1. Introduction

This Tax Policy applies to all Accor Group entities, conditional on its approval and adoption, in compliance with local regulations. It defines the governance principles, values and guidelines applicable to the decision-making process with regard to tax issues.

This Tax Policy complies with the values and principles of commitment, team spirt, integrity, respect, openness and diversity as well as the Corporate Social Responsibility Policy and the Code of Ethics of the Accor Group.
As a multinational company, Accor must apply the laws and regulations in force in the countries in which it operates and pay tax amounts in line with such activities. Its first responsibility is to pay taxes and file related tax declarations in compliance with the deadlines established by the different tax authorities, in compliance with the laws and regulations of each country.

Accor considers that the tax the Group must pay in the different tax jurisdictions significantly contributes to the progress and development of these countries. The Accor Group Tax Policy aims to create value for its shareholders, guests, employees and any other relevant third parties.

Accor also aspires to develop and maintain open, transparent and collaborative relations with tax and government authorities.

This Tax Policy, which is mandatory, ensures that the Group complies with the tax regulations in force. Moreover, the Policy seeks to reduce tax risk and define the guidelines and governance framework applicable to all Accor Group entities, subject to approval in compliance with local regulations.

In this respect, and as part of the Group’s Corporate Social Responsibility approach, Accor favors a responsible attitude to taxation, taking into account the interests and the sustainable economic development of the territories in which it operates. To this end, Accor also ensures implementation of best tax practices.

The Accor Group fiscal policy is based on four concepts:

• tax compliance ;
• tax risk management;
• operational support;
• tax transparency;

2. Tax policy

To promote responsible tax practices, Accor assesses its tax exposure in terms of potential economic and reputational impacts in the short- and long-term, taking account of its shareholders, guests and employees.

By meeting its tax obligations, Accor seeks to maintain co-operative and satisfactory relations with the Tax Authorities in the countries where it operates.

To promote compliance with these commitments, which include the above Action Principles, the Accor Group has adopted the following procedures:


Tax compliance

Worldwide, Accor Group’s business generates significant taxes of various kinds. In addition to corporate income tax, the Group is required to pay other taxes in its various host countries, such as local taxes, customs duties, stamp duties and social security contributions.

Accor ensures that the Group’s various entities comply with all international laws, regulations and treaties. This involves filing the necessary tax returns and paying the taxes due on time.

Recourse to the use of artificial structures without connection to the business activities of Group entities for the sole purpose of reducing the tax burden, avoiding taxation or hindering the work of tax administrations or tax authorities in each country is strictly prohibited by the Tax Policy applied by the Accor Group.

Furthermore, Accor constantly monitors changes in regulations.

Certain complex issues are also formally approved by the use of external, independent, recognized and reputable tax advisors and, when possible and necessary, by correspondence with the relevant tax authorities (i.e.: use of advanced rulings or approval procedures).


Tax risk management

The Fiscal Department is managed by the Chief Tax Officer, who reports to the Deputy Chief Financial Officer. The latter reports to the Deputy Chief Executive Officer and Chief Financial Officer.

The Accor Group’s Tax Department bases its decisions on a network of qualified employees throughout the world and ensures that they benefit from continuous training as well as requiring them to comply with the Company’s Code of Ethics and its procedures.

They all commit to upholding the laws and tax regulations of the countries where Accor operates business activities and they apply the highest quality standards.

Tax risk is managed so that the reputation of the Accor Group is protected. This means:

• complying with all applicable regulations and paying taxes;  
• mitigating tax risk through fiscal monitoring and the use of external advisors. Thus, any reform that has an impact on the Group’s activity is analyzed;  
• closely monitoring tax audits and disputes. 

The Audit, Compliance & Risk Committee also examines how fiscal policy could impact the Group and its stakeholders. The Audit Committee is responsible for the quality and completeness of financial disclosure and for managing the Group’s risk exposure. It has oversight to ensure that the fiscal risks are fully understood. It is therefore periodically informed of the Group’s fiscal risks. Internal Control as well as external auditors also ensure compliance with policies and procedures in force and overall tax risk management within the Accor Group.

