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Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
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GRI 207: Tax·Disclosure GRI 207-1
Approach to tax
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official Global Reporting Initiative source.
Legal status
GRI 207: Tax 2019 remains the applicable GRI Topic Standard for tax reporting and is effective for reporting on or after 1 January 2021.
Published passport
Last reviewed 2026-08-01
Reviewed by
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
LRA educational guidance · Not issued or endorsed by Global Reporting Initiative
Standard
GRI 207: Tax
Disclosure GRI 207-1 · 2019
Last reviewed
2026-08-01
LRA educational guidance · Not issued or endorsed by Global Reporting Initiative
To prepare this disclosure
Disclosure focus
Disclosure 207-1 requires an organization to describe its approach to tax. The description includes whether the organization has a tax strategy and, if so, a link where the strategy is publicly available; the governance body or executive-level position that formally reviews and approves the strategy and the frequency of that review; the organization’s approach to regulatory compliance; and how its approach to tax is linked to its business and sustainable development strategies.
An organization is not required to have a formal tax strategy. If no strategy exists, it reports this and describes its actual approach to tax through any relevant policies, standards, principles, practices or codes of conduct. If a strategy exists but is not publicly available, the organization can provide an abstract or summary.
The approach to tax can include the organization’s tax principles, its attitude to tax planning, the level of tax risk it is willing to accept and its approach to engaging with tax authorities. Relevant examples can include the use or non-use of tax havens, the types of tax incentives used, the approach to transfer pricing and tax practices considered acceptable or unacceptable.
When describing regulatory compliance, the organization can explain whether it seeks to comply with both the letter and the spirit of tax law. When explaining the link to sustainable development, it can describe whether the economic and social impacts of its tax approach were considered and how the approach aligns with commitments in the jurisdictions where it operates.
If the tax strategy applies to fewer entities or tax jurisdictions than those reported under Disclosure 207-4, the organization should identify its actual scope. Relevant differences between group-wide and jurisdiction-specific tax strategies should also be explained.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official Global Reporting Initiative source.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Description of the overall approach to tax | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting description of the overall approach to tax. | Tax / Finance / Sustainability Reporting |
| Formal tax strategy exists: yes/no | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting formal tax strategy exists: yes/no. | Tax / Finance / Sustainability Reporting |
| Public link to tax strategy | Required if publicly available. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting public link to tax strategy. | Tax / Finance / Sustainability Reporting |
| Abstract or summary of private strategy | Recommended by GRI. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting abstract or summary of private strategy. | Sustainability Reporting / data owner |
| Governance body or executive-level approver | Required where strategy exists. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting governance body or executive-level approver. | People / Compliance / Sustainability Reporting |
| Formal review frequency | Required where strategy exists. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting formal review frequency. | Sustainability Reporting / data owner |
| Actual most recent review | Necessary assurance information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting actual most recent review. | Sustainability Reporting / data owner |
| Approach to regulatory compliance | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting approach to regulatory compliance. | Sustainability Reporting / data owner |
| Letter and spirit of the law | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting letter and spirit of the law. | Sustainability Reporting / data owner |
| Link to business strategy | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting link to business strategy. | Sustainability Reporting / data owner |
| Link to sustainable development strategy | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting link to sustainable development strategy. | Sustainability Reporting / data owner |
| Economic and social impacts considered | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting economic and social impacts considered. | Sustainability Reporting / data owner |
| Sustainable-development commitments by jurisdiction | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting sustainable-development commitments by jurisdiction. | Sustainability Reporting / data owner |
| Tax planning approach | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting tax planning approach. | Tax / Finance / Sustainability Reporting |
| Tax risk appetite | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting tax risk appetite. | Tax / Finance / Sustainability Reporting |
| Acceptable tax practices | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting acceptable tax practices. | Tax / Finance / Sustainability Reporting |
| Unacceptable tax practices | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting unacceptable tax practices. | Tax / Finance / Sustainability Reporting |
| Use or non-use of tax havens | Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting use or non-use of tax havens. | Tax / Finance / Sustainability Reporting |
| Tax incentives approach | Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting tax incentives approach. | Tax / Finance / Sustainability Reporting |
| Transfer pricing approach | Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting transfer pricing approach. | Sustainability Reporting / data owner |
| Engagement with tax authorities | Contextual GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting engagement with tax authorities. | Tax / Finance / Sustainability Reporting |
| Entities and jurisdictions covered by strategy | Required contextual information where scope is limited. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting entities and jurisdictions covered by strategy. | Sustainability Reporting / data owner |
| Differences between group and local strategies | GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting differences between group and local strategies. | Procurement / Finance / Sustainability Reporting |
| Link to GRI 3-3 | Required contextual control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting link to gri 3-3. | Sustainability Reporting / data owner |
| Link to GRI 207-2 | Necessary to prevent duplication. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting link to gri 207-2. | Sustainability Reporting / data owner |
| Reason for omission | Required in GRI content index where applicable. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting reason for omission. | Sustainability Reporting / data owner |
＋ Show GRI 207-1 sub-elements (LRA working checklist)
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required if publicly available. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Recommended by GRI. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required where strategy exists. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required where strategy exists. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Necessary assurance information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Contextual GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required contextual information where scope is limited. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required contextual control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Necessary to prevent duplication. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required in GRI content index where applicable. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
How to prepare it
Disclosure 207-1 requires an organization to describe its approach to tax. The description includes whether the organization has a tax strategy and, if so, a link where the strategy is publicly available; the governance body or executive-level position that formally reviews and approves the strategy and the frequency of that review; the organization’s approach to regulatory compliance; and how its approach to tax is linked to its business and sustainable development strategies.
