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Basel III and banking

supervision: taxes
are of capital
H. de Gunst


Erik de Gunst*

Basel III and Banking Supervision:

Taxes Are of Capital Importance
Few will have missed that capital requirements
for banks have been tightened significantly in
response to the financial crisis. The new rules
are contained in what is called Basel III. Capital
Requirements Directive IV implements Basel
III in the EU. The rules are very detailed and
have a dramatic impact on banks. Among other
things, banks will be required to increase the
level of their capital and improve the quality
thereof. Although tax plays an important role in
this, it has received very little attention to date.
This article discusses the role of taxes and their
impact on banks capital.
1. Introduction
In December 2010, the Basel Committee on Banking
Supervision (BCBS) released the Basel III Rules text, 1 containing new minimum requirements for solvency, leverage
and liquidity of banks. The members of the BCBS have all
committed themselves to the implementation of Basel III
in their home country legislation. In 2010, during their
Seoul meeting, the G20 also declared strong support for
Basel III.
Capital Requirements Directive IV implements Basel III
in EU legislation. In July 2011, the European Commission published a draft of this Directive. This Directive s
legislative package consists of a directly applicable regulation (Capital Requirements Regulation, CRR) and a directive, Capital Requirements Directive IV (CRD IV). The
new solvency requirements are contained in the Capital
Requirements Regulation. This is an important departure
from current rules which were in the form of a directive
that needed to be implemented in national legislation in
order to take effect.
Originally, the Capital Requirements Regulation was
scheduled to enter into force on 1 January 2013. At the
time of writing this article (February 2013), negotiations
were still ongoing and the January start date was missed.
The current expectation is that the Capital Requirements
Regulation will be finalized by mid-2013, implying that
the new rules would not take effect until 1 January 2014.2

Executive Director, Ernst & Young Financial Services Group,

Amsterdam. The author can be contacted by telephone at
+31(0)621252685 or by email at or


Basel III: A global framework for more resilient banks and banking
systems, available at
See e.g. website of the Dutch Central Bank (DNB),
publicatie/publicaties-dnb/nieuwsbrief-banken/nieuwsbrief-bankendecember-2012/dnb282757.jsp. In Nov. 2012, US regulators already




It is unclear what the impact of this delay will be on the

transitional rules and phase-in/out rules (see below) contained in the Capital Requirements Regulation. For purposes of this article, a 1 January 2013 start date is assumed,
with the caveat that the different dates/periods might be
moved forward one year (assuming a 2014 start).
2. New Capital Requirements: Higher Common
Equity Tier 1 Capital
One of the changes is that banks will have to increase their
capital levels. As its predecessors, Basel III applies an 8%
minimum capital ratio.3 This means that a bank must have
at least 8% qualifying capital. The 8% refers to the total
risk weighted assets (RWA) of the institution and not to its
balance sheet total. Risks can vary per balance sheet item
which is why not all assets are attributed the same risk
weight in determining minimum required capital levels;
different classes of assets can have different risk weights.
Unlike the current rules, Basel III provides that minimum
capital must be comprised of at least 6% of RWA of Tier
1 capital.4 The remaining 2% may consist of Tier 2.5 An
institution s Tier 1 capital consists of Common Equity
Tier 1 (CET1) and Additional Tier 1 capital. Briefly, CET1
capital is made up of ordinary share capital, share premium
and profit reserves.6 Tier 1 capital must consist of at least
4.5% of RWA of CET1 (currently only 2.5%).
Basel III provides for a phase-in of the CET1 capital
increases. With a 1 January 2013 start date, the 4.5% CET1
and the 6% Tier 1 thresholds need not be reached until
2015. For 2013, the minimum level is set at 3.5% and 4.5%
of RWA, respectively. In 2014, these are increased to 4%
and 4.5%, respectively.7
3. New Capital Requirements: Improved Quality
of CET1 Capital
Basel III also requires an improvement in the quality of
CET1 capital.


