CbC report revenues should be split intwocategories:Third-partyrevenues:whicharegenerat
130、edfromtransactionswithindependent parties.This amount fullyreconciles with the published financialstatements.Relatedpartyrevenues:whicharegeneratedfromtransactionswithassociated parties.6.Accumulated earningsAccumulated earningsis the sum of acompanys profits,after dividend payments,since the compan
131、ys inception.The amountcan be negative in case of accumulatedlosses.The accumulated earnings of ConstituentEntities are aggregated so the accumulatedearnings invested through a sequence ofcompanies can be counted morethan once.3.Profit before taxThe profit before tax is based on AXAsconsolidated sta
132、tements prepared accordingtoIFRS standards.As,in accordance with local tax legislation,the IFRS are often not the standards used forthe computation of the corporate income tax,the IFRS profit can vary significantly from thetaxable income driving corporate income tax.7.EmployeesIt is the number of em
133、ployees on a full-timeequivalent(FTE)basis of all the ConstituentEntities resident for tax purposes in therelevant taxjurisdiction.The number of employees on page 16 isbased on legal number at the closing andincludes entities consolidated under equitymethodwhichare not included in theCbCR.4.Income t
134、ax paid(on a cashbasis)This is the amount of the corporate incometax actually paid during the reporting fiscalyear.This includes installments in relation toforecasted taxable profit of the year,thepreviousyearcurrenttaxbalanceandpaymentsrelatedtoreassessmentsorrefunds of previous years.It also inclu
135、deswithholdingtax.8.TangibleAssetsIt is the book value of the tangible assets asper theIFRS financial statements.It does not include cash or cash equivalents,intangible assets orfinancial assets.In AXA,it mainly represents own-used realestatesand equipment.INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-
136、COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION24AXA Tax Transparency Report Tax Year 2022AXA 2022 Country-by-country informationFigures reported in thousandsFlagship CountriesINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTION(1)No Stated C
137、apital when AXA is only operating through branches in the countryACTIVITIES P&C:General Insurance L&S:Life Insurance REINS:Reinsurance AM:Asset Management ASS:Assistance OTH:Others(administrative,holding,investment funds,)Revenues Main ActivitiesThird-Party Revenues Related-Party Revenues Total Reve
138、nues Profit Before Tax Income Tax Paid(cash basis)Income Tax Accrued(current)Stated Capital(1)Accumulated Earnings Number of Employees Tangible Assets CommentsMember States of the European UnionFrance P&C/L&S/AM/ASS/REINS/OTH30 920 1582 535 40833 455 5661 144 723(270 901)(32 532)17 840 52230 555 241
139、19 387350 814The current tax accrued is small due to the French taxgroups 2022 forex and hedging tax losses.The tax paidbased on the2021 resultwillbe adjusted in 2023.AustriaP&C/OTH324 05916 686340 7458 687(983)(4 038)-6 87597859Belgium P&C/L&S/ASS/OTH3 834 626123 7833 958 410632 247(53 683)(73 997)
140、881 5993 820 0963 430176 443The taxable profit is lower than the IFRS profit due totiming difference adjustments triggering deferred taxesin IFRS and non-taxable equitycapital gains.Czech RepublicASS73 9451 33675 2823 542(319)(2 288)835993931 847DenmarkP&C/L&S 7 973-7 9734 272(1 046)(46)-2 092115Fin
141、landP&C/L&S69 340-69 34023 603301628-12 85594146Carryforward losses used to offset the taxable profit oftheyear.Germany P&C/L&S/AM/ASS/OTH12 749 977377 67213 127 6491 162 200(256 858)(482 921)481 6596 219 9899 215348 512The taxable profit is higher than the IFRS profit due totiming difference adjust
