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GRI Training Partner GRI 207 · Tax · Disclosure GRI 207-1

Approach to tax

GRI 207-1 · mandatory · narrative disclosure

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.

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.

Start preparing ↓ Official Global Reporting Initiative source ↗

Disclosure focus

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.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Description of the overall approach to tax

    Tax / Finance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting description of the overall approach to tax.

    Watch for The published response for description of the overall approach to tax is incomplete or does not match the supporting records.

  • Formal tax strategy exists: yes/no

    Tax / Finance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting formal tax strategy exists: yes/no.

    Watch for The published response for formal tax strategy exists: yes/no is incomplete or does not match the supporting records.

  • Public link to tax strategy

    Tax / Finance / Sustainability Reporting

    Required if publicly available. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting public link to tax strategy.

    Watch for The published response for public link to tax strategy is incomplete or does not match the supporting records.

  • Abstract or summary of private strategy

    Sustainability Reporting / data owner

    Recommended by GRI. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting abstract or summary of private strategy.

    Watch for The published response for abstract or summary of private strategy is incomplete or does not match the supporting records.

  • Governance body or executive-level approver

    People / Compliance / Sustainability Reporting

    Required where strategy exists. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting governance body or executive-level approver.

    Watch for The published response for governance body or executive-level approver is incomplete or does not match the supporting records.

  • Formal review frequency

    Sustainability Reporting / data owner

    Required where strategy exists. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting formal review frequency.

    Watch for The published response for formal review frequency is incomplete or does not match the supporting records.

  • Actual most recent review

    Sustainability Reporting / data owner

    Necessary assurance information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting actual most recent review.

    Watch for The published response for actual most recent review is incomplete or does not match the supporting records.

  • Approach to regulatory compliance

    Sustainability Reporting / data owner

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting approach to regulatory compliance.

    Watch for The published response for approach to regulatory compliance is incomplete or does not match the supporting records.

  • Letter and spirit of the law

    Sustainability Reporting / data owner

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting letter and spirit of the law.

    Watch for The published response for letter and spirit of the law is incomplete or does not match the supporting records.

  • Link to business strategy

    Sustainability Reporting / data owner

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting link to business strategy.

    Watch for The published response for link to business strategy is incomplete or does not match the supporting records.

  • Link to sustainable development strategy

    Sustainability Reporting / data owner

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting link to sustainable development strategy.

    Watch for The published response for link to sustainable development strategy is incomplete or does not match the supporting records.

  • Economic and social impacts considered

    Sustainability Reporting / data owner

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting economic and social impacts considered.

    Watch for The published response for economic and social impacts considered is incomplete or does not match the supporting records.

  • Sustainable-development commitments by jurisdiction

    Sustainability Reporting / data owner

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting sustainable-development commitments by jurisdiction.

    Watch for The published response for sustainable-development commitments by jurisdiction is incomplete or does not match the supporting records.

  • Tax planning approach

    Tax / Finance / Sustainability Reporting

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting tax planning approach.

    Watch for The published response for tax planning approach is incomplete or does not match the supporting records.

  • Tax risk appetite

    Tax / Finance / Sustainability Reporting

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting tax risk appetite.

    Watch for The published response for tax risk appetite is incomplete or does not match the supporting records.

  • Acceptable tax practices

    Tax / Finance / Sustainability Reporting

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting acceptable tax practices.

    Watch for The published response for acceptable tax practices is incomplete or does not match the supporting records.

  • Unacceptable tax practices

    Tax / Finance / Sustainability Reporting

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting unacceptable tax practices.

    Watch for The published response for unacceptable tax practices is incomplete or does not match the supporting records.

  • Use or non-use of tax havens

    Tax / Finance / Sustainability Reporting

    Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting use or non-use of tax havens.

    Watch for The published response for use or non-use of tax havens is incomplete or does not match the supporting records.

  • Tax incentives approach

    Tax / Finance / Sustainability Reporting

    Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting tax incentives approach.

    Watch for The published response for tax incentives approach is incomplete or does not match the supporting records.

