Question ID: 2098
Regulation Reference: Guidelines on reporting and public disclosure
Topic: Public Disclosure
Article: 35
Template: S.25.02
Status: Final
Date of submission: 08 Jan 2020
Question
One of the undertakings under our supervision has a question regarding filling out the new template for LACDT information (S.25.02). The issue is that they take into account subsidiary companies (e.g. the undertaking may apply carry back to the taxes that the subsidiary companies have paid in the past) to substantiate their LACDT calculations, whereas the scope of the QRTs is exclusive of subsidiary undertakings. Their question: should they fill out the S.25.02 template according to how they substantiate LACDT or in line with the scope of the rest of the QRTs? In practice, the first option would result in two different DTAs.
EIOPA answer
The DTA and the DTL reported in the new tables of S.25 templates (R0600 to R0630) should only include the amount of the undertaking itself, i.e. exclude any amount from its subsidiaries. However, the information on the justification of LACDT (i.e. C0130) should be reported considering the real substantiation of LACDT, which may take into account subsidiary undertakings.