SAP Global Tax Principles
SAP’s Global Tax Principles ensure compliance with tax laws, support sustainable planning, and align with corporate social responsibility. They focus on transparency, responsible tax management, and maintaining constructive relationships with tax authorities, benefiting SAP, its customers, and society. Preuzmite dokument© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions
related to this material.
SAP Global Tax Principles
SAP’s Global Tax Principles are an integral part of the guiding principle of our business
strategy, which is to help the world run better and improve people's lives. As a global leader,
we stand for this higher purpose beyond economic success. We believe social,
environmental, and economic activities and performance are interrelated – each impacting
the others. Our efforts focus on creating a sustainable future for SAP, our customers, and
society.
Through our business activities, we generate a substantial amount and variety of taxes. We
pay corporate income taxes, indirect taxes, withholding taxes, employment taxes, as well as
other applicable taxes. The taxes we collect and pay form a significant part of our economic
contribution to the countries in which we operate, hereby contributing to our purpose. By
ensuring compliance with all relevant laws and regulations in the countries in which we
operate, we act in line with our broader social responsibilities and our stakeholders’
expectations.
In our tax principles, we determine our approach to tax compliance and tax risks, which set
our tax governance and control framework. Our guiding principles – as provided below – are
based on the recognition that tax is an essential element of our overall corporate social
responsibility, as well as on the material issues of tax compliance and of responsible and
sustainable planning. While our sustainability reporting follows the European Sustainability
Reporting Standards (ESRS), our Global Tax Principles follow Global Reporting Initiative
(GRI) standards to support structured and transparent tax disclosures, as ESRS provides
related to this material.
SAP Global Tax Principles
SAP’s Global Tax Principles are an integral part of the guiding principle of our business
strategy, which is to help the world run better and improve people's lives. As a global leader,
we stand for this higher purpose beyond economic success. We believe social,
environmental, and economic activities and performance are interrelated – each impacting
the others. Our efforts focus on creating a sustainable future for SAP, our customers, and
society.
Through our business activities, we generate a substantial amount and variety of taxes. We
pay corporate income taxes, indirect taxes, withholding taxes, employment taxes, as well as
other applicable taxes. The taxes we collect and pay form a significant part of our economic
contribution to the countries in which we operate, hereby contributing to our purpose. By
ensuring compliance with all relevant laws and regulations in the countries in which we
operate, we act in line with our broader social responsibilities and our stakeholders’
expectations.
In our tax principles, we determine our approach to tax compliance and tax risks, which set
our tax governance and control framework. Our guiding principles – as provided below – are
based on the recognition that tax is an essential element of our overall corporate social
responsibility, as well as on the material issues of tax compliance and of responsible and
sustainable planning. While our sustainability reporting follows the European Sustainability
Reporting Standards (ESRS), our Global Tax Principles follow Global Reporting Initiative
(GRI) standards to support structured and transparent tax disclosures, as ESRS provides
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions
related to this material.
limited guidance in this area. This reference supports our reporting approach and aligns with
ESRS provisions on third-party standards.
These principles apply to all individuals involved in managing and executing SAP’s tax affairs
worldwide, as well as to SAP SE’s own operations. They are continuously aligned with our
business strategy as well as our values and are reviewed and approved by the SAP SE
Executive Board on a regular basis.
1. Compliance with tax laws and regulations
SAP is committed to complying with all tax laws and regulations in the territories in which we
operate, while also maintaining open and constructive relationships with tax authorities.
Compliance for us means paying tax in the amount, in the place, and at the time, and making
such disclosures to the tax authorities, as required by applicable tax laws and regulations,
while also claiming reliefs and incentives where available under law. This implies that we file
our tax returns and make all required disclosures in tax returns, reports and documents in
due time. We do not use our commercial bargaining power in any given country or region to
obtain company-specific tax advantages that are not properly legislated.
