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2020 Tax Contribution Report B U I L D I N G T H E D R E A M 2 5 Y E A R S

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Page 1: Tax Contribution Report 2020

2020

Tax Contribution Report

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Page 2: Tax Contribution Report 2020

00.Index

01.Letter from CEO

03.Commitment and compliance

02.2020 Total tax Contribution

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Page 3: Tax Contribution Report 2020

01. Letter from CEO

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Dear reader,

Since our beginnings in 1996, CIE Automotive has led a project of economic and social growth based on its commitment to the environment and trust with our different stakeholders. Today, CIE Automotive is a strengthened, solid and unified industrial group, driven by the same enthusiasm and commitment which we began with 25 years ago. During this time, in addition to creating and distributing value to our shareholders, we have understood the company as an essential contributor to the state of welfare.

At CIE Automotive, we are fully aware of the emerging social, institutional and investor demand for transparency in relation to our activities; including our fiscal and tax policies and practices. In response to this claim, I am pleased to present this Tax Contribution Report, which aims to step forward in this spirit of transparency we have been working on.

Our growth over the past 25 years has led to the integration of more than 100 companies throughout our history, in 20 countries, operating in different technologies and with different realities. Each of these incorporations has been a fascinating challenge which has involved a coordination and integration effort with very satisfactory outcomes. This growth has generated the need to understand and apply different regulations and tax criteria constantly changing over the years. To that end,

Jesús Mª Herrera

Chief Executive

Officer

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2020 01.Tax Contribution Report

Letter from CEO

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we have collaborated in all territories both with those who have joined our project and who are an essential part of CIE Automotive, as well as with third party teams, by always applying for transparency and accountancy. Some years ago, CIE Automotive launched a strategic project to promote the tax field that involved the definition of a common framework in the search of a corporate tax culture and awareness among all our people. Additionally, the coordinated vertical integration of CIE Automotive – plant – advisor has resulted in the homogenization of consolidated tax information, through the development of innovative tools that have facilitated the integrated management of such information (currently subject to more than 20 different tax regulations), the establishment of homogeneous criteria for processes; and as a result of all the above, the application of an efficient, responsible and unified tax policy.

As a summary, with this Tax Contribution Report, we want to publicly show what is expected from us, and what we have already been doing in the past: an active and committed contribution with the global environment. In addition, and guided by our spirit of ongoing improvement, I am pleased to inform you that CIE Automotive has acceded to the Code of Good Tax Practices of the Spanish State Tax Administration Agency (AEAT), with the only objective of reaffirming itself in the implementation of the indications and recommendations included in such code; and that we have been carrying out throughout our path.

With these words, I complete this letter excited believing that, after reading this report, any of you will be able to better understand and appreciate our tax and social contribution, performed in a convinced and committed manner for each of the people, stakeholders and companies who are part of us.

In 2021, CIE Automotive has acceded to the AEAT Code of Good Tax Practices to reaffirm its commitment to responsible taxation

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2020 01.Tax Contribution Report

Letter from CEO

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02. 2020 Total tax Contribution

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02.1EXECUTIVE SUMMARY

Transparency is a priority for CIE Automotive and this 2020 Tax Contribution Report, which breaks down the main tax payments in the territories in which the company is present, reflects the company’s commitment to respond to the relevance given by stakeholders to tax matters.

2020 TOTAL

TAX RATE

TOTAL TAX CONTRIBUTION CIE AUTOMOTIVE GROUP 2020: 349.3€M

63%TAXES COLLECTED

194.4€M

TAXES BORNE

154.9€MDuring 2020, CIE Automotive’s Total Tax Contribution in all its geographies represents 63%, more than half of its profit before taxes borne.

For every € 1 of Corporate Income Tax paid, CIE Automotive has additionally contributed with € 2.6 of taxes borne and € 4.5 of taxes collected.

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2020 02. 2020 Total tax Contribution

Tax Contribution Report

> 1,000€M

TOTAL VALUE GENERATION

IN 2020

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02.2FRAMEWORK

CIE Automotive’s Total Tax Contribution (TTC) framework measures the total contribution made by each of the companies of the Group to different tax authorities considering a cash-flow criterion.

There are two different type of taxes when taking about tax contribution:

· Taxes borne (Tax charge): taxes that represent an effective expense for CIE Automotive, reducing its profit (corporate income tax, taxes on production, social welfare paid by the company, etc.).