decided to delay the introduction of Basel III (without giving any

indication as to the extent of the delay).
Para. 50 Basel III Rules; art. 87(1) draft Capital Requirements Regulation
Art. 24 draft CRR.
The CRR introduces two additional buffers (both in the form of CET1
capital): the capital conservation buffer (2.5% of RWA) and a variable
countercyclical capital buffer (maximum of 2.5% of RWA). Separately,
additional capital requirements will apply for systemically important
banks, ranging from 1% to 2.5% of RWA. Finally, in 2011, the European
Banking Authority (EBA) published a list of European banks required to
maintain a minimum temporary buffer of 9% to deal with the financial


Basel III and Banking Supervision: Taxes Are of Capital Importance

Generally, the starting point in determining the regulatory

capital of a bank is the IFRS financial accounts.8 In some
instances, adjustments are made to the numbers contained
in these financial accounts. These are so-called prudential filters and deductions which remove or reduce certain
elements considered undesired in the determination of a
bank s regulatory capital.
Basel III and the Capital Requirements Regulation introduce a considerable number of deductions from CET1.
The reason for this is that the items that are deducted are
of very little or no value to a bank in a stress situation.
Continued inclusion of these items would inflate the size
of the bank s capital, thereby leading the outside world to
believe that the institution is in better shape than it truly is.
Article 33 of the draft Capital Requirements Regulation
lists (most of) the deductions from CET1 capital. This discussion focuses on the deduction related to deferred tax
4. Different Types of Deferred Tax Assets
Article 22(9) of the draft Capital Requirements Regulation provides that the term deferred tax assets must be
interpreted on the basis of the applicable accounting standard. For banks reporting under IFRS, this would be IAS
12 (Income Taxes).
A distinction can be made between: (i) deferred tax assets
for deductible temporary differences, (ii) deferred tax
assets for tax loss carry-forwards and (iii) deferred tax
assets relating to tax credits that may be carried forward.
Temporary differences arise where assets and liabilities
are valued differently for accounting and tax purposes.
It is possible to have (i) deferred tax liability (the temporary differences mean a higher future tax liability) or
(ii) a deferred tax asset (less tax will be due in future). An
example is the difference between tax and accounting
depreciation of a fixed asset. Where the depreciation for
tax purposes is less, this results in a deductible temporary
difference, for which a deferred tax asset can be created. If
it is higher, this means a taxable temporary difference and
the inclusion of a deferred tax liability on the balance sheet.
Under current rules, deferred tax assets for tax loss carryforwards count fully towards bank regulatory capital. It is
questionable whether this is justified. How much value can
actually be attributed to a deferred tax asset for loss carryforwards if a bank is close to going under and it needs to
have adequate capital levels to pull through? At that point,
presumably it will not be earning taxable profits at a high
enough level to offset the existing losses. Does the deferred
tax asset then have a real value and does its (full) inclusion
in capital not paint an overly rosy picture of the size of the
bank s regulatory capital?9


Art. 4(53) draft CRR.

See Mirror, mirror on the wall, who has the highest DTAs of all?, Financial
Times (21 July 2011); Tax Assets: Here Today, Gone Tomorrow, The Wall
Street Journal (10 Apr. 2010); Want to boost tier one capital? Make losses
and prosper, Financial Times (9 Dec. 2011).


4.1. Deferred tax assets that rely on future profitability

Basel III and the Capital Requirements Regulation have
recognized this and determine that these types of deferred
tax assets must be removed in full from CET1 capital to
determine its true size.10,11
Article 22(10) of the draft Capital Requirements Regulation defines deferred tax assets that rely on future profitability as deferred tax assets the future value of which may
be realized in the event the institution generates taxable
profit in the future, the prime example of these being
deferred tax assets for loss carry-forwards.
Introduction as from 1 January 2013 would not have
meant that the deduction for these types of deferred tax
assets occurs in full and immediately. Basel III and the
Capital Requirements Regulation provide for a transitional period, allowing for a phasing in of the deduction.
In 2013, no deduction would be required.12 In 2014, at least
20% must be deducted; in 2015, at least 40%; in 2016, at
least 60% and in 2017 at least 80%. Full deduction will be
required from 2018 onwards. Article 453(4) of the draft
Capital Requirements Regulation provides that the residual deferred tax asset amount that is yet to be deducted is
awarded a 0% risk weight during the transitional phase.
4.2. Deferred tax assets that rely on future profitability
and arise from temporary differences
An example of these types of deferred tax assets is deferred
tax assets resulting from a lower rate of depreciation for
tax purposes compared to financial accounting.
Deferred tax assets arising from temporary differences are,
in principle, included in full in CET1 capital and are not
deducted unless they exceed a certain threshold.13 Firstly,
these deferred tax assets must remain below 10% of CET1
capital;14 any excess must be deducted from CET1 capital.
In addition, they may not exceed 15% of CET1 capital
when taken together with another specific deduction from
CET1 capital.15 Again, any excess must be deducted from
CET1 capital.
Deferred tax assets that remain below the combined
threshold are attributed a 250% risk weight (contrast this
with the 0% risk weight generally applicable to receivables
from EU governments).16 The increased 250% risk weighting applies immediately from the date of introduction of
the Capital Requirements Regulation.



