Tax Strategy – Deutsche Bank

Show content of Introduction

The bank considers that the following statements comply with Deutsche Bank AG’s obligations under paragraph 16(2) of schedule 19 of the UK Finance Act 2016 to publish a tax strategy for 2026 and provide supplementary tax information.

Deutsche Bank’s Code of Conduct is the foundation upon which the bank builds its purpose. It sets out the standards of behavior and conduct, to which the bank and all of its employees are expected to adhere. Consistent with these standards, the bank has clear principles of conduct and behavior as they relate to the bank’s tax affairs and a framework setting out roles and responsibilities among the various functions for defined tax types to ensure that the bank remains compliant with its tax obligations.

In keeping with this purpose, the bank applies the principles set out in this document in the management of its tax affairs. These tax principles, which are embedded in the bank’s control framework, are approved by the Management Board and apply to all its businesses and group entities.

The key principles are:

Deutsche Bank undertakes its tax affairs on a basis which generates sustainable value while meeting applicable legal and regulatory tax requirements.

Deutsche Bank gives due regard to the intent and spirit of tax laws, the social context within which the bank operates, and the bank’s standing and reputation with the public, tax administrations, regulators, and political representatives.

Show content of Approach to tax risk management and governance

Under Deutsche Bank’s risk management framework, organizational structures follow the Three Lines of Defense model with a clear definition of roles and responsibilities for all risk types.

The bank’s tax affairs are managed by the in-house tax function, which is an independent risk and control function separate to the business divisions. The Global Head of Tax, who leads the in-house tax function, has a direct reporting line into the Chief Financial Officer.

The bank’s in-house tax function manages the bank’s tax affairs consistent with its tax principles on a basis which protects Deutsche Bank’s reputation and brand. It employs skilled professionals to ensure that the bank’s position with respect to its own tax matters is robust. In appropriate situations the bank’s internal experts may take specialist external tax advice. In addition, the in-house tax function monitors developments and legislative changes and the bank routinely updates its tax strategy and related policies and procedures in response.

The bank does not provide tax advice to clients. The tax principles embedded in the bank’s new product approval process stipulate that transactions with clients are to be conducted on the basis that clients comply with relevant tax laws and reporting requirements. The bank also expects the same from third parties providing services to the bank or on the bank’s behalf.

Show content of Attitude towards tax planning

Deutsche Bank manages its tax affairs in a way which aims to ensure that the tax consequences of business operations are appropriately aligned with the economic, regulatory and commercial consequences of those business operations, with due regard being given to the potential perspective of the relevant tax authorities.

In conducting its business affairs, setting up and structuring its business operations and commercial activities, the bank considers – among other factors – the tax requirements of the respective jurisdictions in which it operates, with a view to generating sustainable value to Deutsche Bank and its shareholders. In this context the bank may seek to avail itself of tax benefits and beneficial tax rates available under those tax laws. Uncommercial artificial steps for the purpose of obtaining tax benefits are not to be undertaken. In addition, the bank does not endorse confidentiality arrangements which seek to preclude disclosure or reporting to tax authorities nor does it endorse success fee arrangements determined by the amount or existence of tax benefits.

As a matter of principle, Deutsche Bank reports its profits in the countries in which they are generated. This means that profits are also taxed in accordance with applicable tax rules in those countries. Intercompany transactions are undertaken on an arm’s length basis in accordance with internationally accepted OECD transfer pricing principles, giving due consideration to applicable local rules and requirements.

Show content of Level of risk

The bank is subject to tax-related risks, which is an inherent consequence of the scale and diversity of Deutsche Bank’s business activities and the international nature of the bank’s business. This is exacerbated by the growing complexity of international tax laws and divergent approach of national tax authorities in various instances. The bank seeks to understand and mitigate risks where possible. It operates a control framework which ensures that it is compliant in all material aspects with applicable tax laws, files accurate tax returns, and pays the amount of tax due.

Show content of Relationships with tax authorities

Deutsche Bank aims for its dealings with tax authorities to be undertaken in a proactive, transparent, professional, courteous and timely manner and seeks to develop and foster good working relationships with tax authorities.