· Taxes collected (Tax collection): taxes withheld or passed on to the final taxpayer, where CIE Automotive assumes the responsibility of their collection, but not bearing the cost (value added tax, sales tax of products, taxes collected from employees, etc.).

CIE Automotive’s framework classifies taxes into 4 large categories:

Taxes on profits: includes taxes borne / collected on profits obtained by companies such as corporate income tax.

Other taxes: other types of taxation that do not fall into the previous categories (property, environmental and other taxes).

Taxes associated with employment: contributions to Social Security and other similar charges borne or collected by the employer.

Taxes on products and services: those levied on the consumption of goods and services.

TOTAL TAX

CONTRIBUTION

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02.3TOTAL TAX CONTRIBUTION

In 2020, and despite the global economic recession derived from the pandemic, taxes paid by CIE Automotive continue to represent a very relevant percentage of its total income, 349.3 million euros of total tax contribution. CIE Automotive pays close to 1 million euros a day to tax administrations.

2020 Total Tax Contribution

TAXES BORNE TAXES COLLECTED44% 56%154.9€M 194.4€M

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2020 02. 2020 Total tax Contribution

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12%2020 TOTAL TAX CONTRIBUTION REPRESENTS

OF 2020 TURNOVER

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02.3TOTAL TAX CONTRIBUTION

Taxes borne represent a cost for companies and have a direct impact on the generated profit (own taxes).

In the case of CIE Automotive, the profile of taxes borne in 2020 is as follows:

CIE Automotive collects taxes from customers, employees, suppliers and shareholders for tax authorities. In 2020 the profile of taxes collected is as follows:

Out of the total own taxes, Corporate Income Tax paid represents only 28% of total taxes borne and 12% of the total tax contribution of CIE Automotive.

Taxes borne Taxes collected

TOTAL

154.9 €M

TOTAL

194.4 €M

Taxes on profits

Other taxes

Taxes associated with employment

Taxes on products and services

4.6%31.9%

51.4%52.2%

43.9%10.4%

0.1%5.5%

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02.3TOTAL TAX CONTRIBUTION

Total Tax Rate ratio (TTR) is a measure of the cost of all taxes borne in relation to the benefits obtained by a company. The calculation is performed as the percentage of the taxes borne with respect to the profit before said taxes*.

For every 100 euros of profit before taxes borne, CIE Automotive pays 63 euros of taxes to tax authorities.

*Profit before tax excluding share in profit of associates.

Source: PwC, “Paying Taxes 2020” Report referred to the year 2018 carried out by the World Bank, which compares corporate taxation throughout the world from a typical medium-sized company.

TTR ratio

COMPARATIVE ANALYSISTotal Tax Rate

CIE AUTOMOTIVE

EUROPEAN UNION

63% 39%SPAIN

47%

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2020 02. 2020 Total tax Contribution

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63%TOTAL TAX RATE

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Shareholders 19%

Employees 43%

Taxes borne 16%

Taxes collected 19%

Interests 3%

CIE AUTOMOTIVE

In 2020, CIE Automotive has made an economic and social contribution to tax authorities through the payment of its own and third-party taxes, to financial institutions through interest payments, to shareholders through the distribution of dividends and to employees with the payment of wages and salaries, of

more than 1,000 million euros.

02.3TOTAL TAX CONTRIBUTION

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1,000.3 €M

Shareholders 25%29%

Employees 20%21%

Taxes borne 19%14%

Taxes collected 33%36%

Interests 3%

COMPARATIVELYwith respect to the European

Union(1) and Spain(2) the distribution of said contribution would be:

EUROPEAN UNION

SPAIN IBEX 35

Sources: (1) Total Tax Contribution study from European Business Tax Forum December 2019.(2) PwC IBEX 35 Total tax Contribution report 2019. Spain’s Stock Market Benchmark.

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02.3TOTAL TAX CONTRIBUTION

The ratio of total distributed value is a measure to calculate and reflect, not only the value generated by the payment of taxes borne and collected to public authorities, but also to fully represent the economic value that CIE Automotive generates and contributes to society.

In accordance with CIE Automotive TTC methodology, the value distributed is made up of the sum of the following elements:

Total distributed value

(1) 5% capital reduction to boost shareholder remuneration.

(2) Accrued expenses for wages and salaries (net of taxes collected on behalf of employees).

