In Enel’s organisational model, the Holding Company’s Tax Affairs unit is tasked – among other things – with developing the Group’s tax strategy, identifying, analysing and managing the various optimisation initiatives, monitoring the key tax issues and providing its support to the various Business Lines. Alongside the Holding Function, the Tax Affairs units of the various countries – acting in accordance with the values and principles of the tax strategy set out by the holding company – are responsible for managing compliance, tax planning and tax monitoring at local level.
For the Enel Group, tax compliance is considered a key aspect of the Company’s ethical and responsible management. As such, the violations that can be reported through the Company’s internal channels also include those relating to tax.
The Group has a Tax Control Framework (TCF) whose main aim is to provide the Tax units with a single and consistent set of guidance for adopting a correct and effective approach to tax risk management within the Group. The framework sets out guidelines and methodological rules so as to consistently assess, monitor and manage the relevant tax risk for the Group’s companies. This is in accordance with the principles and guidelines set out by the tax strategy and Tax Risk Policy, and in the awareness that the Group companies operating in different jurisdictions must adopt the TCF with respect for the specific societal context and domestic regulations of the individual countries in question. In accordance with the principles and guidelines set out in the tax strategy, the Enel Group aims to proactively manage the tax risk and believes that adopting a TCF can ensure the timely detection, correct measurement and control of the risk tax.
For companies that meet the legal requirements for participation, the Enel Group promotes participation in cooperative compliance schemes where they exist in the various Countries in which it operates. In particular, Enel participates in the Collaborative Fulfilment (Adempimento Collaborativo) scheme in Italy1, for larger companies, in the equivalent Code of Good Tax Practices (Código de Buenas Prácticas Tributarias) scheme in Spain2 and is collaborating with the federal tax authority in a pilot project for the creation of a local Cooperative Tax Compliance model (Projeto CONFIA - Conformidade Cooperativa Fiscal) in Brazil3.
In order to monitor the status of this activity, an index (the Cooperative Compliance Index - CCI) was developed to measure the participation of Enel Group companies in cooperative compliance regimes in various countries based on their size and membership requirements4.