Approach to tax

In line with the Code of Ethics, Snam and its direct and indirect subsidiaries apply principles of fairness, transparency, honesty and integrity, which in the tax area are implemented in the correct discharge of tax obligations in compliance with the rules; in managing tax matters, the Group aims for the “certainty” of its tax adopted positions.

In order to further strengthen its Internal Control and Risk Management System, the Snam Group has adopted the Tax Control Framework (TCF), which provides a structured approach to the detection, assessment, management and control of tax risks.

The implementation of the TCF for Snam S.p.A. and Snam Rete Gas S.p.A. was instrumental to the admission, on 2 December 2019, to the collaborative compliance regime laid out by Legislative Decree no. 128/2015 (so-called “cooperative compliance”). The regime enables continuous and preventive dialogue with the Italian Tax Agency and reflects the constant application of the principles of fairness, transparency and awareness of the fulfilment of the tax obligation defined in the “Tax Control Framework – Tax Strategy” Guidelines.

These guidelines define the company’s policy concerning taxation and is available in an extract on the web page www.snam.it/en/Sustainability/snam_commitments/tax_policy.html.

The Tax Strategy sets out to achieve the following aims:

• Tax Value, i.e. the effective management of the tax ‘cost’ inherent to the company’s business;
• Risks and Reputation, i.e. the control of fiscal risks with a view to protecting the reputation of the Company and the Group;
• Tax Compliance, i.e. integrity in the management of tax compliance and the determination of the tax liability of Group companies;
• Promotion of shared values, i.e. promoting awareness at all levels of the company of the importance that Snam attributes to the values of transparency, honesty, fairness and compliance with regulations;
• Relations with the tax authorities, i.e. establishing relations with the tax authorities based on good faith and transparency;
• Best use of resources, i.e. developing and strengthening the professional skills of resources involved at any level in the tax process.

The Tax Control Framework carries out periodic assessment and monitoring activities, which are reported to the relevant corporate functions, the Company’s Administrative and Control Bodies and the financial authorities.

In order to ensure maximum transparency of the tax management procedures, Snam provides its financial, economic and tax information for each jurisdiction in which it operates. This reporting provides an indication of the magnitude of the Group activities and their tax contributions in these jurisdictions.