· Taxes borne and collected:

349.3 €M

· Net interest paid to financial institutions:

34.2 €M

· Dividends and other remuneration to shareholders(1):

189.4 €M

· Wages and salaries(2):

427.4 €M

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2020 02. 2020 Total tax Contribution

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IN 2020, MORE THAN 1,000 MILLION EUROS

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dato destacado

02.4GEOGRAPHIC CONTRIBUTION

Taxes borne

Taxes borneTaxes borne Taxes borne

Taxes borne

Taxes collected

Taxes collectedTaxes collected Taxes collected

Taxes collected

NORTH AMERICA

EUROPABRASIL INDIA

CHINA

38.7€M

72.8€M21.7€M 6.0€M

15.7€M

46.9€M

97.9€M4.1€M 28.9€M

16.6€M

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02.4GEOGRAPHIC CONTRIBUTION

By geographic area

Europe concentrates most of CIE Automotive’s tax contribution (48.9%), in accordance with the Group’s structure and business, as it is the region with the highest sales volume and number of plants.

Out of the 170.7 million euros of 2020 total tax contribution in Europe, Spain is the country that has received the largest share (42.5%), taking into account the three tax jurisdictions in which CIE Automotive is present (Territorio Foral Vasco, Territorio Común Español and Territorio Foral Navarro).

EUROPENorth America represents 24.5% of CIE Automotive’s contribution (85.6 million euros), which reflects the significant presence of CIE Automotive in Mexico (second country in number of employees) and the United States, a key market in the automotive sector and where the Group has made important acquisitions in recent years.

NORTH AMERICAWith 19.3% of the total contribution (67.2 million euros), Asia is in third place, a geographical area that has become increasingly important since the alliance with Mahindra & Mahindra was formalized in 2013 to enter the Indian market, and the consolidation of the presence in China in recent years with the acquisition of CIE Golde in 2019.

ASIAFinally, Brazil accounts for 7.4% (25.8 million euros). In this territory, the multiplicity of taxes and its complex tax structure make tax borne volume very high proportionally to other territories.

BRAZIL

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02.5COUNTRY BY COUNTRY REPORTCIE Automotive Group is made up of about 140 companies that carry out their activity in different areas of the automotive sector, from the design and manufacture of components, to the sale and distribution to manufacturers and TIER-1. These companies are spread over 20 countries and 22 tax jurisdictions.Under the terms established by the OECD, CIE Automotive publishes its Country by Country Report taking into account the Corporate Income Tax accrued and paid in each country, including additionally the rest of parameters contained in said report and thus guarantees its total transparency in tax information to third parties.

Tax jurisdiction

Revenue Third-party

Revenue Related

party

Revenues Total

Pre-tax profit

Corporate Income tax

Paid

Corporate Income tax

Accrued

Capital declared

Retained Earnings

Average number of

employees

Tangible assets

Germany 167 28 195 (15) 2 3 28 (33) 877 95Barbados - - - - - - - (1) - -Brazil 193 12 205 1 1 1 356 296 2,792 137Czechia 78 10 87 3 1 1 48 21 562 64China 443 30 473 63 10 7 42 128 1,628 113Slovakia 171 17 188 10 - (7) 78 (59) 839 45Spain 541 143 684 182 3 16 738 479 2,125 350United States 256 3 259 12 - (2) 189 162 1,592 161France 88 8 96 5 1 (1) 3 57 305 38Guatemala - - - - - - 3 (5) - 1 India 345 7 352 21 1 6 51 272 6,802 202 Italy 75 1 75 1 - (1) 15 (6) 403 77 Lithuania 31 - 31 4 1 - 8 1 180 27 Morocco 7 - 7 - - - 4 - 93 4 Mexico 535 64 599 121 24 20 394 329 5,415 357Netherlands 1 1 2 - - - - 141 4 -Portugal 24 5 29 1 - - 5 7 276 12United Kingdom 1 - 1 - - - 16 (24) 1 -Romania 47 17 63 9 1 2 8 17 512 43Russia 8 - 8 2 - - 2 7 79 11

Total 3,009 345 3,354 421 43 47 1,987 1,790 24,483 1,735

The information included in this table is presented in Form No. 231 of Spanish tax filling.

The data are in million euros except for the number of employees.

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02.6CORPORATE INCOME TAX

In 2020, CIE Automotive Group’s corporate income tax expense amounted to 57.8 million euros, which represents 23.4% of its profit before tax (ETR or effective tax rate).

The Group’s nominal tax rate, resulting from multiplying the taxable income before tax in each jurisdiction by its nominal rate applicable in 2020 is 25.6%.

The reconciliation between the consolidated earnings before tax (EBT) and the consolidated tax base is disclosed in the attached table.

Reconciliation between EBT and consolidated tax base

€M 2020PROFIT BEFORE TAX (*) 247.0

Adjustments to profit before tax and permanent differences (77.1)

Temporary differences 2.8

Consolidated taxable income before application of losses carried-forward 172.7

Application of losses carried-forward (25.2)

Consolidated taxable income 147.5

Current income tax at nominal rate in each country 49.8

Deductions (1.9)

Current Income tax 47.9

Deferred income tax 3.0

Others 6.9

Consolidated income tax expense 57.8

% Effective tax rate 23.4%

*Profit before taxes excluding the share of companies integrated by the equity method

The Corporate Income Tax legislation applicable to CIE Automotive, S.A. as parent company of the Group in 2020 is the one related to Bizkaia Regional Regulation 11/2013 (December 5), modified by the Biscay Regional Regulation 2/2018, March 12.

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2020 CORPORATE INCOME TAX EXPENSE

57.8€M

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31%

30%

29%

28%

27%

26%

25%

24%

23%

22%

21%

20%2018 2019 2020

02.6CORPORATE INCOME TAX

The attached figure compares CIE Automotive’s effective tax rate with its theoretical nominal rate as well as with the average effective rate of the IBEX 35 companies (excluding REITs and companies in losses)(1).

(1) Excluded from the calculation: a) REITs (Real Estate Investment Trust) with a special tax regime where dividend distribution is mandatory, thus transferring the tax to the shareholder; b) Companies in losses but paying taxes where it is not possible to apply a positive effective rate.

(2) CIE Automotive’s 2018 data correspond to recurring results according to financial information published.

28.6%

22.6%(2)

26.4% 26.4%

25.6%

23.4%

22.7%

27.4%

29.2%

CIE NOMINAL RATE

CIE EFFECTIVE RATE

IBEX 35(1)

2020CIE EFFECTIVE RATE

23.4%vs

CIE NOMINAL RATE25.6%

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03. Commitment and compliance

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03.1CORPORATE TAX POLICY AND COMPLIANCE

The main objective of the tax strategy of CIE Automotive is to ensure compliance with the applicable tax regulations in all areas in which the Group operates in line with the activity carried out in each area. This objective is adequately aligned with social interests and sustained value creation for shareholders, avoiding tax risks and inefficiencies when making business decisions at the same time.

The mission of CIE Automotive’s Tax and Compliance Strategy is to manage tax matters in a proactive, transparent and responsible manner with all its stakeholders. Accordingly, not only is the Group compliant with tax legislation but it also minimizes reputational risk and protects its shareholders’ value.

Not setting aside the maximization of economic and social profitability, CIE Automotive promotes and carries out responsible tax performance by considering the interests and sustainable economic development of the communities in which it is integrated, ensuring the proper application of good tax practices and guaranteeing a scrupulous and faithful contribution to the maintenance of public finances.

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CIE Automotive’s tax strategy is governed by six principles:

Ensuring compliance with tax rules in the different countries and territories in which the Group operates, paying the corresponding taxes in accordance with the legal system.

Adopting decisions related to tax matters based on a reasonable interpretation of the applicable legislation and in close connection with the activity of the Group.

Preventing and reducing tax risks, ensuring that taxation is appropriately related to the structure and location of CIE Automotive’s activities, human and material resources and business risks.

Fostering a relationship with authorities in relation to tax matters based on respect for the law, loyalty, trust, professionalism, collaboration, reciprocity and good faith, regardless to legitimate disputes that, respecting the preceding principles and in defense of corporate interest, may arise with the aforementioned authorities in relation to the interpretation of the applicable rules.

Reporting to the Board regarding the main fiscal implications of the transactions or matters submitted for its approval when they are a relevant factor for decision making.

Conceiving taxes the Group companies pay in the countries and areas in which they operate as the main contribution to supporting public expenditure and, therefore, one of CIE Automotive’s contributions to society.

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03.2POLICIES AND TAX RISK MANAGEMENT

Companies are key elements for the development of the communities they are part of. Being aware of this, and consequently, CIE Automotive has established a policy that implies a series of behaviors that go beyond strict compliance with laws and regulations.

CIE Automotive has operated since its beginning assuming a position of active and voluntary contribution to social, economic and environmental development. In this sense, it meets, in the development of its activities, the principles of an orderly and diligent tax policy embodied in the commitment to:

Promote practices that lead to the prevention and reduction of significant tax risks through internal information control systems.

Reduce conflicts arising from the interpretation of the applicable legislation through the use of tools established for such purposes by tax laws.

Adequately assess, in advance, investments and transactions that, a priori, pose a particular fiscal risk.

Avoid using contrived and/or opaque structures for tax purposes, with the understanding that the latter are aimed at preventing the discovery by the competent tax authorities of the party ultimately responsible for the activities or the ultimate owner of the goods or rights involved.

Not to form or acquire companies that are residents in tax havens to elude tax obligations with the sole exception of cases in which it must to do so due to an indirect acquisition in which the company that is a resident of a tax haven is a part of a group of companies acquired.

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Assuming taxation as a dynamic and constantly changing field, CIE Automotive self imposes to keep up to date with such changes and submits its Corporate Tax Policy subject to a continuous review process, with the consecuent incorporation of the best and most demanding practices in matters of transparency and tax conduct.

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Based on a robust tax

management model,

CIE Automotive dedicates the

necessary resources to

guarantee responsible

and efficient tax

performance

03.2POLICIES AND TAX RISK MANAGEMENT

In recent years, CIE Automotive has been building and strengthening its tax risk control framework, in order to respond to the different requirements which have been incorporated in terms of transparency and tax responsibility both by current legislation and by different interest groups.

When making decisions on tax matters, CIE Automotive will always choose to make well-founded interpretations of the regulations and standards, always following the principles stated in the Tax Strategy approved by the Board of Directors and taking into account not only the risk assumed, but also the probability of acceptance of adopted criteria by the Tax Administrations and the corresponding reputational risk.

If there are several tax alternatives for the same objective, the most efficient one from the tax point of view is chosen, always focused on strict compliance and aligned with business activities.

The duty of coordinating the strategies and general guidelines for tax management rests with the Board of Directors, being the responsibility of the President, CEO and Senior Management its communication, implementation and monitoring. The companies that are part of CIE Automotive adopt the needed monitoring mechanisms to ensure, by applying proper business management, compliance with tax regulations, the principles and good practices compiled in the Group’s Tax Policy, dedicating the adequate and sufficiently qualified human and material resources.

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03.3COOPERATION WITH AUTHORITIES

One of the main challenges tax administrations are facing around the world is the lack of comprehensive information on companies’ tax planning strategies. Quick and timely access to this type of information provides the opportunity to respond effectively to eventual tax risks, either through an adequate assessment of said risks, the relevant tax inspections or, where appropriate, by modifying the applicable legislation and/or regulation.

CIE Automotive’s relationships with the competent tax authorities are governed by the principles of transparency, mutual trust, good faith and loyalty. Historically, CIE Automotive has built its industrial activity and growth by cooperating with authorities, by meeting proactively with their representatives on its own initiative in order to inform, consult and request indications regarding the tax practices followed and the tax impacts that its industrial and corporate activities may raise.

In terms of collaboration with authorities, CIE Automotive relies on the following good tax practices:

1. Collaborate in identifying and seeking solutions to fraudulent tax practices that may be used in the markets in

which the Group is present.

2. Facilitate information and documentation with tax relevance that is requested by the competent tax authorities

within the shortest time frame possible and in the most complete manner.

3. Properly inform and discuss with the corresponding body of the competent tax authorities any matters related to significant events

of which it is aware to commence, where applicable, the proceedings in question and to promote, to the extent reasonably possible and without harming good business management, the agreements and conformities within audit proceedings.

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As a new example of this cooperation and transparency commitment, CIE Automotive has acceded to the Code of Good Tax Practices promoted by the AEAT, an action through which it reaffirms the application of the recommendations of the State Tax Administration Agency in terms of mutual collaboration.

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03.4PRESENCE IN TAX HAVENS

The presence in tax havens is increasingly dismissed even if legal industrial activities are carried out in these territories. For this reason, the incorporation of companies in CIE Automotive always follows operating activity criteria. In fact, the Group’s tax policy determines that investments are not made in or through territories classified as low taxation in order to reduce the tax burden.

CIE Automotive is aware that the presence in these non-cooperative territories in tax matters has a reputational impact. For this reason, legal companies are only held in those territories where it is justified by the industrial activity itself and, in the cases of having acquired groups with companies in this type of territory, efforts are made to reduce their presence to what is strictly necessary.

When determining which territories are likely to be perceived as tax havens, low-tax territories or non-cooperative territories, CIE Automotive applies for the definition of tax haven in article 529 ter of the Spanish Companies Act, and the European Union list of non-cooperative countries and territories for tax purposes, first adopted in 2017 and updated twice a year, the latest in February 2021.

At the year-ended 2020, CIE Automotive holds companies located in the Netherlands and Barbados, both territories included in the aforementioned definitions. In both cases, they are non-operating portfolio companies inherited from the roofing business structure acquired in mid-2019 from the American group Inteva and that CIE Automotive plans to liquidate or restructure in the short term.

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THE BUSINESS STRUCTURE OF CIE AUTOMOTIVE IS A FAIR IMAGE OF ITS INDUSTRIAL ACTIVITY AND DOES NOT RESPOND TO TAX ENGINEERING STRUCTURES

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03.5MANAGEMENT OF TAX PROCEDURES AND LITIGATIONS

As a multinational company, CIE Automotive is subject to permanent review by the different tax authorities of the 20 countries in which it operates. Given this global presence, the existence of open procedures in one or more countries is reasonable, considering lawful situations where there might be interpretative divergences between the company and the tax authorities.

The management of all litigation and verification procedures, both in cases of routinely reviews and in those of tax audits of a specific scope, is carried out following the principles of corporate tax policy and under the coordination and supervision of internal

and external advisors in order to support and justify how all tax decisions adopted have been carried out under reasonable and accurate interpretations of the tax regulations.

To the extent that most of tax litigation processes underway in 2020 at CIE Automotive refer to refunds of undue income, where the relevant taxes have already been paid in a timely manner, not sharing the interpretive criteria followed by part of the tax Authorities, its resolution represents a remote risk for CIE Automotive since it does not involve negative effects in the event of loss, either in terms of cash or income.

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03.6INTERNATIONAL TAXATION AND TRANSFER PRICING

CIE Automotive’s business model consists in meeting the needs of its customers wherever they are located, which has resulted in having presence in different countries through alliances, acquisitions and building new plants with the aim of bringing its production centers closer to the assembly plants of vehicle manufacturers.

However, this decentralized operating model represents a reduced level of risk for the purposes of related-party transactions since, due to the nature of its industrial activity, CIE Automotive does not relocate profits or use tax base erosion mechanisms. There are no shared product transformation transactions that could be questioned, centralizing companies, shared functions or services, or cost distributions that follow an exclusively tax purpose.

In general, related-party transactions correspond mainly to corporate services rendered by the parent company of CIE Automotive to its subsidiaries. These services, which encompass a variety of services (management and administration, quality, commercial, financial, information technology, etc.) are invoiced following objective, transparent and consistent criteria with the market value principle.

CIE Automotive values its related-party transactions at their fair market value, faithfully following the transfer pricing guidelines of the OECD and considering the principles of the BEPS Project (Base Erosion and Profit Shifting)

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When invoicing its related-party transactions, CIE Automotive also takes the BEPS principles into account insofar as:

· There is no presence in tax havens or territories not subject to taxation.

· It complies timely and accurately with its tax obligations in all tax territories.

Over the years, CIE Automotive has ensured that the profit from related-party transactions, which have become more and more challenging as the globalization of businesses and markets progress, are in line with the creation of value by adopting the arm’s length principle as the cornerstone when determining transfer prices.

For greater control, transactions with related parties, in accordance with current company regulations, are presented to the Board of Directors, which are previously validated regarding their compliance with transfer pricing regulations. All documentation is carried out according to the foreseen legislative terms and maximum transparency is ensured before the authorities.

03.6INTERNATIONAL TAXATION AND TRANSFER PRICING

· Prudent and reasonable interpretations of tax regulations are performed, not relying on aggressive tax planning mechanisms.

· No abusive use of tax treaties is applied (treaty shopping).

· Hybrid, fraudulent or elusive legal figures are avoided (absence of tax residence, permanent establishments, income reallocation, invoicing from companies without substance or employees, etc.).

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2020

Tax Contribution Report

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CIE Automotive S.A.

Alameda Mazarredo 69, 8º48009 Bilbao (Vizcaya), Spain

Tel.:+34 946 054 835Fax: +34 946 054 837

www.cieautomotive.com