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I’ve written before about the increasing importance of having a solid technology base for a company’s tax function, and it’s important enough for me to revisit the topic. Tax departments are entrusted with a highly sensitive and essential task in their companies. Taxes usually are the second largest corporate expense, after salaries and wages. Failure to understand this liability is expensive – either because taxes are overpaid or because of fines and interest levied for underpayment. Moreover, taxes remain a political issue, and corporations – especially larger ones – must be mindful of the reputational implications of their tax liabilities.
In this context of seriousness, there are five interrelated requirements for the work that tax departments do:
- The work must be absolutely accurate.
- Corporate and tax executives must be certain that the numbers are right – instilling confidence is key.
- Certainty depends on transparency: Source data and calculations must be demonstrably accurate, and any questions about the numbers must be answerable without delay.
- Speed is critical. All department tasks related to tax planning, analysis and provisioning can become sources of delay in core finance department processes. Being able to quickly execute data collection and calculations allows more time to explore the results and consider alternatives.
- Control of the process is essential. Only particular trustworthy individuals can be permitted to access systems, perform tasks and check results. Control promotes accuracy, certainty and transparency.
These requirements form the basis of a business case for a tax data warehouse. Properly executed, it promotes all of these qualities. However, our forthcoming benchmark research on the Office of Finance shows that not many corporations have adopted one. Rather, most companies rely mainly or entirely on spreadsheets for provisioning income tax: managing data, calculations and modeling. More than half (52%) of companies use spreadsheets alone to handle income taxes while just 10 percent use a dedicated application designed for that purpose. Desktop spreadsheets are a poor choice for managing taxes since they are error-prone, lack transparency, are difficult to use for data aggregation, lack controls and have little ability to handle more than a few dimensions at a time. To deal with these deficiencies companies have to spend more time than they should in assembling data, making calculations, checking for errors and creating reports.
There are strong reasons to change this reliance on inappropriate tools. One is that more companies must deal with an increasingly complex tax environment. Despite decades of talk about simplifying the tax code in the United States, it has grown ever more intricate. For those with a long memory, there was some simplification in the 1980s, but since then complexity has returned with a vengeance. Moreover, as corporations grow and expand internationally, their legal entity structure becomes more multifaceted, and their source systems for collecting and managing tax data can become fragmented. Unless the tax function is completely centralized, companies that operate in more than a handful of tax jurisdictions can find it hard to coordinate their tax data, calculations and processes. Centralization is not a cure-all, either, as the lack of local presence poses its own issues in tax management in coordinating with local operations and finance organizations.
Another reason is that national taxing authorities are beginning to improve their coordination with one another, which means that tax departments will have to deal with increasing complexity in reporting and a more stringent compliance environment. In 2013, the Organization for Economic Cooperation and Development (OECD) published a report titled “Action Plan on Base Erosion and Profit Shifting”, which describes the challenges national governments face in enforcing taxation in an increasingly global environment with a growing share of digital commerce. The OECD also is providing a forum for member governments to take action (including collective action) to strengthen their tax collection capabilities. Although the process of increased government coordination is likely to take years to unfold, the outcome almost certainly will be to put additional pressure on companies that have legal entities domiciled in multiple countries. The impact is likely to mean longer and more frequent audits (including concurrent audits by multiple tax authorities) with more detailed requests for information. Increased data sharing among tax authorities will make it even more critical that the tax data – and all the minutiae of adjustments, reconciliations and year-to-year permanent changes – be absolutely accurate, consistent and readily available.
In addition, governments worldwide are increasing their electronic collection of tax data. This enables them to improve scrutiny of tax returns by applying analytic techniques that highlight errors and discrepancies as well as to identify suspicious activities or potentially aggressive tax treatments. Eliminating paper forms allows tax authorities to require even more data from companies. In this environment, having accurate, consistent data becomes essential. Having time to consider the best tax-related options thus becomes even more valuable.