Para. 69 Basel III Rules.

Art. 33(1)(c) draft CRR.
A national regulator does have the ability to already require a deduction
in 2013. The UK regulator, the FSA, has announced that it will do so: in
2013 (this was on the basis of the CRR applying as from 1 January 2013),
UK banks are required to already deduct 10% of the relevant deferred tax
Art. 45 draft CRR.
This is the CET1 capital reduced by various other mandatory deductions
from capital, and after considering prudential filters.
This deduction is the deduction for significant interests of the bank in
other financial institutions (art. 33(1) draft CRR).
Art. 109(4) draft CRR.



Erik de Gunst

Source: European Banking Authority, Results of the Basel III monitoring exercise based on data as of 31 December 2011, available at

4.3. Tax overpayments, tax loss carry-backs and

deferred tax assets that do not rely on future
Article 36 draft Capital Requirements Regulation provides
that banks are not required to deduct overpayments of tax
for the current year and tax loss carry-backs from capital.17
Furthermore, article 36(3) of the draft Capital Requirements Regulation provides that deferred tax assets that do
not rely on future profitability are limited to deferred tax
assets arising from temporary differences, provided that
the following requirements are satisfied:
(1) the deferred tax assets are immediately replaced with
a tax credit in the event that the bank reports a loss
in its financial statements or in the event of liquidation or insolvency;
(2) under applicable national tax laws, the bank is able to
offset this tax credit against any (type of) tax liability
of its own or of an entity that is included in the same
tax consolidation; and
(3) where the tax credits exceed the tax liabilities mentioned under (2), any excess is replaced with a direct
claim on the government of the Member State in
which the institution is incorporated. This receivable
is attributed a risk weight of 100%.18
The origin of this provision can be found in new rules
introduced in Italy in 2012. To date, no other EU country
has introduced the same or similar legislation.
4.4. Deferred tax assets and deferred tax liabilities
The deduction from CET1 capital for deferred tax assets
relying on future profitability is limited to a net amount.
Provided that certain requirements are satisfied, associated deferred tax liabilities may first be set-off against these

deferred tax assets, with only the remainder deducted from

CET1. The netting requirements contained in the Capital
Requirements Regulation correspond to those in IAS 12:
the entity has the legally enforceable right under
applicable national law to set off the relevant current
tax assets against current tax liabilities; and
the relevant deferred tax assets and the deferred tax
liabilities relate to income taxes levied by the same tax
authority and on the same taxable entity.19
The manner in which deferred tax liabilities are set off
against existing deferred tax assets is described in specific
rules unique to the Capital Requirements Regulation (and
not included in IAS 12). This implies that any previous
netting for financial accounting purposes would have to be
undone, in order to calculate the netting under the Capital
Requirements Regulation. Particularly for large international banks, this might be a considerable exercise which
would also need to be repeated regularly.
Netting under the Capital Requirements Regulation takes
place as follows:
the deferred tax liabilities that may be netted against
existing deferred tax assets must first be reduced by
deferred tax liabilities relating to (i) intangible assets
(including goodwill) or (ii) defined benefit pension
fund assets.20 Both are separately listed deductions
from CET1 capital, and for both only the net amount
would need to be deducted, i.e. reduced by the amount
of associated deferred tax liabilities;21 and
the remaining deferred tax liabilities are allocated
proportionally to (i) deferred tax assets arising from
temporary differences which need not be deducted
from CET1 capital (below the 10%/15% combined
threshold) and (ii) all other deferred tax assets that
rely on future profitability.22
5. Impact on Banks CET1 Capital Levels




