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GRI 207: Tax · 2019
Disclosure GRI 207-1

Approach to tax

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain its overall approach to tax: how it manages tax matters, the principles or policies it follows, and how that approach is embedded in decision-making. The emphasis is on the organisation’s tax governance and operating approach, rather than on giving a detailed tax calculation or a list of every tax paid.

In practice, the focus is usually on whether the approach applies across the whole organisation and its relevant entities, not just at a few headline sites or flagship operations. A useful explanation will show how tax is handled consistently, who is responsible, and how the organisation makes sure its approach is applied in day-to-day operations and across different jurisdictions where it operates.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Tax approach summary A plain-language summary of how the organisation manages tax matters in practice, covering the main principles or stance it follows. Tax policy, tax governance paper, board-approved tax framework, or internal tax position note. Tax / Finance
Tax strategy exists A yes/no confirmation of whether the organisation has a formal tax strategy in place. Board paper, policy register, governance tracker, or published tax strategy document. Tax / Finance
Public strategy link The web address or document link for the tax strategy, if the organisation has made it public. Published website page, annual report link, or external document repository entry. Tax / Communications
Strategy approver The board, committee, or senior executive role that formally signs off the tax strategy. Board minutes, committee terms of reference, approval memo, or delegated authority schedule. Tax / Company Secretariat
Review cycle How often the tax strategy is formally checked and refreshed, such as annually or on another set cycle. Policy review calendar, governance timetable, board paper, or control schedule. Tax / Finance
Compliance approach A plain-language summary of how the organisation handles legal and regulatory tax compliance in day-to-day practice. Tax compliance policy, control framework, risk register, or internal compliance procedures. Tax / Compliance
Strategy alignment A description of how the tax approach supports the organisation’s wider business plan and its sustainability objectives. Strategy deck, sustainability plan, tax policy, or integrated reporting narrative. Tax / Strategy
+ Show GRI 207-1 sub-elements (LRA working checklist)

How to prepare it

1Start by deciding whether the organisation has a tax policy or strategy, and gather the source material that shows it exists. If it is published, keep the live link or document reference ready for the disclosure file.
2Identify who in the organisation formally signs off on that tax approach. Record the relevant board-level group or senior executive role, and note how often that review happens.
3Write a plain summary of how the organisation handles tax in practice. Keep it focused on the approach itself, and separate it from broader commentary or unrelated tax topics.
4Set out how the organisation manages compliance with tax rules and filing obligations. Use evidence from internal policies, controls, or process notes that support the description you give.
5Explain how the tax approach connects with the organisation’s wider business direction and its sustainability priorities. Make sure the link is specific enough to show how the two are aligned.
6Before finalising, check every item against the source documents and confirm nothing material is missing or misstated. If you have left anything out or changed wording from the source, document that clearly and correct it where needed.
Request the data

Request the tax policy pack from Finance / Tax

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

How does the organisation set, approve, review and explain its tax approach, and how is that approach connected to the wider business plan and sustainability priorities?

Use your organisation’s own labels first, then map them to the reporting wording. For example, if you call this a tax policy, tax principles note, or tax governance paper internally, use that term in the request and in the evidence pack. Keep the ask in business language, not framework language, and check the source material before sign-off.

Weak request

Please provide the GRI 207-1 tax strategy evidence and confirm governance review, compliance approach, and linkage to sustainable development.

Why it fails: This uses framework wording that many internal owners will not use day to day, so it is easy to misunderstand or answer only partially. It also does not point the owner to the actual document types, approval trail, review timing, or where the evidence sits.

Better request

Please send the current tax policy or equivalent note for [period], the approval record showing who signed it off, how often it is refreshed, whether it is public, and a short explanation of how it supports the wider business plan and sustainability priorities. If your team uses different labels, use those and add a quick mapping note.