142、ments triggering deferred taxesin IFRS.GreeceP&C/L&S/ASS19 808-19 808(1 832)71512-17 75614133The loss before tax in IFRS is made up of a consolidationof profit-making and loss-making entities.Such aconsolidation for tax purposes is however impossible inGreece.25AXA Tax Transparency Report Tax Year 2
143、022AXA 2022 Country-by-country information(1)No Stated Capital when AXA is only operating through branches in the countryINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONFlagship CountriesACTIVITIES P&C:General Insurance L&S:Life Insurance REINS:Rei
144、nsurance AM:Asset Management ASS:Assistance OTH:Others(administrative,holding,investment funds,)Figures reported in thousandsRevenues Main ActivitiesThird-Party Revenues Related-Party Revenues Total Revenues Profit Before Tax Income Tax Paid(cash basis)Income Tax Accrued(current)Stated Capital(1)Acc
145、umulated Earnings Number of Employees Tangible Assets CommentsMember States of the European UnionIreland P&C/L&S/AM/ASS/REIN 2 362 02137 1552 399 176409 933(45 658)(28 232)2 578 3392 083 8921 40329 629The tax result is lower than the IFRS profit due to timingdifference adjustments linked to unrealiz
146、ed losses thattrigger deferred taxes in IFRS.In addition,the worldwidetax regime allows AXA Irelands headquarters to useforeign losses in Ireland.Italy P&C/L&S/AM/ASS/4 482 143121 5924 603 735434 594(83 885)(34 733)1 406 9732 153 8182 26343 195The current tax accrued is small due to the Italian taxg
147、roups 2022 tax losses.The tax paid based on the 2021resultswillbe adjusted in 2023.Luxembourg P&C/L&S/AM1 049 6612 9891 052 65052 911(8 883)(12 222)216 032220 24230320 409Under IFRS,the profit before tax is made of aconsolidation of profit-making and loss-making entities.Such a consolidation for tax
148、 purposes is howeverimpossible for AXA XL entities in Luxembourg because ofthepresence ofa non-UE entity in theholding chain.MaltaP&C19-1914(1)-Netherlands P&C/AM279 5654 803284 36855 511(5 300)(4 934)18(884 667)86675The low current tax reflects the participation exemptionregimeapplicabletodividends
149、receivedintheNetherlands.PolandP&C/L&S/ASS196 756852197 60811 474(1 476)(1 682)427(5 110)7451 520The profit before tax in IFRS is made up of aconsolidation of profit-making and loss-making entities.Such a consolidation for tax purposes is howeverimpossible in Poland.PortugalP&C/L&S/ASS99 14922399 37
150、26 604(747)(857)1502 8954292 362Carryforward losses used to offset the taxable profit oftheyear.26AXA Tax Transparency Report Tax Year 2022AXA 2022 Country-by-country informationINTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONFlagship CountriesACTI
151、VITIES P&C:General Insurance L&S:Life Insurance REINS:Reinsurance AM:Asset Management ASS:Assistance OTH:Others(administrative,holding,investment funds,)(1)No Stated Capital when AXA is only operating through branches in the countryFigures reported in thousandsRevenues Main ActivitiesThird-Party Rev
152、enues Related-Party Revenues Total Revenues Profit Before Tax Income Tax Paid(cash basis)Income Tax Accrued(current)Stated Capital(1)Accumulated Earnings Number of Employees Tangible Assets CommentsMember States of the European UnionSpain P&C/L&S/ASS/OTH3 178 50351 4153 229 917172 01825 446(46 320)4
153、15 9592 710 3653 59140 374The installments are based on accounting result thatincluded non-taxable dividends leading to tax refundsthe year after.The lower tax basis in 2022 explains thesenet cash refunds.SwedenP&C/L&S289 9683 581293 549(21 981)(1 269)2 29296 5577366The profit before tax in IFRS is
154、made up of aconsolidation of profit-making and loss-making entities.Such a consolidation for tax purposes is howeverimpossible in Sweden.Flagship countries(other than EU Member States)Hong Kong P&C/L&S/AM 4 298 12152 0564 350 177557 866(23 927)(21 945)1 457 2293 528 3451 84677 493In Hong Kong,life i