Art. 36(2)(a) and (b) draft CRR. The most recent draft CRR, which can be
found on the website of the European Parliament (www.europarl.europa.
eu), provides for a new paragraph (d), which describes a deferred tax asset
scenario that is also not considered to rely on future profitability. The
author s understanding is that this is one of over 2,000 amendments that
have come out of discussions with the European Parliament, and that it is
uncertain whether this amendment will be approved. Further discussion
of this issue is beyond the scope of this article.
It is uncertain whether this 100% RWA will survive (see supra n. 17).


The table above was taken from a recent report of the European Banking Authority.

Art. 35(3) draft CRR.

Art. 35(4) draft CRR.
Arts. 34 and 38 draft CRR.
Art. 35(5) draft CRR.


Basel III and Banking Supervision: Taxes Are of Capital Importance

Every six months, the European Banking Authority investigates the expected impact of Basel III on European banks.
The distinction between Group 1 and Group 2 banks is
made based on their size, with Group 1 banks being the
bigger banks. For the first category of banks, the expected
deductions from 100 CET1 capital are 34.6. Of this amount,
5 relates to deferred tax assets relying on future profitability (3.5 plus 1.5). Excess above 15% also includes deferred
tax assets, but how much is not clear. Tax (netting) is also of
importance in relation to goodwill and intangibles, and
also under Other to the extent this relates to the deduction for defined benefit pension fund assets. Essentially,
this means that tax is one of the more important deductions from CET1 capital coming out of Basel III.
The gradual phased-in introduction of the deduction
for deferred tax assets for tax loss carry-forwards, might
lead some banks to not giving this aspect the attention
it deserves, the view being that existing losses would be
recovered before a full deduction must be made in 2018.
However, the financial crisis is continuing much longer
than originally expected and it is questionable whether
sufficient profits will be realized in the coming years to
make up for the existing losses, and indeed in the current
climate, there is a real chance of the losses increasing rather
than decreasing, exacerbating the problem.
Furthermore, the market has shown little interest in the
phasing-in aspect of Basel III. The expectation is that
banks show the impact of an integral introduction of Basel
III. Banks are also releasing figures distinguishing between
Basel III phase-in and Basel III fully loaded, as if Basel
III had entered into force fully on 1 January 2013.23 Some
banks have also publicly announced their intention to be
fully Basel III compliant as from 1 January 2013.
Also, if phasing-in is considered, a partial deduction of say
60% of deferred tax assets in 2016 could already have a significant detrimental impact, with the bank being required
to have increased its minimum CET1 capital level to 4.5%
of RWA.
Finally, the increased 250% risk weight for deferred tax
assets arising from temporary differences (not deducted
because below 10%/15% threshold) could have a negative impact. As mentioned, this increased risk weighting
applies immediately from the date the new rules enter
into force; banks will be required to maintain more CET1
capital against this.24
6. Some Areas of Attention for Dutch Banks
Basel III is a global effort. The Capital Requirements Regulation and Capital Requirements Directive IV form the
implementation of Basel III at the EU level. By contrast,
tax still very much operates at a local level. Each individual

E.g. 2011 Annual Accounts of ABN AMRO.

The following is also significant. Over the next few years, banks will
face many changes in relation to financial accounting. This accounting
change will directly impact the capital levels of banks. It may also lead
to increased capital volatility. As a result, there may also be (dramatic)
swings in the 10%/15% threshold, which could impact the deduction for
deferred tax assets from CET1.