Formal email template
Subject: Request for the tax policy pack and supporting evidence

Hi [Name],

I’m pulling together the reporting pack for [period]. Could you please share the current tax policy or equivalent internal document, plus any supporting material that shows:
- whether the organisation has a formal tax policy or similar position paper;
- where that document is published, if it is public;
- who reviews and signs it off at executive or board level;
- how often it is reviewed;
- how the organisation manages tax compliance in practice; and
- how the tax approach links to the wider business plan and sustainability priorities.

Please include the latest approved version, the approval record or board paper, and any short note that explains the link to strategy. If the wording differs from the terms above, please use your internal terminology and add a brief mapping note.

A possible LRA training template only — please adapt this to your organisation and check the source material before sign-off.

Thanks,
[Your name]
Short Teams / Slack version
Hi [Name] — could you send over the latest tax policy / position note for [period], plus the approval record, review frequency, any public link, and a short note on how it connects to the business plan and sustainability priorities? Please use your internal terms if they differ. Thanks.
Industry examples
Manufacturing

Context. A group tax team holds the policy in a policy library and the board approval in a committee paper archive.

Adapted request. Please share the current tax policy note for [period], the latest committee or board approval paper, the review cycle, any public link, and a short summary of how the tax position supports operational resilience, investment plans, and sustainability goals.

Example response. Policy title: Group Tax Principles; Owner: Head of Tax; Approved by: Audit Committee; Review cycle: Annual; Public link: Annual report section; Compliance note: Central oversight of filings and external advice; Business link: Supports capital allocation, supply chain stability, and responsible growth.

Retail

Context. The finance team keeps a short tax governance memo and the public statement sits on the corporate website.

Adapted request. Please provide the current tax governance memo or equivalent, the sign-off record, how often it is reviewed, the website link if published, and a brief note on how the tax approach fits with trading strategy and responsible business commitments.

Example response. Document title: Tax Governance Statement; Owner: Finance Director; Approved by: CFO; Review cycle: Every two years and on material change; Public link: Company website; Compliance note: Filing calendar, controls, and escalation routes; Business link: Supports store expansion, cash management, and responsible business commitments.

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

Describe the basis used to prepare the disclosure, including how the organisation defines its tax approach, what it treats as its tax strategy, who is counted as the approving decision-maker, and how it determines the review frequency.

Context note

Explain what the figures and descriptions show about how tax is managed in practice, including whether there is a formal strategy, how oversight is organised, how often it is refreshed, and how tax is aligned with the wider business and sustainability agenda.

Fluctuation statement

If the approach, approval route, review timing, or public link has changed since the prior period, note the reason for the change and whether it reflects a shift in governance, compliance focus, or business strategy.

Content index entry
GRI 207-1 Approach to tax — [location / page] / [notes]
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Preparation tools & forms

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We have a documented tax policy or equivalent statement, and we can show the version we used for the reporting period.The assurer may question whether the organisation is relying on an actual approved policy rather than an informal summary or draft.Approved policy document, version history, publication date, internal sign-off record, and any board or committee paper that confirms adoption.
Where we say a public link is available, we can point to the live source and show it matches the version we relied on.The assurer may test whether the link works, whether it is current, and whether the published text is the same as the one used for the disclosure.Working URL, archived copy or screenshot, publication date, and a comparison between the public text and the internal source used for reporting.
The tax policy was reviewed and approved by the named senior decision-maker or governing group we refer to in the report.The assurer may probe whether the named reviewer really had authority and whether approval was properly recorded.Committee or board minutes, approval memo, delegated authority matrix, and any paper showing who reviewed and signed off the policy.
We can show how often the policy is revisited, and that the stated cycle is the one actually followed.The assurer may challenge whether the review frequency is real, current, and consistently applied.Policy review timetable, calendar invites, meeting minutes, change log, and evidence of the most recent completed review.
Our description of compliance is based on the controls and processes we actually use to meet tax obligations.The assurer may look for gaps between the narrative and the operating reality, including weak controls or unsupported claims about compliance.Tax compliance procedures, control testing results, filing calendars, reconciliations, internal audit reports, and evidence of monitoring or escalation.
We have explained the link between tax matters and the wider business direction using internal strategy material and approved reporting inputs.The assurer may test whether the connection is genuine, current, and supported by strategy documents rather than added after the fact.Business strategy papers, sustainability strategy documents, cross-references in management reporting, and sign-off showing the linkage was reviewed before publication.

