what should I fill in when asked about transparent tax policy

Tax transparency: aggressive planning and country-by-country

The customer is asking here whether the undertaking has a conscious, documented position on tax planning, and whether it is willing to report on this per country in which it operates. It concerns three sub-questions that are often nested together in a single question: (1) is there an internal document that describes the tax policy, (2) does the undertaking avoid structures that are primarily designed to evade taxes, and (3) does it publish or share data on profit, tax and activities per country (country-by-country reporting). For an SME without an international structure, the answer is usually straightforward: there is no separate policy document, and there are no cross-border structures to clarify. That is a valid answer, but it must be entered as such — not as "yes" in the absence of evidence.

If the undertaking does have establishments or subsidiaries in multiple countries, the question becomes more concrete: some customers want to know whether intercompany rates have been set on an arm's length basis, or whether use is made of low-tax jurisdictions without genuine economic activity. That is a different kind of question than for example the policy against bribery and corruption, but is often placed side by side in the same questionnaire because both fall under "good governance". If a formal tax policy is lacking, then "no, not yet documented" is a more honest answer than a YES without supporting documentation.

Where this comes from: the VSME baseline module and the CSRD

The question about transparent tax policy comes from the governance indicators of the VSME baseline module of EFRAG, the voluntary reporting standard for non-listed SMEs, and aligns with the broader reporting obligations that Directive (EU) 2022/2464 (CSRD) introduces for larger chain partners. Larger buyers that themselves report under the CSRD translate those governance requirements to their own suppliers through questionnaires like these — similar to how they also ask about an internal whistleblower reporting procedure. A formal tax declaration or country-by-country report is not a legal obligation for most SMEs; the question in the list therefore goes beyond what the law requires, and the answer may reflect that difference.