Atradius Tax Policy 2019

The parent entity of the Atradius Group, Atradius N.V.,
is a Dutch company that is majority owned by Grupo
Catalana Occidente, S.A., a Spanish company that islisted on the Spanish stock exchange.
The Atradius Group’s tax policy is aligned with thetax policy of Grupo Catalana Occidente. Accordingly,
it is aimed at ensuring compliance with applicabletax regulations and seeks to establish an appropriate
coordination of the tax practices of the entities in theAtradius Group.
The tax policy operates within the framework offulfilling the corporate interest and supporting along-term business strategy that seeks to minimise
tax risks and inefficiencies in the implementation ofbusiness decisions.

Atradius Tax Policy 2019
Principles
The Atradius Group has adopted the principles of integrity,honesty, transparency and professionalism as thefoundations that inform and guide our business, including
our approach to tax matters.
As a responsible corporate citizen we aim to:■■Ensure compliance with applicable tax regulations in
all jurisdictions in which we operate■■

Promote reciprocal and cooperative relationships with
tax authorities that are based on the above principles
as well as on respect for the law, cooperation,transparency and good faith■■

Ensure that our tax policies are applied consistently
across the Atradius Group and Grupo Catalana
Occidente, S.A.

■■

Promote responsible actions that take into accountthe interests of stakeholders and the economic
development of the communities in which theAtradius Group is integrated. This includes thepayment of all taxes due in accordance with thetax regulations of each jurisdiction in which theAtradius Group operates as an important part of its
contribution to the economies of all the jurisdictions
in which it operates■■

Prevent and minimise significant tax risks, ensuringthat the tax profile of the Atradius Group bears anappropriate relationship to the structure and locationof activities, resources including human resources,and business risks

Tax management and governance
Each legal entity / branch in the Atradius Group has theprimary responsibility for determining, coordinating andsupervising the compliance with tax regulations in eachjurisdiction in which it operates. The Group Tax team
based in Amsterdam supports all entities in the AtradiusGroup in respect of tax matters and ensures that aconsistent approach is taken across the group with respect
to tax policies.
In most cases, tax matters are managed through thecooperation of our Group Tax team and Local Financeteams, with the assistance of independent tax advisors.
The Atradius Group has a tax control framework (TCF),
which is embedded in its risk governance and internal
control framework. The Management Board owns,
implements and oversees Atradius group-wide risk
governance through the Risk Strategy Management Board(RSMB).

The RSMB consists of all members of the Management
Board, as well as the directors of the Group Risk
Management, Strategy and Corporate Development
and Group Finance. The Supervisory Board and relevant
committees thereof (e.g. Audit Committee with assistanceof the internal audit team) are responsible for overseeingthat the Management Board implements, amongst otherthings, a suitable risk management and internal controlsystem.
We mitigate potential tax risks by:■■

Ensuring specific controls are included in the quarterly
Financial Reporting Controls.

■■

Putting control mechanisms in place to ensurecompliance with tax regulations and with theprinciples outlined above. This is a part of an
appropriate business management process, which canalso include the use of independent tax advisors■■

Employing processes and controls to ensure due
consideration is given to tax implications; for example
by requiring input from our Group Tax team in
respect of new products, mergers and acquisitions or
intragroup transactions■■

Requesting services from reputable independenttax experts; for example where the application oflaw is unclear or where we do not have the required
expertise or resources available internally■■Following the available and applicable guidance fromtax authorities and codes of good tax practices in thejurisdictions in which we operate■■

Seeking guidance from tax authorities prior to tax
positions being taken, which may include requesting
tax rulings from a tax authority

The internal Guidelines on Financial Reporting Controls
prepared by the Group Risk Management team defines
roles and responsibilities and provides a descriptionof the related processes such as improvement points,
assessment and sign-off, management testing andretaining evidence (periodically audited by the internalaudit team).
In addition, a bi-annual detailed tax risk review process
forms part of our TCF. The Management Board isfrequently updated in respect of tax matters.