Collect and reconcile the records for: Description of the overall approach to tax; Formal tax strategy exists: yes/no; Public link to tax strategy; Abstract or summary of private strategy; Governance body or executive-level approver; Formal review frequency; Actual most recent review; Approach to regulatory compliance; Letter and spirit of the law; Link to business strategy; Link to sustainable development strategy; Economic and social impacts considered; Sustainable-development commitments by jurisdiction; Tax planning approach; Tax risk appetite; Acceptable tax practices; Unacceptable tax practices; Use or non-use of tax havens; Tax incentives approach; Transfer pricing approach; Engagement with tax authorities; Entities and jurisdictions covered by strategy; Differences between group and local strategies; Link to GRI 3-3; Link to GRI 207-2; Reason for omission.
Apply Disclosure 207-1 when the related topic is material and this disclosure is relevant to the organisation's impacts, or when an applicable GRI Sector Standard identifies it for reporting.
Draft the response using the defined terms shown in the disclosure focus; do not substitute broader internal labels.
Review the final wording against every requirement and the supporting governance or data records before sign-off.
Request the data
Request the disclosure evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Provide the reporting-period records and reconciliations for Disclosure 207-1: Description of the overall approach to tax; Formal tax strategy exists: yes/no; Public link to tax strategy; Abstract or summary of private strategy; Governance body or executive-level approver; Formal review frequency; Actual most recent review; Approach to regulatory compliance; Letter and spirit of the law; Link to business strategy; Link to sustainable development strategy; Economic and social impacts considered; Sustainable-development commitments by jurisdiction; Tax planning approach; Tax risk appetite; Acceptable tax practices; Unacceptable tax practices; Use or non-use of tax havens; Tax incentives approach; Transfer pricing approach; Engagement with tax authorities; Entities and jurisdictions covered by strategy; Differences between group and local strategies; Link to GRI 3-3; Link to GRI 207-2; Reason for omission. Include scope, definitions, methods, assumptions, limitations, owners and approvals.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
Provide the reporting-period records and reconciliations for Disclosure 207-1: Description of the overall approach to tax; Formal tax strategy exists: yes/no; Public link to tax strategy; Abstract or summary of private strategy; Governance body or executive-level approver; Formal review frequency; Actual most recent review; Approach to regulatory compliance; Letter and spirit of the law; Link to business strategy; Link to sustainable development strategy; Economic and social impacts considered; Sustainable-development commitments by jurisdiction; Tax planning approach; Tax risk appetite; Acceptable tax practices; Unacceptable tax practices; Use or non-use of tax havens; Tax incentives approach; Transfer pricing approach; Engagement with tax authorities; Entities and jurisdictions covered by strategy; Differences between group and local strategies; Link to GRI 3-3; Link to GRI 207-2; Reason for omission. Include scope, definitions, methods, assumptions, limitations, owners and approvals.
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
If the tax strategy applies to fewer entities or tax jurisdictions than those reported under Disclosure 207-4, the organization should identify its actual scope. Relevant differences between group-wide and jurisdiction-specific tax strategies should also be explained.
Context note
Keep mandatory Requirements, GRI recommendations and additional LRA preparation controls clearly distinguished. Use a GRI 1 reason for omission where an applicable requirement cannot be reported.
