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How to pursue a Responsible & Transparent Tax Behaviour, the case of BBVA

Tuesday, June 11, 2019

With its Total Tax Contribution report, the multinational Spanish banking group discloses, on a yearly basis, its corporate income tax, VAT, wage tax and others, to increase transparency and trust amongst stakeholders. The BBVA approach was recently included in CSR Europe’s Blueprint on Responsible and Transparent Tax behaviour. Discover our service offer to help your company ensuring corporate responsibility on tax.


BBVA is one of the largest banks in Spain, and as a financial institution, it is required to publicly report certain tax-related information under the EU Capital Requirements Directive IV (“CRD IV”) since 2013. The bank is required to disclose the corporate tax on profit or loss, turnover, number of employees and the nature of their activities for each country in which BBVA has an establishment. BBVA started to publish tax information on a country-by-country basis in 2011, before the legal obligation. Since then, it has published an annual Total Tax Contribution (“TTC”) report on its economic contribution to public finances, which goes beyond the information it is required to disclose under CRD IV. The TTC report includes information on the tax payments made by BBVA and covers corporate income tax, VAT, wage tax and other taxes. BBVA believes that the TTC report enables all its stakeholders to have a good understanding of the company’s tax payments, that it represents a forward-thinking approach and shows BBVA’s commitment to corporate responsibility. By using the TTC, BBVA aims to assume a leading role on tax transparency and increase the understanding of NGOs and other external stakeholders of its tax reporting where necessary in order to help rebuild public trust in the financial sector. One of the main benefits of publishing the TTC report has been that, over time, BBVA says it has come to be recognized as a “best practice” for tax transparency by its peers in Spain. This incentivizes the company to continue publishing the TTC report and develop the methodology it uses for it further. Furthermore, when CRD IV was first introduced, BBVA was already prepared with regard to the adaption and compliance costs in connection with implementing the new regulations, as its TTC report included all the information that became mandatory to disclose under the directive. As a substantial amount of data needs to be collected and managed for the annual TTC report, as well as for the mandatory reporting under CRD IV and Country-by-Country reporting, 50 BBVA has engaged an external IT service provider to digitalize the process of data collection and management. However, ultimately, BBVA aims to automate the process of tax data collection in-house. To ensure the accuracy of the reported data, BBVA has set up several internal controls. The current data collection system, for instance, indicates significant differences from country to country and, if necessary, raises “red flags” that require further analysis. Furthermore, only a limited group of employees has access to the data collection system and is allowed to process the relevant data. Although robust internal controls are in place, improving the quality of the reported data continues to be of huge importance to BBVA and additional controls are being developed. Since the TTC report is available to the public, as part of its internal control system, BBVA analyses the data reported per country to ensure full alignment with the information in its publicly available Corporate Tax Strategy.

In order to help your company scaling up corporate tax transparency and establishing responsible tax behaviour, CSR Europe developed a 3-step approach focussed on:

  • Rating your processes with the Tax self-assessment Questionnaire (Step 1)
  • Developing internal buy-in through an Internal Workshop (Step 2)
  • Testing your strategy through an External Stakeholder Dialogue (Step 3)

After checking whether your company has adequate and appropriate internal processes and measures in place to implement its tax strategies, the CSR Europe Team will guide you to link tax with sustainability. Not only. We will also help you upgrading tax in your company’s vision and strategy. Lastly, we will facilitate your engagement with external stakeholders to test current and future tax strategy, and test plans for more transparency.

More Information:

CSR Europe’s Blueprint for Responsible and Transparent Tax Behaviour (Publication)

Learn more about the 3-step approach offered by CSR Europe.


Elisa Casazza

Project Manager