Tax risk profile
We seek to maintain a low to moderate tax risk profile andwe aim to always comply with both the spirit and the letterof the law.
Within the Atradius Group tax exposures and tax risks canarise for numerous reasons. Typically, tax risks are much
more likely to arise in respect of cross-border transactions
given the multitude of tax jurisdictions in which weoperate and the different interpretation of the various tax
authorities.
We assess our exposure to tax risks in a number of ways
including: short and long term fiscal impact; the impact on
our corporate reputation; the impact on our relationships
with governments and tax authorities; and the impact on
our stakeholders including shareholders, clients, and thebroader communities in which we operate.

Tax planning
Tax planning is used to support and ethically alignour business operations with tax regulations in thejurisdictions in which we operate.
As such, our Group does not make use of aggressive tax
planning strategies. We do not operate through opaqueor artificial structures, or structures that are intended toresult in tax avoidance. We do not use tax havens and ourpresence in any so called low-tax jurisdiction is related
to our effective business activities in those jurisdictions
and is not aimed at shifting profits to such jurisdictions
in order to reduce our tax burden or obfuscate ourtransparency.
Atradius is driven by commercial objectives. While theidentification and consideration of tax matters, including
tax risks and ensuring our continuing compliance withapplicable tax regulations, forms an important part of our
day to day business activities, tax is not a key driver in ourdecision making process.

Transfer pricing
As a global organisation with different types and levels ofresources and expertise in each jurisdiction in which we
operate, intragroup transactions play a significant role
as we strive for success. With these transactions cometransfer pricing considerations that are presided by theprinciples of free competition, value creation and theassumption of risks and benefits.
We seek to comply with the OECD Transfer Pricing
Guidelines and the transfer pricing regulations in eachof the jurisdictions in which we operate. As a result ourprofits are derived and taxed where value is created andour transfer pricing policies are based on compliance withthe arm’s length principle. We do not enter into relatedparty transactions solely to erode the tax base or totransfer profits to low-tax jurisdictions.

A formal tax governance process is in place to ensure thatthe perspectives of all relevant stakeholders (internaland external) are considered prior to significant decisions
regarding transfer pricing policies being made.

ProductsIn the elaboration and design of any product, we consider
the tax implications that it may have on our customers,and provide them with transparent, clear and responsible
guidance to assist them in fulfilling their tax obligations.
The products we offer are designed to provide commercial
solutions to our customers and are not designed toproduce or facilitate tax avoidance or evasion.

Interactions with tax authorities
We aim to maintain and develop relationships withtax authorities that are governed by the principles ofcooperation, transparency, mutual trust and good faith.
Our interactions with tax authorities are carried out in aprofessional and honest manner.
We cooperate and proactively collaborate with tax
authorities to provide certainty with respect to tax mattersand to ensure our compliance with tax regulations. We
respond to requests from tax authorities for informationor documents as soon as possible.
Atradius N.V. has its fiscal residency in the Netherlands.
Since 26 September 2012 it has entered into a covenantwith the Dutch tax authorities regarding horizontal
monitoring. This means that uncertain tax positions
relating to any of the Dutch entities within the AtradiusGroup are discussed with the tax authorities up front,
before submitting the tax returns. Horizontal monitoringis based on mutual trust between the taxpayer andthe Dutch tax authorities and establishes a more equal
position between both parties. Review of the TCF forms
part of the process.
Likewise, we cooperate with the competent tax authorities
in the detection of, and search for, solutions for fraudulent
tax practices of which the Group is aware that may be usedin the markets in which the Group has a presence.

Scope and references
This tax policy applies to financial year 1 January 2019 –31 December 2019. It is applicable to Atradius N.V. and allof its direct and indirect majority owned shareholdings,including branches. It has been prepared in accordancewith the requirements of the UK Finance Bill 2016
Schedule 19, paragraph 19(2).
Approval date by the RSMB: 22 January 2019

Connect with Atradius

atradius@atradius

atradiusgroupwww.atradius.com

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Atradius
David Ricardostraat 1,1066 JS Amsterdam
Postbus 8982, 1006 JD Amsterdam
The Netherlands