4. Tax Planning Our tax activities are conducted with the clear understanding that all facts and circumstances have to be disclosed to the tax authorities. # Efficient Tax Planning # We seek efficiency in tax matters, including the prevention of double-taxation to pay the tax due, following reasonable interpretation and application of tax rules. We do not engage in aggressive tax planning or artificial structuring that lacks business purpose or economic substance. If jurisdictions offer tax incentives that are publicly available and rule-based, for example to promote a country’s economic development and our business activity is within their scope, they are carefully considered. Yet, it depends on the specific needs of our business operations and the overall fit with our investment or business strategy whether such tax incentives are eventually claimed. We refrain from discretionary tax arrangements. Transfer Pricing # International activities and transactions with and between Group subsidiaries are disclosed to the relevant tax authorities as part of our tax returns or other filing requirements. For instance, in many countries cross-border business relations with affiliated parties are subject to detailed documentation requirements, including their pricing and comparison basis known as master file, local file and Country-by- Country Reporting. We ensure that the pricing for intra-group activities is consistent with the OECD arm’s length principle 10 as well as with local transfer pricing rules to pay adequate tax on profits where the value is created. As such, transfer pricing is not used for profit shifting and we are committed to complying with the regulations of every tax jurisdiction in which we operate regarding the transfer pricing documentation and notification requirements. Engagement in Tax Havens Allianz approach # As a general rule Allianz does not engage in tax haven jurisdictions. Exceptions can be made if there is a valid business reason for the engagement. The achievement of tax advantages and avoidance of paying our fair tax share on activities taking place elsewhere are not to be seen as valid business reasons. The EU has published a ‘black list’ and a ’grey list’ with countries outside the EU including jurisdictions that grant foreign enterprises opportunities to engage in tax avoidance/evasion. Allianz regards the fact that a country is included in those lists and has a statutory income tax rate of below 10% as an indication for a tax haven. Contemplated acquisitions or investments in tax haven jurisdictions need preclearance from Allianz Group Taxation in line with the predefined conditions set out in the respective internal Group Standard. Consolidated participations Subsidiaries in nil or low taxed jurisdictions carry out operative insurance, reinsurance or asset management activities, including insurance- related administrative or assistance services. The choice of residence in these jurisdictions is not tax but business or regulatory driven. The fact that fully consolidated entities located in tax havens contributed less than 1% to the Group’s profit before income taxes in 2021 makes this obvious. Non-consolidated investments Our insurance companies hold diversified investment portfolios that include so-called alternative assets: equity, debt, or fund investments in real estate or infrastructure or private equity. These are asset classes that are particularly beneficial for the policyholder during low-interest periods. These investments can include fund products that are structured with various legal entities in different jurisdictions, which can contain low or nil tax countries. In these cases our investment will rarely exceed 10% of the total fund volume. Regardless of the lower-tier tax burden, income from such an investment is generally subject to further taxation in the country of residence of the investing Allianz entity. Our asset management entities, PIMCO and Allianz Global Investors, have fund-related entities in various jurisdictions. In accordance with international practice, most of them are established in countries that do not impose an additional layer of taxes on the fund itself. This ensures that, when the investment return is taxed at the customer’s level in their country of residence, their tax position is the same as if they had made the investment directly. Regardless of where the fund invests, tax will be paid in accordance with the tax rules of those countries; it is not intended that Allianz Group companies derive tax advantages from the fund jurisdictions. This procedure also applies in those cases where, due to commercial and regulatory reasons, the fund-related entities are established in tax haven jurisdictions. 10 Arm’s length principle: amount one related party charges to another for a product/service is the same as if the parties were not related. GRI 207–1 Allianz Group Tax Transparency Report 2021 5
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