Tax Function Evolution for Executives
Tax Function Evolution for Executives
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This is the second part in a thought leadership The global predictions cover six main areas:
series exploring our predictions for the Tax
Function of the Future. In our first piece, 1. Global legislative and regulatory landscape
we outlined our predictions concerning the 2. Tax function’s role in risk management
new challenges facing the tax function and and governance
why they (and other) functions will have to
adapt to remain relevant. This piece focuses 3. Data flow into the tax function
specifically on our predictions relating to global
4. Technology automation for tax function
tax legislation and regulation as well as risk
analytical tasks
management and how legislative and regulatory
change will mandate transformation. 5. Tax function roles and processes
6. The tax professional of the future.
For more information on our predictions for
the Tax Function of the Future, follow the link
below to see the first publication in our series.
www.pwc.com/taxfunctionofthefuture
What potential impact might What should I be thinking plan to expand their tax function capabilities,
I face? about now and what are the integrate new reporting requirements, and
opportunities? provide the business case for operational
We expect base-line tax administration and investments. While risk and compliance
other compliance burdens to expand, audits to Companies should think creatively and obligations may be the main drivers for change,
increase, and there to be enhanced controversy strategically to address these risks while there may be several positive benefits to reap
creating the potential for increased and double proactively engaging with their broader along the way such as management having
taxation. More pressure will be placed on tax organisation and potentially the public. Now is greater real-time insight due to enhanced access
functions to better manage tax and related the time for companies to create a multi-year to information.
risks by strengthening the control environment
that governs reporting processes. Overall,
the tax function will need to expand its core
capabilities relating to data, people, and
technology. In addition, due to the potential It is unclear what legislation the United States will enact going
business and reputational risks associated with
many transparency initiatives, the tax function forward relating to transparency and the broader BEPS initiatives.
will need to be more engaged with the C-suite But companies should not undertake actions simply based on
stakeholders about such issues.
their home country laws. Other countries have broader and more
divergent agendas and will continue to seek more disclosure
from multinationals.
— Dave Camp, Former Chairman of the House Committee on Ways and Means
and now PwC Senior Policy Advisor
Some companies may view CbCR as another compliance activity that could be outsourced to a third party. However, the nature
of the data being gathered and validated demands the continued and time-intensive involvement of companies themselves. A dry
run will bring to light the amount of time and the resources required in the data gathering process—a key step that is difficult to
outsource to a third party.
Notwithstanding CbCR, there are other imminent Examples of tasks to perform now to help manage
difficulties for taxpayers relating to BEPS: these concerns—all requiring technological and
analytical capability:
• Ensure proper reporting of the company’s profitability and value
chain profile • Engage in a value contribution analysis—review the core competencies
• Pressure on historical single-sided tests for transfer pricing purposes, of the organisation, its competitors globally, and where profits are
such as the comparable profits method and transactional net generated as compared with those competencies
margin method • Bolster global transfer pricing documentation to meet evolving
• Strong bias toward disregarding the role of capital and risk in favor requirements—consider a single documentation source that is used
of people functions and the use of profit-split methods for transfer worldwide, along with a technology solution to enable consolidation of
pricing purposes data, collaboration, tracking of responsibilities, and document storage
• Tax authority assertions regarding the existence of local intangibles • Strengthen the tracking of mobile employees to help manage PE risks,
that would attract income leveraging technology tools rather than manual methods to capture
data more efficiently
• Increased risks of re-characterisation and permanent establishment
(PE) income attribution
• Changes to financing rules requiring companies to rethink their
financing strategy
Companies should analyse whatever perception or Shell believes that greater transparency about the
substantive gaps exist between their stated core values payments we make can help build trust between
and overall tax strategy and disclosures, as well as
our business and the communities where we
identify opportunities to highlight overall contributions—
Tip including all tax payments—to society. Companies may work. This is the fourth consecutive year that
also want to consider consistency between communication Shell is voluntarily publishing tax payments. In
strategies, e.g. if the business is publishing their 2014, this amounted to over $90 billion.
sustainability strategy, companies should understand
— Simon Henry, CFO, Royal Dutch Shell plc.
how it could impact their tax strategy.