  • Transfer pricing approach

    Sustainability Reporting / data owner

    Illustrative GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting transfer pricing approach.

    Watch for The published response for transfer pricing approach is incomplete or does not match the supporting records.

  • Engagement with tax authorities

    Tax / Finance / Sustainability Reporting

    Contextual GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting engagement with tax authorities.

    Watch for The published response for engagement with tax authorities is incomplete or does not match the supporting records.

  • Entities and jurisdictions covered by strategy

    Sustainability Reporting / data owner

    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.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting entities and jurisdictions covered by strategy.

    Watch for The published response for entities and jurisdictions covered by strategy is incomplete or does not match the supporting records.

  • Differences between group and local strategies

    Procurement / Finance / Sustainability Reporting

    GRI guidance. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting differences between group and local strategies.

    Watch for The published response for differences between group and local strategies is incomplete or does not match the supporting records.

  • Link to GRI 3-3

    Sustainability Reporting / data owner

    Required contextual control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting link to gri 3-3.

    Watch for The published response for link to gri 3-3 is incomplete or does not match the supporting records.

  • Link to GRI 207-2

    Sustainability Reporting / data owner

    Necessary to prevent duplication. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting link to gri 207-2.

    Watch for The published response for link to gri 207-2 is incomplete or does not match the supporting records.

  • Reason for omission

    Sustainability Reporting / data owner

    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.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting reason for omission.

    Watch for The published response for reason for omission is incomplete or does not match the supporting records.

Before you start

  • 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.
  • 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.
  • Have the supporting records and the final response been reconciled?
＋ Show GRI 207-1 sub-elements (LRA working checklist)

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

Download preparation tools for GRI 207-1 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Check

For each claim, check the evidence

  • Description of the overall approach to tax is reported accurately and completely.

    Risk The response omits, misclassifies or overstates description of the overall approach to tax.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates formal tax strategy exists: yes/no.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates public link to tax strategy.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates abstract or summary of private strategy.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates governance body or executive-level approver.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting governance body or executive-level approver.

  • Formal review frequency is reported accurately and completely.

    Risk The response omits, misclassifies or overstates formal review frequency.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting formal review frequency.

  • Actual most recent review is reported accurately and completely.

    Risk The response omits, misclassifies or overstates actual most recent review.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting actual most recent review.

  • Approach to regulatory compliance is reported accurately and completely.

    Risk The response omits, misclassifies or overstates approach to regulatory compliance.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates letter and spirit of the law.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates link to business strategy.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting link to business strategy.

  • Link to sustainable development strategy is reported accurately and completely.

    Risk The response omits, misclassifies or overstates link to sustainable development strategy.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates economic and social impacts considered.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates sustainable-development commitments by jurisdiction.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting sustainable-development commitments by jurisdiction.

  • Tax planning approach is reported accurately and completely.

    Risk The response omits, misclassifies or overstates tax planning approach.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting tax planning approach.

  • Tax risk appetite is reported accurately and completely.

    Risk The response omits, misclassifies or overstates tax risk appetite.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting tax risk appetite.

  • Acceptable tax practices is reported accurately and completely.

    Risk The response omits, misclassifies or overstates acceptable tax practices.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting acceptable tax practices.

  • Unacceptable tax practices is reported accurately and completely.

    Risk The response omits, misclassifies or overstates unacceptable tax practices.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates use or non-use of tax havens.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates tax incentives approach.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting tax incentives approach.

  • Transfer pricing approach is reported accurately and completely.

    Risk The response omits, misclassifies or overstates transfer pricing approach.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting transfer pricing approach.

  • Engagement with tax authorities is reported accurately and completely.

    Risk The response omits, misclassifies or overstates engagement with tax authorities.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates entities and jurisdictions covered by strategy.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates differences between group and local strategies.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates link to gri 3-3.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates link to gri 207-2.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting link to gri 207-2.

  • Reason for omission is reported accurately and completely.

    Risk The response omits, misclassifies or overstates reason for omission.

    Evidence to check 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

GRI

GRI 207-1

within GRI 207: Tax

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