country applies its own local tax rules to determine the tax
implications of the different aspects of the new regulatory
rules. An example is the different tax treatment afforded to
the payment of coupons on new Additional Tier 1 instruments. Some countries allow banks to deduct these payments for local corporate income tax purposes, while
others do not. And there are countries such as the Netherlands which have yet to formulate policy on this issue.
The following are a few examples of how Dutch banks
could be affected by the new rules relating to deferred tax
assets and deferred tax liabilities. Banks in other jurisdictions may face similar issues.
Consider a Dutch bank with a foreign permanent establishment, which incurred losses in years before 2012.
If deferred tax assets were formed locally at the branch
level, these would, in principle, be fully deductible from
the bank s CET1 capital (albeit with the five-year phasein). Where these branch losses were deducted from Dutch
taxable profits, the Netherlands imposes a mandatory
recapture rule, implying that no exemption would be
given from Dutch corporate income tax under the Dutch
double tax relief system, for future profits coming out of the
branch. Relief would not become available until after the
losses previously deducted from the bank s Dutch taxable
profits had been recaptured in full. The Netherlands introduced a new double tax relief system for branch results in
2012. This new system is more territorial based, removing the possibility for permanent establishment losses to
be deducted from Dutch taxable profits at the head office
level. However, as a transitional measure, the recapture rule
for pre-2012 losses has remained in place.25 Generally, the
Dutch bank will have recorded a deferred tax liability in
relation to the possible future recapture. With deferred tax
asset being a future receivable on the tax authorities of the
jurisdiction where the permanent establishment is situated on the one hand, and the deferred tax liability being
a future liability towards the Dutch tax authorities on the
other, netting as described above will not be possible. As
a result, the deferred tax asset would be deducted in full
from the bank s CET1 capital.
Another area that is affected concerns tax consolidations
(fiscal unities in the Netherlands) existing between banks
and non-banks, e.g. insurers. The question involves how to
deal with intra-group (tax) receivables, tax set-offs and socalled tax sharing agreements. What if differences exist
between tax consolidation and consolidation for financial
accounting purposes? Dutch domestic accounting guidelines (Richtlijnen voor de Jaarverslaggeving) provide some
guidance for the allocation of taxes within fiscal unities,
but leave many questions unanswered.
Finally, many Dutch banks have concluded IFRS agreements with the Dutch tax authorities under which they
have agreed that the measurement of financial instruments for accounting purposes is determinative for their
tax measurement. However, this is not always the case, and


Art. 33b Dutch Corporate Income Tax Act 1969.



Erik de Gunst

there are a few important exceptions. How do the new regulatory capital requirements affect these agreements?
7. Improvement of CET1 Capital Ratios
A bank can improve its CET1 capital ratio by increasing
CET1 capital or by reducing RWA. Currently, they do both.
Profits are retained and cost reduction programmes are
carried out. There are share/rights issues (although limited
due to their comparatively expensive nature and dilutioneffect for existing shareholders). Banks are also attempting
to reduce balance sheet totals through disinvestments and
reduced lending. Risk weighting is also actively managed,
e.g. by transferring certain risks to insurers or other nonregulated institutions, such as hedge funds.26 Another
option is reducing or mitigating the mandatory deductions from CET1 capital of which deferred tax assets
are one.
Given the impact that deferred tax assets could have on the
size of a bank s qualifying CET1 capital and the impetus
for increased capital levels, a critical and detailed analysis by banks of their deferred tax asset and deferred tax
liability positions could help improve CET1 levels. This
would be cheaper and easier to achieve compared to, say,
issuing new shares. Also, improved netting could ensure
that more deferred tax liabilities are set off against deferred
tax assets for loss carry-forwards, thus reducing the deduction from CET1 capital. Deferred tax liability positions
would need to be analysed in (minute) detail to achieve
optimal netting.
A possibility is also to accelerate income recognition for
tax purposes. In the Netherlands, this has also received
some recent attention as a means to prevent the expiration of loss carry-forwards.27 An existing tax loss could
be set off against accelerated profits (profit reserves). The
deferred tax asset recognized in the bank s accounts disappears and may be replaced with a deferred tax asset arising
from temporary differences. As a result, deferred tax assets
are no longer deducted from CET1 capital, that is provided
and for as long as the combined 10%/15% threshold is not
There are other ways in which to optimize a bank s
deferred tax asset position for regulatory purposes,
without this reaching the level of tax planning. Rather,
what is required is a granular analysis of the deferred tax
asset/deferred tax liability positions of a bank. In particular, banks with foreign subsidiaries or operating abroad
through branches should analyse their foreign tax positions, more so if foreign tax consolidations are in place or
local netting has occurred.
8. Regulatory Reporting: Common Reporting
Banks are required to periodically file reports about their
solvency position, on both a solo and consolidated basis.

