Companies are facing numerous challenges in complying with the requirements put upon them. Conditions are becoming ever more complex – particularly those to do with tax. Complying with all the legislation and regulations is a critical goal. The requirements on organising tax are growing at the same rate as the requirements of tax compliance. One thing is certain: things are getting more complex — and will continue to do so. We support our clients with implementing a tax CMS based on the practice notes of the Institute of Public Auditors in Germany [Institut der Wirtschaftsprüfer in Deutschland e.V. (IDW)] on designing and auditing tax CMSs under the German standard IDW PS 980.

We focus on the following items for tax CMS:

Comparison of the tax risks necessary to achieve tax compliance targets and the steps the company has taken in response, as part of:

  • an analysis of current status
  • developing a plan of target status and
  • support with implementation.

We focus on ways to technically support the tax CMS, particularly in the area of documenting the implementation of measures and controls. 

With process documentation, we support the integration of already existing processes and the defining of new processes and controls to be implemented from scratch. We will be glad to model these according to the BPMN 2.0 standard. Using our extensive process library makes process modelling more efficient.

We give you assistance in developing an implementation plan, from the status quo to the target structure, always keeping in mind which digitalisation solutions to select. We realise that it’s important to our clients to be able to operationalise their tax CMS without incurring disruptions. We will gladly assist you with selecting tools.

The tax CMS should be designed in such a way that it can be used as the indicator that an internal tax control system is functional. It should be possible to prove that an error in a tax return was not made intentionally or through negligence.

We observe the following requirements on tax compliance management systems:

  • The CMS description as the basis for the tax CMS
  • The basic attitude and behaviours of management (‘tone from the top and tone from the middle’)
  • Information on taxes in the code of conduct

Defining the major tax goals taking account of the company’s main objectives

  • Roles and responsibilities of the tax risk owners and other stakeholders
  • Structure and process organisation
  • Resource planning/rules on representation

Identification of significant tax risks to the company/group

Defining measures and controls to minimise risk based on the tax risks identified

  • Procedural controls
  • Automated controls
  • Detective controls
  • Informing employees and any third parties concerned about the tax compliance programme and about roles and responsibilities
  • Defining a channel to report identified tax risks, breaches of rules and tip-offs
  • Implementing monitoring, control and reporting processes
  • Documentation of monitoring
  • Continual review of the TCMS to make improvements

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