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
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".
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.