Tax Transparency

Tax transparency activities are carried out in line with the Regulation on the Implementation of Certain Obligations Arising from Tax Information Exchange Laws Between the Republic of Poland and Other Countries. These activities include:

• The onboarding process, which ensures the collection of FATCA/CRS declarations from customers opening a financial account as defined under FATCA/CRS regulations;
• The development of IT systems to support customer identification processes under FATCA/CRS, including business applications for customer onboarding and dedicated functionalities enabling online declaration submission and updates;
• The customer classification process, conducted based on submitted FATCA/CRS declarations as well as personal and contact information provided by the customer;
• The enhancement of IT systems supporting customer classification and data reporting to the Head of the National Revenue Administration, via the IFT application, which includes Residency, FATCA, and CRS modules;
• The monitoring of changes in customer circumstances that may impact their FATCA/CRS classification;
• Annual reviews of high-balance customers;
• Communication campaigns targeting customers whose data requires updating or where discrepancies in previously submitted declarations have been identified;
• Planning and conducting internal control tests within the Internal Control System, verifying FATCA/CRS compliance on a sample basis;
• Annual data reporting to the Head of the National Revenue Administration, with submission deadlines set for 30 June each year for the previous fiscal year.

The Regulation on the Implementation of Certain Obligations Arising from Tax Information Exchange Laws Between the Republic of Poland and Other Countries also establishes the Bank’s objectives in managing tax transparency. These include: 

• Timely submission of FAT-1/CRS-1 reports to the Head of the National Revenue Administration by 30 June each year for the preceding fiscal year;
• Regular customer communication campaigns for individuals identified as having potential classification changes or missing data, conducted at least once per quarter;
• Annual high-balance customer reviews;
• Preparation and execution of an internal control plan, ensuring all scheduled audits are completed within the planned timeframe.

An essential aspect of tax transparency management is the establishment and monitoring of key performance indicators that assess the effectiveness of tax compliance processes. Within the Capital Group, this assessment takes place across several areas:

• Internal Control System, which includes an annual FATCA/CRS testing plan specifying the timelines for various audit activities. Test results and related documentation are recorded in a dedicated application (Compeo) administered by the Compliance Department and reported semi-annually to the Vice President responsible for the Financial Division;
• Periodic audits conducted by the Internal Audit Department, with the most recent FATCA audit completed in Q1 2024 and the most recent CRS audit in Q3 2022. All recommendations were implemented, and ongoing monitoring is conducted through the dedicated Gaudi IT tool;
• Register of Due Diligence Activities, maintaining a record of all due diligence activities performed for individual Bank customers within the customer classification system (IFT-Residency module);
• Data governance quality indicators within the Data Governance System, which assess whether FATCA/CRS-related data generated in business processes meet completeness and quality standards. These indicators are maintained in the Data Governance Platform (Platforma Zarządzania Danymi, PZD);
• Official confirmations of submission (Urzędowe Poświadczenia, UPO) for FAT-1/CRS-1 reports.