In this increasingly complex and demanding environment it is good news that technology, such as a tax data warehouse, has advanced to become feasible and affordable for the kinds of organizations that can benefit most from it. A tax data warehouse addresses all of the needs of a tax department listed above. A single source of data minimizes errors and ensures consistency. It also promotes transparency, especially when used in conjunction with a dedicated direct tax management application. Because it is possible to exactly recreate the assumptions, data and methods used and because the data and the calculations are consistent, the answer to “where did that number come from” can be found quickly and with complete assurance. The process is better controlled, access to the records and application is more secure, and the entire process is much more easily audited than when working with spreadsheets. Since all of the numbers and assumptions are kept intact and readily available, an audit defense can be performed with less effort and greater confidence. In addition, the ability to create multiple scenarios with different assumptions and treatments enables tax and legal departments to determine the best approach for the company’s risk tolerance. The financial impact of these benefits can be considerable because most companies that operate in multiple direct (income) tax jurisdictions spend considerable amounts of time gathering and assembling data manually. As noted, they often use spreadsheets – sometimes dozens or even hundreds of them – for tax calculations and data storage. These spreadsheet-based systems are built on a weak foundation because of the data issues inherent when there are multiple systems of record and inconsistent data-related processes.
The evolving tax environment means that tax departments must be in the mainstream of finance organizations. Our research on the financial close finds that a majority of finance executives do not know how long it takes for the tax department to complete quarterly tax calculations. Executives who are not tax professionals usually do not appreciate the important difference between finance and tax data requirements. Corporations are constantly changing their organizational structure as well as acquiring and divesting business units. As these events occur, accounting and management reporting systems adapt to the changes both in the current as well as past periods. Tax data, on the other hand, must be stable. Legal obligations to pay taxes are based on facts as they exist in specific legal entities operating in a specific tax jurisdiction in a specific period. From a tax authority’s standpoint, these facts never change even as operating structures and ownership evolve. Audit defense requires a corporation to assemble the facts and related calculations, sometimes years after the fact. A general finance data warehouse does not deliver this capability because it is not – and for all practical purposes cannot be – structured to satisfy the needs of a tax department, particularly those that operate in multiple jurisdictions.
To ensure accuracy and inspire confidence in the products of the tax department’s work, it important for tax departments to tightly control the end-to-end process of taking numbers from source systems, constructing tax financial statements, calculating taxes owed and keeping track of cumulative amounts and other balance sheet items related to taxes. Transparency is the natural result of a controlled process which uses a single set of all relevant tax data. A readily accessible authoritative data set makes tax department operations more efficient. Reducing the time and effort to execute the tax department’s core functions frees up the time of tax professionals for more useful analysis. In a more challenging tax-levying environment, having tax data and tax calculations that are immediately traceable, reproducible and permanently accessible provides company executives with greater certainty and reduces the risk of noncompliance and the attendant costs and reputation issues. Having an accurate and consistent tax data warehouse of record provides corporations and their tax departments with the ability to better execute tax planning, provisioning and compliance.
Robert Kugel – SVP Research
Tagetik provides financial performance management software. One particularly useful aspect of its suite is the Collaborative Disclosure Management (CDM). CDM addresses an important need in finance departments, which routinely generate highly formatted documents that combine words and numbers. Often these documents are assembled by contributors outside of the finance department; human resources, facilities, legal and corporate groups are the most common. The data used in these reports almost always come from multiple sources – not just enterprise systems such as ERP and financial consolidation software but also individual spreadsheets and databases that collect and store nonfinancial data (such as information about leased facilities, executive compensation, fixed assets, acquisitions and corporate actions). Until recently, these reports were almost always cobbled together manually – a painstaking process made even more time-consuming by the need to double-check the documents for accuracy and consistency. The adoption of a more automated approach was driven by the requirement imposed several years ago by United States Securities and Exchange Commission (SEC) that companies tag their required periodic disclosure filings using eXtensible Business Reporting Language (XBRL), which I have written about. This mandate created a tipping point in the workload, making the manual approach infeasible for a large number of companies and motivating them to adopt tools to automate the process. Although disclosure filings were the initial impetus to acquire collaborative disclosure management software, companies have found it useful for generating a range of formatted periodic reports that combine text and data, including board books (internal documents for senior executives and members of the board of directors), highly formatted periodic internal reports and filings with nonfinancial regulators or lien holders.
