Sustainability

Tax Transparency

Both as a multinational company and as a provider of investments and savings products, the AXA Group follows a responsible and transparent approach on tax issues.

AXA Group Tax Policy

Both as a multinational company and as a provider of investments and savings products, the AXA Group follows a responsible and transparent approach on tax issues. As a general principle, AXA is committed to complying with the rules applicable to all countries in which the Group operates, including regulations designed to prevent tax evasion.

The taxes AXA pays are an important part of its wider economic and social impact and play a key role in the development of countries where it operates. AXA regards it as a critical element of its commitment to grow in a sustainable, responsible and socially inclusive way.

Overall, the AXA Tax Community represents around 150 qualified professionals. The AXA Group Tax Department reports directly to the Group Chief Financial Officer, who is a member of the Management Committee, and in most countries and business lines, the local tax team reports to the local Chief Financial Officer. The Group has implemented a formal internal review and sign‑off process pursuant to which Chief Financial Officers are required to certify various matters, including tax matters.

AXA also squares its responsibilities as a co‑operative, compliant taxpayer in each and every country in which it operates, with the need to support competitive business growth – serving all its stakeholders including investors, suppliers and employees. We seek an open dialogue with our stakeholders, including relevant tax authorities, our shareholders and regulators.

The Group Audit Committee reviews the Group tax policy annually.

Tax aspects in relation to AXA as a multinational company

The AXA Group’s approach to tax issues

In the countries where it operates, AXA is both a taxpayer and a tax collector, given that many specific taxes are levied on insurance and reinsurance policies and collected from our customers as part of the insurance, reinsurance and Asset Management revenues, and remitted to the various state and federal administrations around the world.

The tax function is organized within the Group to ensure full compliance with all tax legislation in the countries where AXA operates. In addition to the Group Tax Department based in France, all key operational entities/countries/geographic zones have a tax team in charge of ensuring that tax regulations are well understood and fully satisfied by the entities.

As a part of the global internal risk assessment, a specific tax internal control program has been implemented. These controls must be reported and documented by each team in scope to ensure full compliance. There is a yearly update made to the Group Audit Committee around tax topics with a specific focus on ongoing tax audits and litigation.

A Tax Code of Ethics, agreed between Group Tax Department and local tax teams, highlights the key principles guiding the actions of the various tax teams:

  • to remain up to date with respect to applicable laws and regulations;
  • to comply with tax laws and regulations;
  • to maintain a good relationship with the local tax authorities; and
  • not to engage in aggressive tax driven transactions that could compromise the good reputation of the Group, or otherwise put the Group at risk.

Within the objective of keeping good relationship with tax authorities, the AXA Group may seek, when necessary, certainty in advance from tax authorities to confirm an applicable tax treatment based on full disclosure of all relevant facts and circumstances. In addition, AXA is keen to build trust‑based relationships with tax authorities and therefore to adhere, when possible, to cooperative compliance programs or similar initiatives in countries in which it operates.

Compliance with this Code of Ethics is a prerequisite of the activities performed by all AXA tax teams and gives rise to an annual certification by each head of tax, which is provided to the Group Tax Department. In addition, a bi‑annual tax review process of each key entity or business line is performed by the Group Tax Department in connection with each local team. During these reviews, specific attention is given to tax audits and associated tax risks as well as market positions on tax matters that may impact AXA. These reviews offer a global framework for the tax teams to identify, analyze, control, and report tax risks.

Lastly, an International Tax Committee composed of various senior tax executives within AXA tax teams meets every quarter to ensure consistency in approach on some technical topics, as well as agreements on guidelines, when necessary, connected to specific items.

As an international group operating in several countries, the AXA Group is subject to various tax regimes and regulations and takes into account any changes in tax law. AXA is specifically vigilant about the changes that could result in higher tax expenses and payments, higher compliance costs or that may affect the AXA Group’s tax liability, return on investments and business operations. In particular, please see the paragraph Changes in tax laws, regulations or interpretations or uncertainties in the interpretation of certain tax requirements may result in adverse consequences to our business and our results of operations in Section 5.1.2.3 - Regulatory and litigation‑related risks of Annual Report.

When considering how AXA entities structure commercial arrangements, tax implications are analyzed in parallel with other consequences such as capital efficiency and legal and regulatory aspects when deciding between potential alternative arrangements.

AXA has no licensed insurance or operating business activities in the countries specifically identified as non‑cooperative jurisdictions* under French and European rules, except in Panama. The presence in Panama is purely driven by operational purposes. In Panama, AXA still holds two non‑consolidated operating companies (one providing assistance services to local customers, and the other delivering health claim services) employing circa 40 people.

In addition, AXA holds a minority financial investment in Reso Garantia, a Russian insurance company.

More globally, AXA does not use non‑cooperative jurisdictions to avoid taxes on operational activities performed elsewhere.

To the extent that AXA operates in countries with tax rates lower than in France, its presence is driven by business operations. AXA has accordingly been operating in Bermuda since the acquisition of the XL Group in September 2018, with nearly 200 employees working for AXA XL there. Bermuda is a center of expertise and one of the key jurisdictions in the worldwide reinsurance market, offering flexible local capital management regulation regarding required capital for reinsurance activities. AXA supports the Economic Substance legislation enacted in Bermuda, where it conducts insurance and reinsurance business. Bermuda, which was previously a low‑tax jurisdiction, enacted at the end of 2023 a tax reform to create a corporate tax at 15% as from January 1, 2025. It is not considered as a non‑cooperative jurisdiction under French and EU laws.