Evidence pack to prepare

Common reporting gaps

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps

Mistakes to avoid when collecting the data

Asked the tax team only
The request goes to tax specialists alone, so the answer misses how finance, legal, governance and strategy owners actually describe the organisation’s tax approach.
Used framework language in the ask
The data call is written in reporting jargon, which makes internal owners search for the wrong documents instead of answering in the organisation’s own terms.
No clear boundary for what counts
Teams collect material from some entities or functions but not others because nobody defined which parts of the group, business lines or jurisdictions belong in scope.
Mixed different reporting periods
One source is pulled from the current year while another reflects a different review cycle, so the final pack combines timings that do not match.
Switched counting bases mid-stream
Some inputs are captured as yes/no answers while others are gathered as narrative or dated records, and the team later treats them as if they were the same kind of evidence.
Lost the original source labels
When files are copied into a working sheet, the team drops the document names, version marks or owner tags that show where each fact came from.
Merged separate populations too early
Information about the board, a committee and an executive reviewer is blended into one line, even though each group should be tracked separately for the draft.
Collected evidence without metadata
The pack contains statements but not the supporting dates, authors, approval references or links needed to show what each item was based on.
No sign-off trail before drafting
The team starts writing the disclosure before anyone has confirmed the source pack, so there is no record of who checked the facts and when.

Where judgement is often needed

What counts as the group’s tax policy after a deal closes
If a purchase or sale changes the businesses in scope, explain whether the write-up covers the new group as at the reporting date or only the businesses that were already in place for the full period, and note any cut-off used.
When local rules use different labels for the same tax topic
Where countries use different legal terms or filing concepts, describe the common business meaning you have used so readers can see how the group’s tax approach is applied across jurisdictions.
How to treat joint ventures, associates, and other partly controlled interests
State whether these interests are included, excluded, or described separately in the tax approach narrative, and explain the basis for that choice if the treatment is not the same everywhere.
Whether the policy description is based on policy in force now or during the year
Make clear if the account reflects the current tax policy, the policy that operated during the reporting period, or both, and explain any timing difference between approval, update, and publication.
Using estimates where the underlying record is incomplete
If some parts of the description rely on judgement or proxy information rather than direct records, say where estimates were used, why they were needed, and how they were checked.
How much detail to give when the public version could expose sensitive information
If the full internal wording cannot be shared, provide a higher-level summary that still explains the approach, and say that more detailed material is withheld for confidentiality reasons.
Choosing the level of rounding or grouping in the narrative
If figures, dates, or review intervals are rounded or grouped for readability, state the convention used and keep it consistent so the reader can compare items without confusion.
Deciding which governance role to name when approval sits with more than one person or forum
If sign-off is shared between a board-level group and an executive role, identify the body or role that formally approves the tax policy and explain any split in oversight or review.
Explaining the link to wider business and sustainability plans when the connection is indirect
Where the tax approach supports the business model or wider sustainability aims only through several steps, describe the chain plainly and avoid overstating the strength of the link.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Consumer goods manufacturing

*Synthetic illustration only.* We keep a written tax policy that sets out how we manage tax risk, meet filing duties and align tax decisions with our wider business plan and sustainability priorities. The board’s audit and risk committee signs off the policy, and we refresh it once a year; the policy is available on our website at a public link. Our compliance process covers registration, returns, payments and controls across the group, with oversight from the finance director and regular reporting to the board.

