2021 UNIVERSAL REGISTRATION DOCUMENT

4. L’Oréal’s social, environmental and societal responsibility

Transparency

L’Oréal establishes and maintains relations with Tax and Customs Authorities based on transparency pursuant to the Group’s “zero tolerance” rule on corruption. L’Oréal also develops a constructive relationship with Tax and Customs Authorities, a relationship based on the principles of co-operation and mutual respect. L’Oréal responds appropriately and promptly to requests from the tax authorities regarding the exchange of information and in compliance with tax conventions.

Where permitted to do so by governments, L’Oréal joins the cooperative compliance programmes launched by the tax authorities. For example, the trust relationship ("relation de confiance") with the French tax authorities.

In addition, the Group may contribute to the analysis of legislative changes at the request of Tax and Customs Authorities or professional associations requested for said changes. Consequently, the Group takes part in OECD working groups relating to pillars 1 and 2.

L’Oréal takes into consideration global challenges and standards in terms of tax transparency. In particular, it adheres to the reporting recommendations of the GRI (Global Reporting Initiative) and, more specifically, standards GRI 207-1, GRI 207-2 and GRI 207-3.

L’Oréal is also a member of the European Business Tax Forum (EBTF), a European companies association that seeks to increase transparency in the tax debate.

Legitimacy

L’Oréal legitimately applies the most relevant tax treatment, in accordance with the economic reality, operational objectives and the laws in force.

In an evolving international tax environment, the positions taken by the Group may be questioned and subject to tax and customs audits by local authorities. If there is disagreement with a Tax or Customs Authority, L’Oréal is able to legitimately defend its interpretation of the law, prove its good faith and, as needed, bring the disputes to court.

A regular review of tax risks carried out by the Group’s Tax Department in contact with the local financial teams enables the risks to be assessed, resulting, if applicable, to the recognition of a provision. The main tax risks are reported to the General Management and the Audit Committee.

Organisation

Compliance with these three pillars is ensured by centralised expertise and a strong geographical presence of tax function in the countries.

Tax compliance falls under the responsibility of the Chief Financial Officers, backed up and relayed by the Tax and Accounting Departments. These Departments, assisted where applicable by external advisors, monitor changes in tax regulations to ensure that the Group complies with these regulations.

Centralised expertise

Within the Department of Operational Finance, the Group Tax Department ensures compliance with the Tax Policy in collaboration with the Finance Departments through the relay of different group-wide tax experts:

  • Intra-group Transactions & Customs, which ensures compliance with tax and customs standards and secures the prices of intra-group transactions and the related documentation;
  • Analytics & Compliance, which analyses, verifies and informs on the Group’s compliance and global tax liability;
  • M&A, which assists and provides tax advice on proposed merger-acquisition projects.

In order to enhance these centres of expertise, two new functions were created in 2021:

  • Tax Digitalisation which will support digital tax compliance projects in accordance with tax regulations in this area; and
  • Tax Governance, in order to ensure the correct deployment of the Group’s tax policy.
A strong geographical presence

In the zones and countries, the tax function is directly represented in 30 countries by local tax departments operating under the accountability of the Country/Zone Chief Financial Officer. The Tax Directors have different responsibilities:

  • respect for compliance rules in collaboration with the accounting departments;
  • assistance and tax advice to the operational teams in the context of their projects;
  • tax directives, ongoing training and pedagogy with other parties;
  • management of the tax contribution;
  • management of tax and customs risks, controls, claims and litigations;
  • relations with the Tax and Customs Authorities and the other public authorities; and
  • tax watch and best practices, which implies dialogue with peers, professional associations, external auditors and law firms.

This matrix organisation, combined with the Group’s tax policy respect, are the basis of successful management of the tax burden and a responsible tax practice.