Tax Strategy and Taxes

Generali contributes significantly to the development and financial stability of the countries where it operates, covering a key role in a period where governments pursue the balance between growth and welfare.

The Group’s Italian and foreign Companies pay income tax based on the rates and taxation rules set by the laws of each country.

The impact of taxation (-3,5 p.p.) is mainly due to the positive effect of extraordinary one off tax settlements in Italy and in Germany, to the one off effect on DTL stock following the expected reduction of CIT in Germany (starting from 2028) and to the lower impact of net non-deductible charges.

Since 2016, a Tax Control Framework has been implemented for detecting, measuring, managing and controlling the tax risks. Currently (FY2025), the framework applies to the 26 Italian Companies (4 insurance Companies, 2 Companies from the real estate field, 3 Companies from banking and investment field and 17 Companies from the service field) and 3 Branch of AG.

Starting from FY2019, some main foreign Companies have set up a similar tax risk management system. Currently (FY2025) 31 foreign Companies belonging to the following countries are included in our Framework: Germany, France, Austria, The Netherlands, Spain, Czech Republic, Portugal and Hong Kong.

The framework of the Companies that adopt the TCF is constantly evolving through the gradual extension to the main Italian and foreign Companies of the Group, which will continue in 2026.

The Tax Risk Management activities, with the aim of ensuring a correct implementation of the TCF, include four phases:

• Management of the Risk & Control Matrix;
• Monitoring Plan;
• Tax Risk Assessment;
• Testing activities.

The Group has an internal regulatory framework that governs the activities relating to the TCF in detail. This regulatory framework is constantly being updated.

The framework is not yet mandatory for Italian companies and is part of OECD’s (Organization for Economic Co-operation and Development) Cooperative Compliance. Its aim is to ensure the correct identification and appropriate control of tax risks through an approach based on an analysis that cuts across various corporate processes, in order to prevent or mitigate the risk of breaching tax regulations.

Please note that the Group Company which have officially joined the Cooperative Compliance programme with the Italian Tax Authority are:

• Assicurazioni Generali S.p.A. (starting from FY2020)
• Banca Generali (starting from dal FY2020)
• Genertel S.p.A (starting from FY2020)
• Generali Italia S.p.A. (starting from FY2021)
• Generali Investments Holding S.p.A. (starting from FY2021)
• Generali Real Estate S.p.A (starting from FY2021)
• Alleanza Assicurazioni S.p.A (starting from FY2022)
• Generali Asset Management SGR S.p.A. (starting from FY2022)
• Generali Operations Service Platform S.r.l. (starting from FY2023)
• Europ Assistance Italia S.p.A. (starting from FY2023)
• Europ Assistance Vai S.p.A. (starting from FY2023)
• Europ Assistance Trade S.p.A. (starting from FY2023)
• Lion River I N.V. (starting from FY2024)