Deutsche Bank Governance and operations Non-Financial Report 2022 Tax Tax – Clear principles of conduct and behavior as they relate to the bank’s tax affairs – Tax governance and control framework fully embedded into the bank’s operating principles and models GRI 3-3, 207-1/3/4 Deutsche Bank’s tax strategy and related policies set out principles of conduct and behavior as they relate to the bank’s tax affairs. These key principles are: – Deutsche Bank undertakes its tax affairs on a basis which generates sustainable value while meeting applicable legal and regulatory tax requirements – Deutsche Bank gives 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 (*) and principles, which have been approved by the Management Board, apply to all businesses and The Tax Strategy entities. They enable the bank to manage the 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. The bank aims for its dealings with tax authorities to be undertaken in a proactive, transparent, professional, courteous, and timely manner and seeks to develop and foster good working relationships with tax authorities. The bank monitors developments and legislative changes and routinely updates its tax strategy and related policies and procedures in response. In recent years the EU’s mandatory tax disclosure directive known as DAC6 has been an area of significant focus for the bank. DAC6 required EU member states to introduce tax reporting obligations for taxpayers and intermediaries (such as banks) in relation to cross-border arrangements containing specified tax hallmarks. The bank evaluated its products and services against DAC6’s reporting requirements, taking into account administrative guidance where available, and introduced policies and workflow procedures to ensure continuing compliance. The bank’s tax strategy was updated accordingly. The OECD and the European Union (EU) continue to be focused on wide ranging changes in the principles of international taxation emanating from the OECD's Base Erosion and Profit Shifting agenda. On December 20, 2021, the OECD issued model rules for a global minimum tax under Pillar Two (‘Global Anti-Base Erosion Model Rules’). These model rules create an internationally coordinated system of taxation intended to ensure that multinational enterprises pay a minimum level of tax of 15% in each jurisdiction in which they operate. The United States are not expected to implement a global minimum tax under the Pillar Two OECD model rules in the near future. Instead, in August 2022, the U.S. enacted the corporate alternative minimum tax (CAMT). The CAMT is imposed at a rate of 15% on profits before tax, typically determined under U.S. Generally Accepted Accounting Principles. The CAMT is not expected to increase the bank’s overall tax burden but may accelerate tax payments. The bank is estimated to be subject to the CAMT starting in 2023 or 2024. Unlike the U.S., the EU issued a draft directive to implement the OECD model rules on December 22, 2021, and the directive was adopted on December 15, 2022. The provisions under the EU directive will need to be transposed into national law by Germany and the other EU member states and are expected to take effect beginning with tax year 2024. The bank’s in-house tax function has set up a working group to monitor developments and start assessing potential future implications and implementation efforts. Deutsche Bank is represented with its active subsidiaries and branches in almost 60 jurisdictions. On a combined basis Deutsche Bank’s blended statutory tax rate across all these jurisdictions on average amounts to 28% to 30%, which is significantly higher than the contemplated minimum tax of 15%. Of the close to 60 countries, six apply a statutory tax rate of less than 15% to the bank’s operations. As of December 31, 2022, none of these countries are listed on the EU list of non- cooperative jurisdictions for tax purposes. On February 14th, 2023, the Council of the EU added Russia to such list. The implications for Deutsche Bank and its Russian operations are currently under review. As a matter of principle, Deutsche Bank reports its profits in the countries in which they are generated, this means that profits are also taxed in those countries. The intercompany transactions are undertaken on an arm’s length basis in accordance with internationally accepted OECD transfer pricing principles, giving due consideration to applicable local rules and requirements. Deutsche Bank does not undertake uncommercial artificial steps for the purpose of obtaining tax benefits. 89
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