10 Global tax transparency and risk management
Let’s dig deeper
Enhanced focus on reconciliation As a large, global company we are familiar with the level of
Taxing jurisdictions will be able to share scrutiny applied by tax authorities around the world regarding tax
more detailed tax data with each other as disclosures. We welcome a globally consistent, standard approach
transparency initiatives increase. As a result,
taxpayers must be able to reconcile information to the reporting of revenues, profit and income taxes paid. However,
between external, consolidated financial, tax, there will always be variances between jurisdictions in terms of
and local statutory reporting. They must also
demonstrate that new filings (such as CbCR) are how they interpret global requirements, which leads to additional
accurate and consistent on a global basis. compliance costs and potential for increased disputes and double
For organisations that have decentralised taxation where the data is inconsistent.
management or multiple ERPs (or varying
instances of the same ERP) more effort may —Ross Lyons, Global Head of Tax, Rio Tinto
be required to gather the data and test it for
accuracy, both at the time of filing and when
an audit arises. To address this problem,
documentation of end-to-end processes should The need for ongoing The data needed for ongoing analytics is often
be undertaken to identify information technology analytics capability not easily accessible, requiring tax functions
investments that will be needed (e.g. a data hub to spend significant time and effort manually
Transparency initiatives are mandating that gathering and manipulating data for reporting
to efficiently gather, store, consolidate, reconcile
companies engage in more ongoing review needs. However, today’s technology and data
and report this information).
and analysis. CbCR is only one of three parts of analytics capabilities provide a variety of options
the new OECD guidelines for transfer pricing to improve reporting and documentation, enable
documentation delivered under BEPS Action 13. greater control and access to information, and
The Master File and Local File should be viewed harness creative ways to make sense of large
as critical companion reports to the CbCR volumes of information.
template and need to be updated on a regular
basis to ensure consistency and accuracy. Tax
authorities will be looking to these documents
to rationalise the results under CbCR as a
starting point for transfer pricing audits.
13 Global tax transparency and risk management
Let’s dig deeper
Predictions
Many jurisdictions will legislatively require the adoption of a tax control framework which follows guidelines similar to Sarbanes-Oxley and the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Growing reliance on tax control The global transparency trend is not necessarily just a one-way
frameworks to manage tax risk street for tax authorities to reap the benefits. Tax functions can
The emphasis on tax control frameworks in leverage voluntary disclosure initiatives like co-operative compliance
helping companies manage tax risk is gaining
momentum globally. The Australian Tax Office arrangements to gain greater certainty and reduce their own
recently stated that the presence of a robust tax administrative burden. Under such programs the taxpayer needs to
control framework will be taken into account
when determining a company’s risk-assessment
be able to confirm by means of a tax control framework, that tax risks
score. Other recent developments include so- are appropriately managed and information and returns submitted
called horizontal monitoring in the Netherlands are accurate and complete.
and the Senior Accounting Officer regime in
the UK. These changes enable tax authorities —Eelco van der Enden, PwC partner and Global Tax Administration
to give more attention to those taxpayers that
Consulting Leader
are deemed higher risk. As a consequence,
more companies outside the United States are
reviewing their internal controls relating to key
tax processes (akin to Sarbanes Oxley in the
United States). This review is not just relating to
corporate income taxes, but all taxes.
Understanding where you are and Understanding how the tax function relies on Capitalise on the opportunity for
where you need to be, along with a other functional groups (and vice versa) is also a change—set the stage for success
detailed plan to arrive there key input to the roadmap to drive solutions that
streamline the full end-to-end processes of the With foundational change comes opportunity to
Tax transparency and increased regulatory tax function. And, the level and need for change right-fit, right-size, and invest strategically, thus
burdens should be catalysts for change. will vary depending on the nature and number setting up the tax function to be more flexible,
Although other factors may be present, these of regulatory obligations (e.g. some industries agile, and responsive as the tax environment
trends are pushing companies to re-examine may be treated differently such as mining and continues to evolve. Identifying and planning
how they are managing tax matters. Most financial services). for efficiencies and opportunities that can be
companies acknowledge that the status quo in achieved will help measure the potential returns
their current tax and supporting governance on upfront costs in technology, process, and
functions is not an option; at the same time, resourcing improvements.
many remain unsure as to how to tackle the
emerging challenges.
