Integrate fiscal integrity into your SIRA

Financial institutions including banks, pension funds, insurers and trust offices, are by law required to implement a Systematic Integrity Risk Analysis (‘SIRA’). DNB supervises financial institutions on the design and implementation of the SIRA. Part of this SIRA, also the tax integrity risks tax evasion and tax avoidance have to be managed. Not only for the own organisation but also with respect to clients, products and services, locations, suppliers and more. DNB provides the risk based approach but leaves it to the financial institutions to determine which tax integrity risks are within their tax risk appetite and therefore acceptable. This is complex: not only relevant (inter)national tax regulations, but also stakeholder views and the (sustainable) business strategy of the financial institution have to be taken into account.

Tax integrity risks have to be identified in a systematic way and actively managed in key processes like the client due diligence and transaction monitoring processes. The integration of tax integrity in these processes is a careful exercise, as it requires tax, risk and compliance expertise to ensure control in an efficient and effective manner.

How we can help you

With our extensive experience in this field, we can help you to safeguard sound business conduct and integrate tax integrity in your existing SIRA framework in a practical manner. Services could include:

  • Design of a tax integrity policy that includes your tax integrity norm and risk appetite

  • Perform a tax risk analysis and assessment and design tax risk criteria

  • Support with the optimization or set-up of procedures, processes, controls, guidance and work papers

  • Support with analysis of complex tax cases based on your tax integrity policy

  • Support to improve tax awareness within your organization

  • Determine the effectiveness of your SIRA for tax integrity and support with the development of the monitoring of your SIRA for tax integrity

  • Assistance with the determination of your internal and external tax reporting requirements and help you to transparently communicate on your approach in line with your tax integrity policy;

  • Help with the design and deployment of technology, for record keeping, automation of processes and advanced data analytics. 


Remco van der Linden

Remco van der Linden

Partner, member Tax & Legal board, PwC Netherlands

Tel: +31 (0)62 040 22 91

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Gerwin Naber

Gerwin Naber

Partner, PwC Netherlands

Tel: +31 (0)65 150 75 75

Thomas Rijneveld

Thomas Rijneveld

Partner, PwC Netherlands

Tel: +31 (0)88 792 51 20