Question ID
2018_3783
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Accounting and auditing
Article
473a
Paragraph
7
Subparagraph
b
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
n/a
Type of submitter
Competent authority
Subject matter
Calculation of the sf factor as per Article 473a(7)(b) of Regulation (EU) No 575/2013 (CRR)
Question

Please clarify whether "RAsa" which is used for the calculation of the “sf” factor, as per Article 473a(7)(b) of the CRR, should be gross or net of tax

Background on the question

In the definitions of Article 473a(7)(b) of the CRR, although it is specified that the numerator of "ABsa" should be calculated in accordance with point (a) of the second subparagraph of paragraph 1 [i.e. reduced by the amount of “t”, which is the increase in CET1 due to tax deductibility of the amounts "A2sa" and "A4sa", no such information is provided for the denominator "RAsa".

Submission date
Final publishing date
Final answer

The requirements for the calculation of amount RAsa under Article 473a(7)(b) of Regulation (EU) No 575/2013  (CRR) do not require the calculation to be performed net of tax effects (which is explicitly the case for ABsa. In particular, when adjustments for tax effects are required elsewhere in Article 473a of the CRR, this is explicitly mentioned in the CRR. Furthermore, calculating the amounts RAsa for the purposes of paragraph 7(b) gross of tax is in line with the calculation of specific credit adjustments.

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.
Note to Q&A

Update 26.03.2021: This Q&A has not yet been reviewed by the EBA in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR).

Update 28.10.2021: This Q&A has been reviewed in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR) and continues to be relevant.

Disclaimer

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