In certain cases, tax laws may be subject to interpretation. We interpret applicable tax laws
and regulations with due consideration, taking their intent and spirit into account, e.g., in the
handling of uncertain tax treatments and jurisdiction-specific details. Where necessary and
appropriate, we seek the advice of external tax advisors to assure that tax positions taken
are solidly grounded on prevailing opinions and relevant jurisprudence. In cases in which
uncertainty and financial risk cannot be eliminated, we account for adequate tax risks in our
audited group financial statements in accordance with the applicable accounting standards
and our group policies.
2. Responsibility for the tax principles, supporting governance and control
framework and management of tax risks
Responsibility for the tax principles, supporting governance and control framework and
management of tax risks of the group is with the Chief Financial Officer and member of the
SAP Executive Board, the Head of Global Accounting, Reporting & Tax, and the Head of
Global Tax. Training is provided to relevant employees to ensure that tax compliance is
carried out with a suitable level of diligence, technical expertise and sustaining a credible
long-term reputation with the tax authorities.
The Chief Financial Officer regularly reviews the Global Tax Policy. The Chief Financial Officer
also regularly reports to and aligns with the Management Board and Supervisory Board on
tax strategy and policy matters, tax developments and risk assessment including tax.
related to this material.
limited guidance in this area. This reference supports our reporting approach and aligns with
ESRS provisions on third-party standards.
These principles apply to all individuals involved in managing and executing SAP’s tax affairs
worldwide, as well as to SAP SE’s own operations. They are continuously aligned with our
business strategy as well as our values and are reviewed and approved by the SAP SE
Executive Board on a regular basis.
1. Compliance with tax laws and regulations
SAP is committed to complying with all tax laws and regulations in the territories in which we
operate, while also maintaining open and constructive relationships with tax authorities.
Compliance for us means paying tax in the amount, in the place, and at the time, and making
such disclosures to the tax authorities, as required by applicable tax laws and regulations,
while also claiming reliefs and incentives where available under law. This implies that we file
our tax returns and make all required disclosures in tax returns, reports and documents in
due time. We do not use our commercial bargaining power in any given country or region to
obtain company-specific tax advantages that are not properly legislated.
In certain cases, tax laws may be subject to interpretation. We interpret applicable tax laws
and regulations with due consideration, taking their intent and spirit into account, e.g., in the
handling of uncertain tax treatments and jurisdiction-specific details. Where necessary and
appropriate, we seek the advice of external tax advisors to assure that tax positions taken
are solidly grounded on prevailing opinions and relevant jurisprudence. In cases in which
uncertainty and financial risk cannot be eliminated, we account for adequate tax risks in our
audited group financial statements in accordance with the applicable accounting standards
and our group policies.
2. Responsibility for the tax principles, supporting governance and control
framework and management of tax risks
Responsibility for the tax principles, supporting governance and control framework and
management of tax risks of the group is with the Chief Financial Officer and member of the
SAP Executive Board, the Head of Global Accounting, Reporting & Tax, and the Head of
Global Tax. Training is provided to relevant employees to ensure that tax compliance is
carried out with a suitable level of diligence, technical expertise and sustaining a credible
long-term reputation with the tax authorities.
The Chief Financial Officer regularly reviews the Global Tax Policy. The Chief Financial Officer
also regularly reports to and aligns with the Management Board and Supervisory Board on
tax strategy and policy matters, tax developments and risk assessment including tax.
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions
related to this material.
3. Relationship with tax authorities
We engage with tax authorities with honesty, integrity, respect and fairness. Regarding our tax
affairs and significant transactions, we are open and transparent. We seek clearance for
significant transactions via advance rulings and mutual agreement procedures and support
active real-time audits. We are prepared to litigate where we disagree with the decision of a
tax authority but will first seek to resolve any disputed matters through proactive and
transparent discussion and negotiation.
4. Transparency
We comply with the disclosure requirements based on applicable tax laws and regulations.
Our tax-related decisions consider SAP’s reputation and relationship with our stakeholders.
