Templates and records · UNE 19602
UNE 19602 tax compliance policy template
The governing body’s commitment to tax compliance: how much tax risk the company is prepared to take on and how it organises itself to stay within that limit.
In one sentence
The tax compliance policy is the document approved by the governing body that sets out the commitment to meeting tax obligations and preventing tax offences, the tax risk appetite, the role of the tax compliance body and the route for reporting irregularities; UNE 19602 requires it to be approved by the governing body and aimed at minimising exposure to tax risks.
- Type of information
- Mandatory document Document required by UNE 19602, approved by the governing body
- Who fills it in
- Governing body Approves it; the tax compliance body drafts it with the finance department
- When
- When the system is implemented Reviewed annually or after changes in strategy, structure or legislation
- How long it is kept
- Current and earlier versions They show since when the commitment existed, which matters if events from past years are being judged
What the standard requires
What UNE 19602 demands and what it leaves to your judgement
The standard calls for a policy approved by the governing body that expresses the commitment to meeting tax obligations and minimising exposure to tax risks, and that is communicated within the organisation and to relevant interested parties.
What separates a useful policy from a generic statement is that it sets the tolerance: what kind of tax planning is considered acceptable, when the tax authority is consulted, which transactions need board approval.
It can be a chapter of the general ISO 37301 compliance policy, provided it covers what UNE 19602 asks for and is approved by the governing body.
Structure
Fields the template should include
- Scope: companies, taxes and territories
- Commitment to compliance and to preventing tax offences
- Tax risk tolerance and transactions requiring approval
- Tax compliance body: duties, autonomy and resources
- Relationship with the tax authority
- Channel for reporting irregularities and prohibition of retaliation
- Consequences of non-compliance
- Approval: body, date and version
Example
Example: extract from a distributor’s policy
Company, people and figures are fictitious: the example only shows what a properly completed record looks like.
| Field | Content |
|---|---|
| Scope | Comercial Duero (fictitious) and its logistics subsidiary · all national and local taxes |
| Commitment | Meet tax obligations on time and on reasonable criteria, and take no part in transactions lacking economic substance |
| Tolerance | Any transaction with a tax effect above €100,000 or involving low-tax jurisdictions requires board approval |
| Body | Tax compliance committee: the finance director and an external adviser, reporting directly to the board |
| Channel | The company’s existing whistleblowing channel, with a “tax” category |
| Approval | Board of directors, 25 February 2026 · v1 |
At the audit
Mistakes auditors commonly flag
- It is approved by the finance department rather than the governing body.
- A generic statement with no risk tolerance and no transactions subject to approval.
- It does not refer to any channel for reporting tax irregularities.
- It is not communicated to finance staff or to the external adviser.
In Kimobox
How this record is kept in Kimobox
- 1The tax compliance policy is published as a controlled document.
- 2It is communicated to the people concerned through the employee portal, with read confirmation.
- 3Each version keeps its approval and earlier versions remain accessible.
Frequently asked questions
What people ask us before getting started
Can it be the same as the general compliance policy?
Yes, if it includes a tax chapter covering what UNE 19602 asks for and is approved by the governing body. What will not do is a general policy that never mentions tax risk.
Does it have to be published?
It must be available to relevant interested parties. Many companies publish it on their website as a sign of tax transparency.
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Sources
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- UNE 19602:2019 — Sistemas de gestión de compliance tributario. Requisitos con orientación para su uso (Tax compliance management systems. Requirements with guidance for use) UNE, Spanish Association for Standardisation · February 2019
- Ley Orgánica 10/1995, Código Penal (Spanish Criminal Code), arts. 31 bis and 305 BOE-A-1995-25444 · Consolidated text