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 207-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI Assistant.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| Description of the overall approach to tax is reported accurately and completely. | The response omits, misclassifies or overstates description of the overall approach to tax. | Approved source records, calculation files, reconciliations and review evidence supporting description of the overall approach to tax. |
| Formal tax strategy exists: yes/no is reported accurately and completely. | The response omits, misclassifies or overstates formal tax strategy exists: yes/no. | Approved source records, calculation files, reconciliations and review evidence supporting formal tax strategy exists: yes/no. |
| Public link to tax strategy is reported accurately and completely. | The response omits, misclassifies or overstates public link to tax strategy. | Approved source records, calculation files, reconciliations and review evidence supporting public link to tax strategy. |
| Abstract or summary of private strategy is reported accurately and completely. | The response omits, misclassifies or overstates abstract or summary of private strategy. | Approved source records, calculation files, reconciliations and review evidence supporting abstract or summary of private strategy. |
| Governance body or executive-level approver is reported accurately and completely. | The response omits, misclassifies or overstates governance body or executive-level approver. | Approved source records, calculation files, reconciliations and review evidence supporting governance body or executive-level approver. |
| Formal review frequency is reported accurately and completely. | The response omits, misclassifies or overstates formal review frequency. | Approved source records, calculation files, reconciliations and review evidence supporting formal review frequency. |
| Actual most recent review is reported accurately and completely. | The response omits, misclassifies or overstates actual most recent review. | Approved source records, calculation files, reconciliations and review evidence supporting actual most recent review. |
| Approach to regulatory compliance is reported accurately and completely. | The response omits, misclassifies or overstates approach to regulatory compliance. | Approved source records, calculation files, reconciliations and review evidence supporting approach to regulatory compliance. |
| Letter and spirit of the law is reported accurately and completely. | The response omits, misclassifies or overstates letter and spirit of the law. | Approved source records, calculation files, reconciliations and review evidence supporting letter and spirit of the law. |
| Link to business strategy is reported accurately and completely. | The response omits, misclassifies or overstates link to business strategy. | Approved source records, calculation files, reconciliations and review evidence supporting link to business strategy. |
| Link to sustainable development strategy is reported accurately and completely. | The response omits, misclassifies or overstates link to sustainable development strategy. | Approved source records, calculation files, reconciliations and review evidence supporting link to sustainable development strategy. |
| Economic and social impacts considered is reported accurately and completely. | The response omits, misclassifies or overstates economic and social impacts considered. | Approved source records, calculation files, reconciliations and review evidence supporting economic and social impacts considered. |
| Sustainable-development commitments by jurisdiction is reported accurately and completely. | The response omits, misclassifies or overstates sustainable-development commitments by jurisdiction. | Approved source records, calculation files, reconciliations and review evidence supporting sustainable-development commitments by jurisdiction. |
| Tax planning approach is reported accurately and completely. | The response omits, misclassifies or overstates tax planning approach. | Approved source records, calculation files, reconciliations and review evidence supporting tax planning approach. |
| Tax risk appetite is reported accurately and completely. | The response omits, misclassifies or overstates tax risk appetite. | Approved source records, calculation files, reconciliations and review evidence supporting tax risk appetite. |
| Acceptable tax practices is reported accurately and completely. | The response omits, misclassifies or overstates acceptable tax practices. | Approved source records, calculation files, reconciliations and review evidence supporting acceptable tax practices. |
| Unacceptable tax practices is reported accurately and completely. | The response omits, misclassifies or overstates unacceptable tax practices. | Approved source records, calculation files, reconciliations and review evidence supporting unacceptable tax practices. |
| Use or non-use of tax havens is reported accurately and completely. | The response omits, misclassifies or overstates use or non-use of tax havens. | Approved source records, calculation files, reconciliations and review evidence supporting use or non-use of tax havens. |
| Tax incentives approach is reported accurately and completely. | The response omits, misclassifies or overstates tax incentives approach. | Approved source records, calculation files, reconciliations and review evidence supporting tax incentives approach. |
| Transfer pricing approach is reported accurately and completely. | The response omits, misclassifies or overstates transfer pricing approach. | Approved source records, calculation files, reconciliations and review evidence supporting transfer pricing approach. |
| Engagement with tax authorities is reported accurately and completely. | The response omits, misclassifies or overstates engagement with tax authorities. | Approved source records, calculation files, reconciliations and review evidence supporting engagement with tax authorities. |
| Entities and jurisdictions covered by strategy is reported accurately and completely. | The response omits, misclassifies or overstates entities and jurisdictions covered by strategy. | Approved source records, calculation files, reconciliations and review evidence supporting entities and jurisdictions covered by strategy. |
| Differences between group and local strategies is reported accurately and completely. | The response omits, misclassifies or overstates differences between group and local strategies. | Approved source records, calculation files, reconciliations and review evidence supporting differences between group and local strategies. |
| Link to GRI 3-3 is reported accurately and completely. | The response omits, misclassifies or overstates link to gri 3-3. | Approved source records, calculation files, reconciliations and review evidence supporting link to gri 3-3. |
| Link to GRI 207-2 is reported accurately and completely. | The response omits, misclassifies or overstates link to gri 207-2. | Approved source records, calculation files, reconciliations and review evidence supporting link to gri 207-2. |
| Reason for omission is reported accurately and completely. | The response omits, misclassifies or overstates reason for omission. | Approved source records, calculation files, reconciliations and review evidence supporting reason for omission. |
Evidence pack to prepare
Common reporting gaps
Assuming that every organisation has a formal or public tax strategy.
Failing to explain how the tax approach links to business and sustainable development strategies.
Using internal labels in place of the defined GRI terms.
Leaving a required preparation field unsupported by traceable evidence.
Treating GRI recommendations as mandatory requirements or mandatory requirements as optional.
Publishing estimates, exclusions or partial scope without methods, assumptions and the applicable reason for omission.
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Framework references
Relevant GRI requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
GRI
GRI 207-1
within GRI 207: Tax
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