Common reporting (COREP) is the standardized reporting framework issued by the European Banking Authority
for Capital Requirements Directive reporting.28 Common
reporting has been in existence since 2005/2006, when it
was introduced by the Committee of European Banking
Supervisors (CEBS), the predecessor of the European
Banking Authority. Member States had the option to
implement common reporting or not, or only partially.
The Netherlands more or less introduced a full version of
common reporting. Germany implemented the best part
of common reporting, as well. By contrast, the United
Kingdom implemented only a very small part.
These differences in common reporting within the European Union will come to an end. As with the Capital
Requirements Regulation, the new common reporting
will take the form of a regulation, and there will be one
set of reporting rules applicable throughout the European
Union. The new common reporting will embed the new
capital requirements for banks as contained in the Capital
Requirements Regulation.
The European Banking Authority has been tasked with
drafting so-called Implementing Technical Standards.29
In December 2011, it published a consultation document
for the Implementing Technical Standards which describes
in detail what must be reported, the frequency of reporting and the format to be used. The Implementing Technical Standards also provide for a large number of templates which must be completed by banks, including one
relating to taxes.30 Once these Standards have been finalized, they will be mandatory for all EU banks; the Standards will also be in the form of a regulation. The intended
commencement date of the new common reporting was
1 January 2013, the same as for the Capital Requirements
Regulation, implying first submission for Q1 2013 in May
2013. The delay in the introduction of the Regulation will
also have an impact on the start date of the new common
reporting. When it will eventually start will become clear
as soon as the Capital Requirements Regulation has been
The amount of data that will need to be submitted, is
substantial and significantly more than that currently
required. The level of detail has also increased compared
to current regulatory reporting. Reporting will be required
each quarter, semi-annually and annually, within 30 business days of the end of the respective period.
The increased importance of taxes and deferred tax assets
in Basel III and the Capital Requirements Regulation
means a significant increase in the tax information that
must be provided to regulators. Because of the potential
adverse impact of existing deferred tax assets on the size
of banks CET1 capital, banks will not be able to escape
the provision of detailed tax information. The expectation
is that regulators will increasingly be scrutinizing banks



Jamie Dimon, CEO of JPMorgan Chase, announced during an earnings

call in Oct. 2012 that he intended to manage the hell out of RWA to
improve his bank s capital position.
Decree of Dutch Deputy Minister of Finance (16 Feb. 2012), BLKB
2012/8M, Stcrt. 2012, 3804, V-N 2012/14.15.



The discussion here concerns Financial Reporting for banks to the

regulator, FINREP.
Art. 95(2) draft CRR.
Consultation paper on draft Implementing Technical Standards on
supervisory reporting requirements for institutions (CP 50), (London,
20 Dec. 2011).


Basel III and Banking Supervision: Taxes Are of Capital Importance

tax positions. The information submitted must therefore

be correct, thought-through and supported by data. The
Implementing Technical Standards require that changes

and mistakes in information already submitted be rectified as soon as possible.

9. Conclusion
The global introduction of Basel III will have a
dramatic impact on banks. Business models are under
pressure. Banks are shedding non-core businesses.
Almost on a daily basis, newspapers feature articles
about the impact of the new rules. Banks are looking
at ways to reduce capital utilization of activities.
Activities are streamlined and/or scaled back when
capital utilization is considered too intense compared
to the activities profitability and profit potential going
forward. Banks are attempting to reduce RWA to
improve capital ratios.

The increased importance of taxes and deferred tax

assets in particular means that taxes can also play a
role in improving ratios (or in any event preventing
an adverse effect on CET1 levels). Getting a grip on
and optimizing the local (and global) deferred tax
asset/deferred tax liability position of banks can have
a positive impact on their CET1 capital and, as a
consequence, CET1 ratio. This makes taxes of capital
importance to banks.


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Is verbonden aan
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Verschenen in:
Derivatives & Financial Instruments 2013 nr. 2
March/April 2013. - p. 42-47,
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Basel III and banking supervision: taxes are of capital importance / H. de Gunst. Derivatives & Financial Instruments 2013 nr. 2