SAP regularly engages with governments as well as policy making institutions such as the EU
Commission and the OECD – typically through public consultation processes or in our role as
a member of an industry group. We provide our perspective on how to best balance the
need for government tax revenues against the need to ensure sustainable growth of the
economy. We are in continuous exchange with other key stakeholders, such as our
shareholders, employees, customers, and industry associations, to be transparent and
balance our responsibilities to society and to our stakeholders, while also supporting our
broader climate strategy and decarbonization efforts as part of our adherence to the UN
Global Compact. In accordance with our group-wide Global Code of Ethics and Business
Conduct, we ensure transparent communication by providing both internally to SAP
employees and externally to concerned parties the opportunity to report on any matters or
concerns, including on tax-related matters or concerns easily and anonymously via our
reporting tool, Speak Out at SAP.
5. Transfer pricing
SAP conducts transactions between its group companies on an arm’s length basis and in
accordance with OECD principles and local requirements in the respective countries where
SAP conducts business. Hence, SAP pays corresponding amounts of tax according to where
value is created and where appropriate economic activities are performed and does not
engage in the artificial shift of profits and value created to low-tax jurisdictions.
6. Management of tax risks
Given the scale of our business, the volume of tax obligations as well as the conflicting fiscal
policies and tax laws, risks will inevitably arise from time to time. SAP’s appetite for tax risk is
low. We therefore seek to minimize tax risks by proactively and continuously identifying,
managing, monitoring and reducing these risks, with an emphasis on seeking opinions from
related to this material.
3. Relationship with tax authorities
We engage with tax authorities with honesty, integrity, respect and fairness. Regarding our tax
affairs and significant transactions, we are open and transparent. We seek clearance for
significant transactions via advance rulings and mutual agreement procedures and support
active real-time audits. We are prepared to litigate where we disagree with the decision of a
tax authority but will first seek to resolve any disputed matters through proactive and
transparent discussion and negotiation.
4. Transparency
We comply with the disclosure requirements based on applicable tax laws and regulations.
Our tax-related decisions consider SAP’s reputation and relationship with our stakeholders.
SAP regularly engages with governments as well as policy making institutions such as the EU
Commission and the OECD – typically through public consultation processes or in our role as
a member of an industry group. We provide our perspective on how to best balance the
need for government tax revenues against the need to ensure sustainable growth of the
economy. We are in continuous exchange with other key stakeholders, such as our
shareholders, employees, customers, and industry associations, to be transparent and
balance our responsibilities to society and to our stakeholders, while also supporting our
broader climate strategy and decarbonization efforts as part of our adherence to the UN
Global Compact. In accordance with our group-wide Global Code of Ethics and Business
Conduct, we ensure transparent communication by providing both internally to SAP
employees and externally to concerned parties the opportunity to report on any matters or
concerns, including on tax-related matters or concerns easily and anonymously via our
reporting tool, Speak Out at SAP.
5. Transfer pricing
SAP conducts transactions between its group companies on an arm’s length basis and in
accordance with OECD principles and local requirements in the respective countries where
SAP conducts business. Hence, SAP pays corresponding amounts of tax according to where
value is created and where appropriate economic activities are performed and does not
engage in the artificial shift of profits and value created to low-tax jurisdictions.
6. Management of tax risks
Given the scale of our business, the volume of tax obligations as well as the conflicting fiscal
policies and tax laws, risks will inevitably arise from time to time. SAP’s appetite for tax risk is
low. We therefore seek to minimize tax risks by proactively and continuously identifying,
managing, monitoring and reducing these risks, with an emphasis on seeking opinions from
© 2025 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions
related to this material.
tax authorities (including Advance Pricing Agreements) to mitigate risks related to transfer
pricing disputes. This also implies taking into account other business risks, including SAP’s
wider reputation and the relationship with our stakeholders. Where possible, the identified
risks are evaluated with regard to their potential impact and likelihood of occurrence. SAP’s
tax risk management is consistent with and embedded in our general approach to risk
management. We account for these risks as appropriate in our audited group financial
statements in accordance with the applicable accounting standards and our group policies.
