Responsible taxpayer

NN considers taxation to be a sustainability matter. Taxes, contributing to public finances and the instrumental use of taxes are vital in achieving sustainability goals. A responsible tax approach is an essential element of good corporate citizenship. Being a responsible taxpayer means that we contribute to public finances in the countries where we operate, we take long-term considerations into account, and we carefully weigh the interests of all stakeholders. The Head of Group Tax annually validates the global tax strategy to ensure it aligns with NN’s ambition, strategy and values.

Besides paying taxes, NN contributes in various ways to its sustainability ambitions. For instance, through our community investment programme, where we have the ambition to use 1% of our operating capital generation to support the communities in which we operate.

Impact of sustainability on taxation

At NN, we recognise the impact that sustainability developments have on taxation and simultaneously the impact that taxation has in helping create a more sustainable world. Taxes can play a vital role in achieving the Sustainable Development Goals (SDGs) and help create a more sustainable world through enhanced public services and investments. We support the instrumental use of taxes as a means of changing behaviour. Through paying the right amount of tax, at the right time and in the right place, NN is committed to contributing to society.

Tax principles

NN believes it is essential to have a set of guiding tax principles to adhere to. The principles of conduct are derived from the global tax strategy and are defined in the NN Tax Policy and Principles of Conduct (Tax Policy). The principles of behaving responsibly mean the timely paying of our fair share of taxes in the countries where we operate.

The Tax Policy is reviewed and approved by the NN Group Management Board and Executive Board every three years or more frequently if the policy has been revised in the intervening period.

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Compliance

We pay our taxes promptly and in accordance with all applicable laws and regulations in the countries in which we operate and are guided by relevant international standards such as the OECD Guidelines. We aim to take both the letter and the spirit of the tax laws and regulations into account.

We seek to resolve any uncertainty in the interpretation of the tax laws directly with tax authorities. We may also seek a cooperative compliance approach, which involves regularly and proactively engaging with tax authorities and providing them with real-time information before filing our tax return. These arrangements offer an opportunity for early resolution, minimising the risk of future disputes. Where necessary, we will seek a clear resolution through the judicial system to test the legal principle of the tax law concerned.

Business rationale

We believe that tax is an integral part of doing business and not merely the domain of the tax function. We adhere to the principle that tax should follow business, and consequently, profits are allocated to the countries in which business value is created. For calculating transfer prices, we apply the arm’s length principle.

Tax is one of the elements we consider in our commercial and economic activities, while businesses may also respond to generally available tax incentives and exemptions.

Relationship with tax authorities

Wherever we operate, we strive to establish and maintain an open and constructive dialogue with tax authorities and other government bodies. This dialogue is based on the disclosure of all relevant facts and circumstances and aims to provide clarity and establish certainty on all relevant local tax components prior to filing our tax return.

NN Group was identified as a Top 100 for profit company by the Dutch tax authorities in their 2021 updated tax monitoring model. In line with the model and the Dutch tax authorities’ guide on the supervision of large businesses, NN’s co-operative compliance programme was replaced with an Individual Monitoring Plan (IMP). The Dutch tax authorities update their IMP with NN Group yearly, with the latest update occurring in 2024 for the 2025 period. The IMP outlines how NN Group is perceived by the tax authorities regarding its activities, inherent tax risks and tax compliance. The Dutch tax authorities consider NN Group to be tax compliant and transparent in its tax affairs. The Dutch tax authorities also acknowledge the Tax Control Framework (TCF) approach being implemented by the NN Group Tax Function.

The NN Group Tax Function has designed and implemented a framework that includes tax risks and controls in line with the Global Tax Risk Management Policy. The TCF is not a static framework but is continuously monitored and improved by the NN Group Tax Function in response to business developments, changes in tax laws and regulations, and the learning circle.

Tax planning

We believe that the NN Tax Function may engage in tax planning initiatives and make use of incentives promoted by government authorities as long as these are generally available. However, we also believe that such planning should give due consideration to NN’s legitimate interests, reputation, brand and corporate social responsibility.

We have clear procedures for tax risk management and carry out risk assessments as part of any tax planning on significant transactions. We do not enter into aggressive and contrived tax planning structures. We do not use secrecy jurisdictions or so-called ‘tax havens’ for tax avoidance, nor do we use artificial tax structures that have no commercial or operational substance.

Furthermore, we believe that our products should not be used by our clients to shelter information from tax authorities or to avoid taxation.

Transparency

We are transparent about our approach to tax and our tax position. Disclosures are made in accordance with domestic regulations, as well as applicable reporting requirements and standards such as IFRS. We strive for an open dialogue on tax matters with governments, policymakers, businesses, investors, and civil society.

We continue the dialogue on taxes with our stakeholders through public tax reporting. We extensively report on our total tax contribution on a country-by-country basis. We do not include environmental taxes (e.g., a carbon, plastic or sugar tax) as currently these are not material, nor do they generally apply to NN’s business. Read more in our Total Tax Contribution Report.

Total Tax Contribution

Besides taxes that NN Group pays as a taxpayer, we are also responsible for collecting taxes on behalf of our clients, employees, or service providers, and passing them on to tax authorities. By consolidating all relevant information about these taxes in our Total Tax Contribution Report, NN Group aims to enhance the understanding of its business and its approach to tax.

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Tax organisation

The tax function within NN Group is organised to ensure compliance with tax laws and regulations in the countries where it operates. NN Group’s Global Head of Tax leads a team of in-house tax advisors and tax accountants, who possess a combination of accounting, tax, and technology qualifications. The NN Group Tax Function holds global responsibility for the tax position of NN Group. In executing this responsibility, it considers long-term factors and carefully weighs the interests of all stakeholders. The NN Group Tax Function continuously monitors relevant changes and developments in tax laws and regulations and regularly reviews NN Group’s corporate and financing structures to ensure that our presence in all countries has a well-grounded substantive and commercial rationale.

Accountability & Governance

The NN Group Management Board and the Supervisory Board oversee NN Group’s tax position as a core part of corporate responsibility and governance. To enable the Supervisory Board to execute its duties, the NN Group Tax function informs the Audit Committee of the Supervisory Board on an annual basis regarding:

• Implementation of and adherence to the NN Group Tax strategy and Tax Policy and Principles of Conduct
• Risk profile per type of tax, including material risk positions and the corresponding risk response
• NN Group’s tax positions
• Developments in relation to tax authorities

Further, the Group Tax Function actively engages and shares knowledge with the Audit Committee of the Supervisory Board on changes in the tax landscape, including tax regulations, reporting requirements or expectations, and internal developments that might have an impact on the NN Group Tax function.

Subsequently, the Audit Committee of the Supervisory Board conducts an annual review of the impact of taxes on NN Group NV and how developments affect the company’s tax positions.