The tax policy of Allegro.eu and its subsidiaries is based on adherence to all obligations arising from tax regulations. The Group pays taxes when due and in the required amount and submits due tax statements and information. In particular, the amount of tax due is defined according to actual economic events. The actual tax strategy of the Group results from a number of internal procedures in individual companies, and strategy implementation reports are publicly available on corporate websites at Allegro.pl2 and Ceneo.pl3 in compliance with applicable Polish law.
2 https://allegro.pl/zobacz/informacja-o-realizacji-strategii-podatkowej
3 https://info.ceneo.pl/Brands/infoceneo/Ceneo_informacja_o_strategii_2020.pdf
The Group’s tax reporting promotes the credibility of its entities among investors and other stakeholders and builds confidence in Group companies. The Group’s tax operations are consistent with the business strategy, and its image of a responsible taxpayer fits into a broader context of the organization’s sustainability.
The Group’s tax strategy is regularly reviewed by the Tax Team in close partnership with the board. Compliance, internal control and risk management systems, including tax risk management systems, and the reliability of financial reports within the Group are overseen by the Audit Committee. The Audit Committee also conducts an independent effectiveness review of those systems.
Given the scale and scope of the Group’s operations, it is impossible to avoid all tax risks, e.g. due to frequent changes in tax regulations and the level of their complexity. The companies are trying to minimize tax risk by following the letter and the spirit of tax law and working with reputable tax consultancies and law firms.
The Group has defined risks and implemented procedures to minimize the potential negative effects of taking those risks. Allegro.eu’s tax risks were disclosed in the Allegro.eu Group Consolidated Annual Report ended on 31 December 2021 in the “Risks Related to Regulation, Legal and Intellectual Property Matters” section. The tax risks defined by the company include:
- changes in Polish tax regulations that may harm the Group’s operational results and financial condition
- the amended Withholding Tax (WHT) regime in Poland
- digital services taxes have been proposed, partially implemented, and may be broadened by Poland, some EU Member States, the European Union or the OECD, and other taxes may be imposed on the e-commerce segment or e-commerce platforms
- an increased focus by the relevant tax authorities on related party transactions may cause the Group’s policies to undergo more scrutiny, and the Group may be subject to tax audits and challenges involving such transactions
- Polish tax rulings may be subject to review
- customs and tax authorities are currently undertaking tax audits into CIT settlements in the Group’s main operating companies, which may, along with any future tax audits, involve additional costs for the Group
- the implementation of the 2021 EU VAT e-commerce package may result in additional tax exposure for the Group due to the considered plans to make the Import One Stop Shop system obligatory for marketplaces
- the Group may be exposed to greater tax liabilities than anticipated
- the Group may face the risk of its operations or transactions being reviewed in selected areas based on the General Anti-Avoidance Rule (GAAR).
If there are any doubts about how to apply tax regulations, the Group consults professional third-party tax and legal advisers and uses the institution of tax interpretation. The Group is also obliged to undergo an annual audit of accounts conducted by an external and independent authorized entity.
As members of trade associations and on their own behalf, Allegro Group companies participate in the Polish and EU legislative process and issue opinions on draft amendments to tax regulations at the stage of public consultation.
[GRI 207-2] [GRI 207-3]
All Group employees can report concerns regarding the organization’s unethical or illegal tax behaviour using a whistleblowing system. The system guarantees confidentiality and safety of the whistleblowers, including protection from retaliatory action. It is open and accessible for everyone in the company (reports can also be submitted anonymously via a special form available online).
The Group cooperates with tax authorities to the full extent provided for by the law. The companies provide tax authorities with complete information regarding tax settlements and provides additional information at the request of tax authorities in a timely manner. In 2021, the Group companies did not enter voluntary cooperation with the National Revenue Administration (Krajowa Administracja Skarbowa, KAS) provided for in tax regulations. The companies do not rule out entering such cooperation in the future.
In 2021, no fines or additional sanctions were imposed on the Group for any tax irregularities.
[GRI 207-4 b]
The Group submits information on its taxes due in periodical financial reports. Since the scale of the Group’s operations in other tax jurisdictions outside Poland is limited (immaterial in terms of value), the information published regards Poland only. The Group does not carry out a fiscal policy in countries considered tax havens.
In FY 2021, the income tax was PLN 268.6 million, PLN 70.4 million (35.5%) higher than the tax for FY 2020. The Group’s effective tax rate was 19.8% and 32.1% for FY 2021 and 2020 respectively, compared to the Polish standard corporate income tax rate of 19% for each period. The high effective tax rate in the comparative period resulted from non-deductible IPO expenses and other tax losses incurred by one of the Group’s Luxembourg subsidiaries in the combined amount of PLN 266.0 million, for which no deferred tax asset was recognized as this entity is not likely to generate taxable income in the foreseeable future.
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Jurisdiction
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Poland
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Names of the resident entities
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Allegro.pl sp. z o.o.,
Ceneo.pl, sp. z o.o.,
Allegro Pay sp. z o.o.
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Primary activities of the organization
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Allegro.pl – operator of online marketplace
Ceneo.pl-multi-category price comparison site in Poland
Allegro.pay – a consumer finance and
lending solutions provide
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Number of employees, and the basis of calculation of this number
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4848*
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Revenues from third-party sales
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–
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Revenues from intra-group transactions with other tax jurisdictions
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–
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Profit/loss before tax
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1358,1 mln PLN
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Tangible assets other than cash and cash equivalents
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443,809
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Corporate income tax paid on a cash basis
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–
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Corporate income tax accrued on profit/loss
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268,5 mln PLN
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Reasons for the difference between corporate income tax accrued on profit/loss and the tax due if the statutory tax rate is applied to profit/loss before tax
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–
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* Employment contract, contractors, employment agency and external services