Accor also publishes information concerning ongoing disputes with certain national tax authorities, on page 386 of the 2020 Universal Registration Document.

The Accor Group complied with the new rules for consolidation related to IFRIC 23.


Operational support 

The Accor Group fiscal policy reflects the Group’s business and development. For example, the Fiscal Department is organized around a central team which works closely with the operational teams.

In this supporting role, the Fiscal Department ensures that the most relevant tax options are implemented in accordance with the various regulations.  As such, Accor promotes the analysis of financial, legal, accounting and commercial impacts that may arise pursuant to recurring and extraordinary operations through the introduction of appropriate means of communication between the different departments. In particular, the Accor Group:

• ensures that investments and transactions which may have a considerable tax impact are correctly assessed in advance, and related financial, accounting, legal and tax impacts are documented appropriately;
• audits and analyzes structures relative to all transactions involving acquisitions of assets, entities and significant businesses to identify and monitor any potential tax risks;
• clearly defines the decision-making framework governing appropriate transfer pricing for all types of transactions, as well as the introduction of audit mechanisms to ensure that such transactions comply with the arm’s length principle.  commits to complying with documentary and declarative obligations as regards transfer pricing in accordance with the provisions of the different tax legislation. Equally, Accor ensures that its transfer pricing policy is regularly updated and reviewed in compliance with regulations in force and operating circumstances.
  The Group is also involved directly, or through industry associations, in dialogue with the tax and legislative authorities in order to create a favorable business environment. 
  Tax transparency 

Accor complies with the international tax standards established by the OECD and ensures that its intercompany transactions comply with European regulations on the Group’s activities with the arm’s-length principle. 
Furthermore, the Group meets its Country-by-Country Reporting (CBCR) obligations and sends the required information to the French tax authorities in accordance with the law.

With respect to transfer pricing, Accor applies the principles defined by the Organisation for Economic Co-operation and Development (OECD) and national regulatory bodies and seeks to apply pricing that reflects arm’s length principles for all intra-company transactions. Accor Group’s transfer pricing policy is documented and supported by economic analysis.

Accor books corporate income tax in line with IAS 12 – Income taxes. 
Details of Accor’s corporate income tax by geographical area (in millions of euros)

The graph before presents the operating profit and corporate income tax according to IFRS 5, excluding deferred taxes and including the value-added contribution for businesses (CVAE).

Based on its consolidated net result (including allocations to provisions for depreciation and amortization and net impairments relating to intangible assets, restructuring costs, etc.), Accor generated tax income of €62 million in 2020, i.e. an effective tax rate of 3.6%. In 2019, the tax expense totaled €138 million, i.e. an effective tax rate of 23.1%.

Lastly, Accor publishes the overall amount of its tax on page 379 of the Universal Registration Document (after IFRS 5).
As well as corporate income tax, the Accor Group pays many other taxes, duties and levies. Most of these taxes, duties and levies are deducted from the profit generated by Accor and in turn profit subject to corporate income tax.

3. Relations with tax authorities 

Accor also aspires to develop and maintain open, transparent and collaborative relations with tax and government authorities.

Whenever possible, Accor requests pre-approval on complex matters or with respect to transfer pricing policy. This same open and co-operative approach is also applied to the regular tax audits the Group is subject to in most countries where it operates.

Either directly or via professional organizations, Accor participates in initiatives with legislators or government and national and international organizations which strive to improve legal security and foster sustainable growth.

4. Governance and structure

The Accor Group’s Tax Department is responsible for coordinating the above best tax practices by introducing the appropriate audit mechanisms and internal guidelines to ensure compliance with the regulations in force. These practices can be applied by departments that directly or indirectly perform tax-related functions.

This mission necessarily covers all the countries and territories where the Group operates and all the business activities carried out to enable coherent and consistent management of tax risks.