155、nsurance companies are taxed on anet premiumbasis.Japan P&C/L&S/OTH5 482 27527 2135 509 488757 088(370 275)(290 705)1 463 330360 5223 90655 020The computation of the Profit Before Tax under IFRSdiffers from the taxable results as the latter triggersmany timing differences.Switzerland P&C/L&S/REINS6
156、551 881245 7476 797 6281 766 136(208 619)(198 325)587 1768 690 7924 631363 918The Profit Before Tax under IFRS that consolidatesprofit-making and loss-making entities is inapplicable inSwitzerland fortax purposes.United Kingdom P&C/REINS/AM/ASS8 676 726328 4349 005 160356 737(40 338)(49 420)2 452 27
157、15 382 04810 939342 473United States P&C/AM/ASS7 541 5343 583 94011 125 473694 162(166 888)(206 137)1 663 084(1 518 951)2 55771 56327AXA Tax Transparency Report Tax Year 2022AXA 2022 Country-by-country information(3)Although Bermuda is not included in the EU Grey/Black list of non-cooperative jurisd
158、ictions,it is shown in a dedicated line as it a low-tax country(2)EU grey and black list as of December 31,2022.See detail on the list on page 13 INTRODUCTIONAXA GROUP TAX POLICYCOUNTRY-BY-COUNTRY INFORMATIONTRANSFER PRICINGTOTAL TAX CONTRIBUTIONACTIVITIES P&C:General Insurance L&S:Life Insurance RE
159、INS:Reinsurance AM:Asset Management ASS:Assistance OTH:Others(administrative,holding,investment funds,)(1)No Stated Capital when AXA is only operating through branches in the countryFigures reported in thousandsRevenues Main ActivitiesThird-Party Revenues Related-Party Revenues Total Revenues Profit
160、 Before Tax Income Tax Paid(cash basis)Income Tax Accrued(current)Stated Capital(1)Accumulated Earnings Number of Employees Tangible Assets CommentsCountries in the EU Grey/Black list of non-cooperative jurisdictions(2)BarbadosOTH-57-1 17271-Theonly entity present in Barbados is being liquidated.Mal
161、aysiaP&C/ASS/REINS 167 3015 656172 9578 207(4 318)(4 013)46 186(2 226)964437These figures include also the contribution of itsinsurance operations untilthedate ofdisposal.ThailandP&C132 4573 543136 0007 702(368)(900)99 565(12 767)4831 700Carryforward losses used to offset part of the yearstaxable pr
162、ofitTurkeyP&C/L&S/ASS637 03224 037661 06981 940(50 319)(58 951)278 392(22 273)78030 878The taxable profit is higher than the IFRS profit due totiming difference adjustments triggering deferred taxesin IFRS.Other countriesBermuda(3)REINS/OTH1 244 1342 606 9803 851 114155 714(6 251)(9 651)95 4032 059
163、77316565 700The corporate income tax paid and accrued correspondtothewithholdingtaxes.Rest of the world7 675 964195 2277 871 191367 134(100 128)(116 404)2 931 770611 51424 804204 751TOTAL102 345 09610 350 327112 695 4238 851 261(1 676 620)(1 677 822)34 897 34866 000 34592 6082 230 92128AXA Tax Trans
164、parency Report Tax Year 2022Socit Anonyme(a public company under French law)-Share capital:5,251,433,141.05-Registered office:25,avenue Matignon 75008 Paris France-Paris Trade and Company Register 572 093 920AXA SA,the Groups holding company,is a French corporation organized in accordance with the l
165、aws of France.The AXA Group Organization chart is available on our website hereThe list of the main consolidated subsidiaries of AXA Group is available in our Annual Report(Note 2 Scope of consolidation,Consolidated financial Statements).DISCLAIMERThis report has not been audited and signed off by g
166、roups external auditors.The total tax contributions are only disclosed for our flagship countries(France,Belgium,Germany,Hong Kong,Italy,Japan,Spain,Switzerland,United Kingdom and United States)and are based on theindividual reporting ofthemostsignificant subsidiaries.Tax Transparency Report-Tax Year 2022Published in May 2023 Head of Publication:AXA Group Tax DepartmentWe warmly invite all our stakeholders to provide feedback and comments on our Tax Transparency Report: