Tax Governance Framework

Integrity, responsible behavior and performance are the foundation of our bank's actions as a value system. Commerzbank AG and all its Group companies (“Commerzbank Group”) are committed to acting in full compliance with the applicable legal and supervisory tax obligations in all jurisdictions and markets in which they operate.

Commerzbank AG Singapore Branch (“CBSG”) operates within the Commerzbank Group’s tax strategy and is committed to complying with all applicable tax obligations in Singapore. We follow a clear zero-tolerance approach to tax offences, including but not limited to illegal and unethical practices. This applies not only to our own tax matters, but to the affairs of customers, employees and business partners.

We are committed in the responsible management of our tax affairs, including a cooperative, transparent and compliant approach to Singapore tax law and regulations. Our approach is laid out in our CBSG Tax Governance Framework as follows:

Compliance with Tax Laws

CBSG is committed and endeavours to comply with all relevant tax laws, regulations, published guidelines and tax treaties across each jurisdiction where we operate. We keep ourselves abreast of the latest developments in tax laws through a combination of formal and informal channels. A formal regulatory screening process is enforced by our Local Regulatory Advisory Board (LRAB) which meets on at least a quarterly basis. All relevant updates to tax laws are duly documented in our RegTrack system, including the steps implemented to ensure strict compliance with these laws.

We support the exchange of information regimes such as the United States' Foreign Account Tax Compliance Act (FATCA) and the Organization for Economic Cooperation and Development's Common Reporting Standard (CRS).

We carry out cross-border intra-group transactions at arm’s length in accordance with the OECD Transfer Pricing Guidelines and we are committed to complying with BEPS Action.

We do not undertake aggressive tax planning other than to support genuine commercial and economic business activities.

We have a zero-tolerance approach towards tax evasion and the facilitation of tax evasion. To this extent, all staff in CBSG undergo an internal online training at least annually to ensure that they are fully aware of their personal responsibilities in preventing the facilitation of tax evasion.

Governance Structure for Managing Tax Risks

CBSG has formalised a governance structure for tax risk management where the roles and responsibilities are clearly defined. The Chief Executive Officer and the Chief Operating Officer, together with the Finance Team, are responsible for overseeing CBSG’s tax affairs. The Finance Team, comprising of our Financial Reporting team, local tax specialist and local Chief Financial Officer, is well supported by an externally appointed tax agent in all areas of tax compliance. All tax risk management topics are pre-aligned with our Head Office through the Regional Chief Financial Officer, with a review of our key tax risks being performed at least annually.

We are committed to ensuring that we pay all taxes due and that all relevant tax returns are completed accurately, reliably and on time. Processes and controls are central to ensuring compliance, and we take care in ensuring that robust processes, a sound system of risk management and strong internal controls are in place to identify, assess and manage tax risks. Regulatory and tax law changes are reviewed and taken into account in an established regulatory screening process as described above. Our procedures are reviewed and updated at least annually to comply with relevant updates to regulations and laws.

We employ competent tax professionals who are equipped with tax knowledge and skills in ensuring tax compliance. We also strive to enhance our awareness of tax compliance through training and industry networking opportunities for our employees.

Any significant tax issues identified exceeding the reporting threshold will be reported to the Singapore Management team as well as to our Head Office through our Regional Chief Financial Officer.

Relationship with Tax Authorities including IRAS

CBSG seeks to maintain an open and cooperative relationship with all Tax Authorities including IRAS, and endeavours to disclose our tax-related information in a fair, timely and appropriate manner.

We are committed to performing regular reviews and self-assessment programs of our tax filing positions to ensure accuracy and timely disclosure to IRAS.

We have a low appetite towards the acceptance of tax risk. Where uncertainties in the tax treatment of our transactions are identified, advice is sought from qualified external tax advisors, and where appropriate, we will seek clarification or rulings from IRAS on material transactions.