Tagetik’s Collaborative Disclosure Management automates the document creation process, eliminating many repetitive, mechanical functions and reducing the time needed to administer the process and ensure accuracy. Automation can shorten finance processes significantly. For example, our benchmark research on trends in developing the fast, clean close finds that companies that use little or no automation in their accounting close take almost twice as long to complete the process as those that fully automate it (9.1 days vs. 5.7 days). Manually assembling the narrative text from perhaps dozens of contributors and combining it with data used in tables and elsewhere in the document is a time-consuming chore. Regulatory filings are legal documents that must be completely accurate and conform to mandated presentation styles. They require careful review to ensure accuracy and completeness. Complicating this effort recently are increasingly stringent deadlines, especially in the U.S. Anyone who has been a party to these efforts knows that there can be frequent changes in the narratives and presentation of the numbers as they are reviewed by different parties, and those responsible need to ensure that any change to a number that occurs is automatically reflected everywhere that amount is cited in the document; to use the depreciation and amortization figure as an example, that would include the statement of cash flows, income statement, the text of the management discussion and analysis and the text or tables of one or more footnotes. Moreover, automated systems afford greater control over the data used. They make it possible to answer the common question of where a number came from quickly and with complete assurance. While inaccuracies in other types of financial documents may not have legal consequences, mistakes can have reputational or financial consequences.
Those managing the process also spend a great deal of energy simply checking the document to ensure that the various sections include the latest wording, that the numbers are consistent in the tables and text, that amounts have been rounded properly (which can be really complicated) and that the right people have signed off on every part of the filing. Automation obviates the need for much of these tasks. Tagetik’s CDM workflow-enables the process, so handoffs are automated, participants get alerts if they haven’t completed their steps in timely fashion, and administrators can keep track of where everyone is in the process. Workflow also promotes consistent execution of the process, and the workflows can be easily modified as needed.
In designing Collaborative Disclosure Management, Tagetik took advantage of users’ widespread familiarity with Microsoft Excel and Word to reduce the amount of training required to use its product. CDM’s workflow design makes it relatively easy for business users to define and modify business process automation. Typically, individuals or small groups work on different sections of the document. CDM enables multiple contributors from finance, accounting, legal, corporate and other functions to work with their part of the document without being concerned about other contributors’ versions. Work can proceed smoothly, and those administering the process can see at any time which components have been completed, are in progress or have not even started. Tagetik’s software can cut the time required to prepare any periodic document, since once a company has configured its system to create what is in effect a template, it’s relatively easy to generate these documents on monthly, quarterly or annual bases. The numbers relevant to the current period are updated from the specified controlled sources, and references to tabular data within the text are automatically adjusted to tie back to these new figures. Often a large percentage of the narrative text is boilerplate that either must not be updated or requires only limited editing to reflect new information. Starting with the previous edition of the report, contributors can quickly mark up a revised version, and reviewers can focus only on what has changed. Other important automation features are data validation, which reduces errors and revisions, and the system’s ability to round numbers using the appropriate statutory methodology.
CDM also handles XBRL tagging, which is essential for all SEC documents and necessary for an increasing number of regulatory filings around the world. The software specifically handles tagging for the two main European prudential regulatory filings for banks and other credit extending institutions, COREP (Common Reporting related to capital) and FINREP (Financial Reporting performed in a consistent fashion across multiple countries).
Companies can gain several key benefits by automating the production of their periodic regulatory filings and internal or external financial reports that combine text and data. One of the most important is time. Automation can substantially reduce the time that highly trained and well-compensated people spend on mechanical tasks (freeing them to do more productive things), and the process can be completed sooner. Having the basic work completed sooner gives senior executives and outside directors more time to review the document before it must be filed or made public. Time that can be devoted to considering how best to polish the narratives or if necessary lengthen upstream deadlines to handle last-minute developments and consider options for how best to treat accounting events. Automation can also reduce the chance of errors, since the numbers tie directly back to the source systems and (if properly configured) ensure that references in the narratives and footnotes to items in tables and the numbers in those table agree completely. Restatements of financial reports caused by errors are relatively rare but when they occur are exceptionally costly for public companies’ reputations.
Disclosure management systems are an essential component for any financial performance management (FPM) system. All midsize and larger corporations should be using this software to automate the production of their periodic mandated filings and other documents that combine text and data. They will find that they are useful in cutting the time and effort required to produce these documents, provide senior executives and directors more time to review and craft the final versions, and reduce the chance of errors in the process. Companies that are using older FPM software should investigate replacing it with an FPM suite to gain the additional capabilities – including disclosure management – that newer suites offer. Tagetik’s should be among the financial systems evaluated for office of finance.
Robert Kugel – SVP Research