This example shows how a reporter can describe its tax approach in plain language, state whether a formal policy exists, identify where it is published, and explain who approves it and how often it is reviewed. It also links tax management to business direction and sustainability goals, while summarising the compliance process without using the standard’s wording.

Illustrative (synthetic) example — Transport and logistics

*Synthetic illustration only.* Our group uses a documented tax framework to guide decisions on tax planning, risk, and day-to-day compliance across the countries where we operate. The group chief financial officer approves the framework after review by the board’s finance committee, and we revisit it every two years; a public version is posted on our corporate website. We connect this approach to our growth plan and responsible business commitments by aiming for predictable tax outcomes, timely filings, and controls that support long-term value creation.

This example illustrates a different sector using a formal tax framework, naming the executive and board-level reviewers, and giving a review cycle plus a public web location. It also explains how tax management supports the business model and sustainable development aims, while describing compliance in practical terms.

Company reports

How companies report GRI 207-1

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Endesa, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Open report →
Endesa, S.A.'s 2025 Consolidated Annual Report includes coverage of general sustainability information and company context on pages 5 and 149, with detailed discussion of material impacts, risks, and opportunities related to consumers and end users on page 153. The report also addresses corporate governance and tax policy as part of its sustainability disclosures on page 362, and references its own methodology aligned with EU Regulation 2020/852 on page 380. However, some narrative elements, such as detailed methodology explanations for certain items, are missing or unclear, with no quotable evidence found for narrative item (a-iv).
E.SUN Financial Holding Company, Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Open report →
E.SUN Financial Holding Company, Ltd.'s 2024 Sustainability Report covers several relevant areas, including a focus on a diverse, inclusive, and friendly workplace as part of talent attraction and retention (p.167), and detailed information on tax policy, governance, control, and risk management aligned with GRI 207 standards (p.164). The report also describes the Board of Directors’ involvement in sustainable development strategy execution (p.41) and outlines its approach to identifying and addressing data security risks (p.189). However, some narrative items lack clear or direct evidence in the report, as indicated by the absence of quotable content for certain disclosure elements.
Canacol Energy Ltd
Oil and Gas · Canada · 2024
Open report →
Canacol Energy Ltd’s 2024 ESG Integrated Report includes coverage of its tax compliance and fiscal approach, highlighting a commitment to accountability and transparency as noted on page 54. The report also outlines the company’s sustainability strategy aimed at strengthening competitiveness and quality (p.16), and references additional climate-related disclosures such as the 2024 Climate Change Management Report and CDP Climate Change Questionnaire (p.86). However, there is no clear or quotable evidence found regarding some specific narrative items (a-iii and a-iv), and certain details remain unclear or missing from the report.
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Scenarios to work through

A group has a written tax policy, but it sits only with the finance team and has never been taken to the board. The policy was last updated two years ago after a change in the group structure.

QCan you describe the organisation’s tax approach if you cannot show who formally signs off the policy and how often it is revisited?
Reveal model answer →

A preparer finds a tax policy on the company website, but the document is a general ethics statement with one short paragraph on taxes. The tax team also has a separate internal memo that sets out the real decision rules.

QWhich document should be used to explain the tax approach, and what should be done if the public document is only part of the story?
Reveal model answer →

The tax policy says the audit committee reviews it every year, but in practice the committee has not seen it for 18 months because the agenda was crowded with other matters. Management still wants to report the annual cycle.

QShould the reported review frequency follow the written policy or the actual governance practice?
Reveal model answer →

A multinational group says its tax approach supports growth, but the draft narrative only mentions filing returns on time and paying local taxes. It does not explain how tax decisions connect to expansion plans or wider sustainability goals.

QWhat extra explanation is needed to show the link between tax management, the business plan, and the organisation’s wider development aims?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 207-1
within GRI 207: Tax
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

For GRI 207-1, what should I have ready before I start drafting the tax disclosure page?+
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What evidence should I collect for GRI 207-1 so the disclosure is assurance-ready?+
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