Show content of Preventing tax evasion

Tax evasion, which is a financial crime, is illegal and goes against Deutsche Bank’s culture. The bank’s policies strictly prohibit aiding or abetting tax evasion. Anti-Financial Crime acts as the independent second line function and sets respective policy and control standards to manage financial crime risks, including the facilitation of tax evasion. For further information see 2025 Annual Report, p. 370, (Sustainability Statement, Anti-financial crime - Prevention of money laundering, terrorist financing, and facilitation of tax evasion).

Show content of Supplementary Tax Information

EU Non-Cooperative Jurisdictions

On February 14, 2023, the Council of the EU added Russia to the list of non-cooperative jurisdictions for tax purposes effective for the tax years beginning January 1, 2024. The bank does not anticipate material implications for Deutsche Bank and its Russian operations.

OECD Base Erosion and Profit Shifting Agenda

The bank is impacted by changes in the principles of international taxation emanating from the OECD's Base Erosion and Profit Shifting agenda. On December 20, 2021, the OECD issued model rules for a global minimum tax under Pillar 2, the Global Anti-Base Erosion Model Rules. These model rules create an internationally coordinated system of taxation intended to ensure that multinational enterprises pay a minimum level of tax of 15% in each jurisdiction in which they operate. The EU implemented these model rules via a directive. The provisions under the EU directive were transposed into German law (“Mindeststeuergesetz” or “MinStG”). The Pillar 2 rules are generally effective for tax years beginning after December 30, 2023. Pillar 2 global information reports and respective tax returns for 2024 are generally due in June 2026. To the extent applicable, Deutsche Bank AG must remit a Pillar 2 liability calculated for a jurisdiction to the German tax authorities, unless that jurisdiction enacts its own set of Pillar 2 rules. Of the close to 60 countries in which the bank operates, approximately 70% have enacted or are in the process of enacting their own set of Pillar 2 rules. The bank has estimated the potential impact on its financial position on a best effort basis and recognized a Pillar 2 related current tax expense of € 3 million for 2025. For further details see 2025 Annual Report, p. 551, (Note 34 – Income Taxes).

Country-by-Country Reporting

Details on the bank’s international operations are provided in Deutsche Bank’s 2025 Notes to the consolidated financial statements, which disclose the income tax expense or benefit in the jurisdictions in which the bank operates; see 2025 Annual Report, p. 577, (Note 43 – Country by country reporting). For information on the domicile of the companies, names and their primary activities please refer to the shareholdings list (see 2025 Annual Report, p. 579, (Note 44 – Shareholdings)). The geographical location of subsidiaries and branches considers the country of incorporation or residence.

To enhance the understanding of the country-by-country reporting, the following explanatory information is provided. The country-by-country information reported is derived from the IFRS Group accounts of Deutsche Bank. It is, however, not directly reconcilable to other financial information in the Annual Report because of specific guidance published by the Bundesbank on December 16, 2014, which includes the requirement to present the country information prior to the elimination of cross-border intragroup transactions. In line with this requirement, only intragroup transactions within the same country are eliminated. As an example, the dividend income received by a group entity in country x from a subsidiary in country y is not included in the IFRS Group accounts, as these are eliminated in consolidation. However, they are included in and reported in the results of country x in the country-by-country reporting. As a matter of principle such intra-group dividend income is generally tax-exempt in most jurisdictions to avoid double or multiple layers of taxation. Accordingly, these specific reporting requirements can have a significant impact on the jurisdictional effective tax rate shown in the country-by-country reporting, which may differ from the country’s statutory tax rate. Moreover, the disclosed income tax expense or benefit may also reflect various other adjustments required by tax law, e.g., non-tax-deductible expenses or tax-exempt income.

2025 Total Income Tax Expense and Income Taxes Paid

In 2025, Deutsche Bank’s total income tax expense amounted to € 2.6 billion (see 2025 Annual Report, p. 425, Consolidated Statement of Income as well as Note 34 – Income Taxes, p. 551) and income taxes paid during 2025 amounted to € 1.4 billion in the year 2025 (see 2025 Annual Report, p. 429, Consolidated Statement of Cash Flows).