Formulating a detailed, realistic, and We see the broad impact transparency initiatives have on the tax
customised transformation roadmap is the function, but more importantly also on the wider organisation.
first step—and begins with a full assessment
of the company’s current state through a Tax is increasingly being embedded in the business and needs to be
gap assessment. This detailed analysis of approached more and more holistically with a broadly supported tax
the tax function’s capabilities, strengths and
weaknesses, and risks relating to governance, awareness throughout the organisation as a basic requirement. Said
process, technology, people, and legal entity initiatives (e.g. CbCR) will, as a positive spin off, expedite this process.
structure, is a critical tool to identify needed
operational improvement, existing risks, and —Niels Tromp, Head of Tax, ARCADIS
how to manage them.
Tax functions should focus on the broader benefits of responding to new challenges by evolving
into a more strategic contributor to the business. It’s an opportunity to further enhance the tax
function’s stature within the organisation by using technology, information, and capacity for
analytics to contribute to the overall corporate vision and business strategy.
Global legislative and regulatory • Strategic focus on jurisdictional reporting • The vast majority of tax functions will rely
landscape and documentation of business activities, on professional data analysis tools to assist in
including transfer pricing, will be critical the decision-making process in areas such as
• Global tax information reporting requirements to managing the increased tax controversy detection of risk, opportunity identification,
(e.g. CbCR and similar transparency initiatives) resulting from transparency initiatives. projections and scenario planning, and overall
will grow exponentially and will have a business support.
material impact on the operations and related Data flow into the tax function
budget allocations within the tax function. Tax function roles and processes
• Regulators will demand transparency • The majority of tax functions will receive all
regarding global taxation, necessitating clear information in a ‘tax-ready format’ from either • Most global tax preparatory compliance and
and thoughtful communications with public their enterprise-wide financial systems or a reporting activities, including data collection
stakeholders about corporate contributions to dedicated tax data hub. and reconciliations, will be performed within
the communities in which they do business. • Dedicated tax data hubs will become the company’s shared service center or will be
mainstream and be developed internally, co-sourced with a third party.
• Information sharing will be commonplace
among taxing jurisdictions, and taxing licensed from a third-party vendor, and/or • Tax functions will use real-time collaboration
authorities will have the capability to mine accessed through an accounting firm as part of tools to automate their workflow, document
data and conduct global audits, resulting in a co-sourcing arrangement. management, calendaring, and internal
increased disputes. • Data security will be high on the agenda of tax controls.
functions due to concerns over confidential
Tax function’s role in risk management information being inadvertently released or The tax professional of the future
and governance shared publicly. • A successful tax professional of the future
• Many jurisdictions will legislatively require will be highly proficient in data analysis,
Technology automation for tax function statistics, and technology, as well as process
the adoption of a tax control framework analytical tasks
which follows guidelines similar to Sarbanes- improvement and change management.
Oxley and COSO (Committee of Sponsoring • More companies will use their enterprise-wide • Tax functions will employ dedicated tax IT,
Organizations of the Treadway Commission). financial systems to prepare tax calculations data and project management specialists who
• Enhanced stakeholder scrutiny and (e.g. income tax accounting and indirect will develop, champion, and execute the tax
reputational risk will force companies to taxes), thereby replacing spreadsheets and/or technology and transformation strategies.
continuously re-evaluate their tax decisions. traditional tax technology solutions.
To have a deeper conversation about how these issues and predictions may affect
you and your business, please contact:
Andrew Wiggins Joaquín Latorre
Michael Shehab Global Tax Accounting Socio de PwC Tax & Legal Services
US Tax Reporting & Services Leader [email protected]
Strategy Leader [email protected] +34 915 684 418
[email protected] +44 (0)121 232 2065
+1 (313) 394 6183
Santiago Barrenechea
Carsten Rössel Socio de PwC Tax Legal Services
Global Tax Reporting & Tax Reporting & Strategy
Global Tax Reporting & Compliance Leader [email protected]
Strategy Leader [email protected] +34 915 684 406
+49 211 981-7141
+44 (0)20 7212 2527
Francisco González Fernández-Mellado
Eelco van der Enden Director de PwC Tax & Legal Services
Giovanni Bracco Global Tax Administration Tax Reporting & Strategy
Global Tax Strategy & Consulting Leader [email protected]
Operations Leader [email protected] +34 915 685 532
[email protected] +31 (0)88 792 5138
+44 (0)20 7804 4059
Todd Bixby
Global Tax Technology Leader
[email protected]
+1 (612) 240 1602
www.pwc.com/taxfunctionofthefuture
This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.
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