Disclosure on tax matters and information on taxes connected with the Group’s activities in each country

The consolidated financial statements are prepared in compliance with IFRS standards (as disclosed in Section 6.6 – Note 1 - Accounting principles of this Document). Accounting for income taxes recognizes both the current tax consequences of transactions and events and the future tax consequences of the future recovery or settlement of the carrying amount of the entity’s assets and liabilities, as required by IAS 12 (see Section 6.6 – Note 1.17.1 - Income taxes of Annual Report).

The Consolidated Financial Statements present the reconciliation between the theoretical tax charge and the effective tax charge under IFRS. All differences are fully explained (see Section 6.6 – Note 17 - Tax of Annual Report). It should be noted that in many jurisdictions where AXA operates, the income and capital gains on savings products benefit from a favorable tax treatment, also when such products are included in Life insurance products. This leads to a lower effective tax rate for Life insurance companies.

In addition to the details reported on the Group effective tax rate, AXA reports substantial information on the impacts of any change in local tax regulations on its business, as well as details of the tax burden per line of business and per country. AXA’s income tax expenses/benefits are extensively disclosed in the Document and are broken down by business segment and country. For each, a dedicated paragraph provides a comment about the line related to Tax Income (see Section 2.3 - Activity report of Annual Report).

Since 2019, AXA has disclosed an annual tax transparency report where it provides information on its tax footprint in its key geographies, as well as the key principles of its tax policy. The tax transparency report has also included, since its 2021 edition, the Group Country‑by‑Country report (CBCR). This report is available on the AXA website (www.axa.com) at the end of the AXA Group Tax Policy page. AXA updates this report annually and the most recent version was issued in June 2024.

Tax aspects of activities and products offered by the Group

Activities of the Group

The Group’s activities are subject to strict regulations and rigorous control in each territory in which AXA operates. In addition to these regulations, AXA has developed a set of detailed internal standards that applies to all Group entities that are managed or controlled by AXA, regardless of the activities undertaken by the entity or its ownership structure.

According to these internal standards, Chief Executive Officers must ensure that staff are fully conversant, and comply with applicable laws, mandatory Codes of Conduct, rules and regulations (including applicable tax laws and regulations) relevant to their area of operations.

This means that local senior management must appreciate the tax implications of the activities in their entity. The main considerations are:

  • compliance with the taxation of employees in the territory in which they are employed;
  • compliance with the taxation of business undertaken in the territory (including levies and sales taxes); and
  • cross-border tax issues.

A specific focus on transfer pricing is included in these standards, to ensure that the pricing of our intra‑group activities is consistent with the OECD arm’s length principle as well as with local transfer pricing rules to pay adequate tax on profits where the value is created.

In particular, Chief Financial Officers must ensure that insurance and reinsurance policies entered into represent a true transfer of risk and that their status as insurance or reinsurance contracts could not be subject to challenge. Business between Group companies must be transacted at market prices where a market price exists, or in the absence of market prices, must be supported by formally documented justification for the charge made.

Products offered by the Group

AXA products are not designed to allow or encourage tax evasion. The Group has set up a validation framework to ensure that new products undergo a thorough approval process before they go to market.

The local decision to launch a new product is subject to a review and approval process that complies with the AXA Group’s standards in terms of product features, pricing, asset‑liability management and aspects related to legal, compliance, regulatory, accounting and reputation.

AXA has also established strict policies on cross‑border activity and know your customer policies, to ensure that our products and services are not misused for money laundering or tax evasion purposes and are subject to specific rules according to which cross‑border life insurance proposals must be presented to the Group Tax and Compliance Departments for validation.

While all Group entities must in any case comply with local regulations, the Group Tax Department can veto a product if this product is not compliant with internal rules.

The AXA Group complies with tax transparency standards and regulations including the OECD Standard for Automatic Exchange of Financial Information (Common Reporting Standard), the US Foreign Account Tax Compliance Act (FATCA), and DAC 6 EU directive (declaration of tax schemes considered to be aggressive in the European Union).

In its compliance with these standards and regulations, AXA may, as a provider of investments and savings products, have tax reporting obligations with respect to certain cross‑border products it designs or implements. In particular, certain investments and savings products with no particular tax motive may be reportable under the above‑mentioned standards and/ or regulations.

Since the entry into force of these regulations, the AXA Group has ensured that it has a compliance system in place, including procedures and adapted control plans.

* The list of non‑cooperative jurisdictions under French tax rules is given by a ministerial decree dated February 12, 2010 as last amended by a ministerial decree dated February 16, 2024, and is composed of the following countries: American Samoa, Anguilla, Antigua and Barbuda, the Bahamas, Belize, Fiji, Guam, Palau, Panama, Russia, Samoa, Seychelles, Trinidad and Tobago, the Turks and Caicos Islands, the United States Virgin Islands and Vanuatu. Pursuant to article 238‑0 A of the French Code général des impôts, this list is updated at least once a year and any update must include the states and jurisdictions on the blacklist set out in Annex I to the conclusions adopted by the Council of the European Union on December 5, 2017, as updated from time to time. On October 8, 2024, the Council of the European Union adopted a revised list of non‑cooperative jurisdictions, which is composed of the American Samoa, Anguilla, Fiji, Guam, Palau, Panama, the Russian Federation, Samoa, Trinidad and Tobago, the United States Virgin Islands and Vanuatu.

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