For detailed information on the basic elements of the Control and Risk Management System,
including the risk management processes and risk factors, please refer to our Global Risk
Management Organization section in SAP Integrated Report 2024, published annually.
We implement tax management measures including controls over compliance processes and
monitor their effectiveness. Prior to carrying out significant transactions, we consider the tax
consequences and may consult with external advisors on the tax implications of a potential
transaction based on an assessment of the risk presented by each transaction. New and
increased regulatory requirements, updated or new enforcement trends, and publicly
available information on compliance issues are continuously observed.
7. Tax planning
In conducting our commercial activities, we consider, among other commercial factors, the
tax laws of the countries within which we operate with a view to maximizing value on a
sustainable basis for our shareholders. Any tax planning and optimization activities
undertaken are compliant with tax laws, supported by commercial and economic substance
and will have regard to sustaining a credible long-term reputation with the tax authorities and
our stakeholders. Despite its global presence, SAP operates in very few countries that are
considered non-cooperative jurisdictions and tax havens. SAP defines non-cooperative
jurisdictions by aligning with internationally recognized lists, such as the EU non-cooperative
tax jurisdictions list (‘blacklist’). While any presence in such jurisdictions is driven by sound
commercial business reasons and economic substance, we closely monitor and re-evaluate
such business reasons against general geo-political risks, including tax risk, on a regular basis,
and may adjust our business activities accordingly. To protect SAP’s reputation, we will not
undertake planning that is contrived or artificial. If entities in these jurisdictions become part
of the SAP Group through an acquisition, we will look to liquidate the respective entities as
soon as reasonably possible.
www.sap.com Copyright/Trademark
related to this material.
tax authorities (including Advance Pricing Agreements) to mitigate risks related to transfer
pricing disputes. This also implies taking into account other business risks, including SAP’s
wider reputation and the relationship with our stakeholders. Where possible, the identified
risks are evaluated with regard to their potential impact and likelihood of occurrence. SAP’s
tax risk management is consistent with and embedded in our general approach to risk
management. We account for these risks as appropriate in our audited group financial
statements in accordance with the applicable accounting standards and our group policies.
For detailed information on the basic elements of the Control and Risk Management System,
including the risk management processes and risk factors, please refer to our Global Risk
Management Organization section in SAP Integrated Report 2024, published annually.
We implement tax management measures including controls over compliance processes and
monitor their effectiveness. Prior to carrying out significant transactions, we consider the tax
consequences and may consult with external advisors on the tax implications of a potential
transaction based on an assessment of the risk presented by each transaction. New and
increased regulatory requirements, updated or new enforcement trends, and publicly
available information on compliance issues are continuously observed.
7. Tax planning
In conducting our commercial activities, we consider, among other commercial factors, the
tax laws of the countries within which we operate with a view to maximizing value on a
sustainable basis for our shareholders. Any tax planning and optimization activities
undertaken are compliant with tax laws, supported by commercial and economic substance
and will have regard to sustaining a credible long-term reputation with the tax authorities and
our stakeholders. Despite its global presence, SAP operates in very few countries that are
considered non-cooperative jurisdictions and tax havens. SAP defines non-cooperative
jurisdictions by aligning with internationally recognized lists, such as the EU non-cooperative
tax jurisdictions list (‘blacklist’). While any presence in such jurisdictions is driven by sound
commercial business reasons and economic substance, we closely monitor and re-evaluate
such business reasons against general geo-political risks, including tax risk, on a regular basis,
and may adjust our business activities accordingly. To protect SAP’s reputation, we will not
undertake planning that is contrived or artificial. If entities in these jurisdictions become part
of the SAP Group through an acquisition, we will look to liquidate the respective entities as
soon as reasonably possible.
www.sap.com Copyright/Trademark