We aspire to be the leading client-centric global universal bank.
Deutsche Bank is Germany’s leading bank, with a strong position in Europe and a significant presence in the Americas and Asia Pacific. Deutsche Bank provides banking services to corporations, governments, institutional investors, small and medium-sized businesses, and private individuals.
We serve shareholders best by putting our clients first and by building a global network of balanced businesses underpinned by strong capital and liquidity. We value our German roots and remain dedicated to our global presence. We also commit to a culture that aligns risks and rewards, attracts and develops talented individuals, fosters teamwork and partnership and is sensitive to the society in which we operate.
In keeping with this vision, we apply the principles set out in this document in the management of our tax affairs. These tax principles, which have been embedded in the Bank’s control framework for a number of years, have been approved by our Management Board and apply to all our businesses and group entities.
The key principles are:
- We undertake our tax affairs on a basis which generates sustainable value while meeting applicable legal and regulatory tax requirements.
- We give due regard to the intent and spirit of tax laws, the social context within which the Bank operates, and the Bank’s standing and reputation with the public, tax administrations, regulators, and political representatives.
Approach to tax risk management and governance
We operate a Three Lines of Defence risk management model. The 1st Line of Defence are the business divisions and service providing infrastructure areas (such as Group Technology Operations) who are the “owners” of the risks. The 2nd Line of Defence are the independent risk and control infrastructure functions (including our in-house Group Tax and Anti-Financial Crime functions). The 3rd Line of Defence is Group Audit, which assures the effectiveness of our controls. This Three Lines of Defence risk management model and the underlying design principles apply to all levels of the organisation, i.e. group-level, regions, countries, branches and legal entities. All Three Lines of Defence are independent of one another and accountable for maintaining structures that ensure adherence to the design principles at all levels.
Based on this model we have a clear framework setting out roles and responsibilities for defined tax types to ensure we remain compliant with our tax obligations.
Attitude towards tax planning
We manage our tax affairs in a way which aims to ensure that the tax consequences of business operations are appropriately aligned with the economic, regulatory and commercial consequences of those business operations, with due regard being given to the potential perspective of the relevant tax authorities.
In conducting our business affairs, setting up and structuring our business operations and commercial activities, we consider – among other factors – the tax requirements of the respective jurisdictions in which we operate, with a view to generating sustainable value for our shareholders. In this context we may seek to avail ourselves of tax benefits and beneficial tax rates available under those tax laws.
We have an in-house Group Tax function, which is an independent risk and control function separate to our business divisions, and we employ skilled professionals to ensure that our position with respect to the Bank’s own tax matters is robust. In appropriate situations our internal experts may take specialist external tax advice.
Level of risk
Our business is subject to various risks, including tax-related risks. We seek to understand and mitigate these risks where possible. A number of tax-related risks are an inherent consequence of the scale and diversity of our business activities and the international nature of our business. This is exacerbated by the growing complexity of international tax laws and divergent approach of national tax authorities in various instances.
In accordance with our principles, we operate with an appropriate control framework and governance to ensure that in all material aspects we are compliant with applicable tax laws, file accurate and timely tax returns, and pay the amount of tax due.
Relationships with tax authorities
We aim for our dealings with tax authorities to be undertaken in a proactive, transparent, professional, courteous, and timely manner. We seek to develop and foster good working relationships with tax authorities.
In 2010 we were among the first banks in the United Kingdom to adopt the UK Code of Practice on Taxation for Banks.
Preventing tax evasion
Tax evasion is illegal and goes against our culture, values and beliefs and our policies strictly prohibit aiding or abetting tax evasion.
We are committed to supporting the development of effective regulations and procedures at international standards to combat financial crime, including tax evasion. We consider this as vital to ensuring the stability of banks and the integrity of the international financial system as a whole; it also helps to protect us from being misused for committing criminal offences.
We have procedures and controls in place to prevent the misuse of our services, including for the purposes of tax evasion and its facilitation.
Deutsche Bank has made significant efforts to safeguard the bank from any involvement in tax evasion and other forms of financial crime. To this end an enhanced Know Your Client (KYC) Policy was launched in April 2017, which included strengthened KYC and New Client Adoption procedures, together with enhanced procedures for identification of ultimate beneficial owners and screening of intermediary beneficial owners.
Deutsche Bank is prepared to discontinue, and has discontinued, relationships with clients in order to safeguard the bank against the risk of tax evasion or other forms of financial crime.
We consider that the above statement complies with Deutsche Bank AG’s obligations under paragraph 16(2) of schedule 19 of the UK Finance Act 2016 to publish a tax strategy.