You are currently browsing the tag archive for the ‘GRC’ tag.
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
Longview Solutions has a longstanding presence in the financial performance management (FPM) software market and was rated a Hot vendor in our most recent FPM Value Index. Several years ago it began offering a tax provision and planning application. I think it’s worthwhile to focus on the tax category because it’s less well known than others in finance and is an engine of growth for Longview. We expect larger corporations increasingly to adopt software to manage direct (income) taxes to improve the quality and efficiency of what today in most companies is an inefficient, spreadsheet-driven process.
Longview’s tax offering consists of four main components. Its Tax Data Platform can be the central repository of a corporation’s tax information. I’ve commented on the need to maintain tax data separate from the data that’s used for financial reporting, managerial accounting and performance management. One reason is that tax accounting must be aligned with legal entities, not corporate organizational structures, because direct taxes are levied on legal entities, not corporate divisions or reporting hierarchies. A second is that tax data must be held in an “as was” state, without regard to subsequent corporate actions such as acquisitions and divestitures or management reorganizations. Longview’s Tax Data Collection software consolidates book and tax data from disparate source systems; it is designed to automate and streamline the movement of data and eliminate time-consuming manual work. It can do consolidations in different, parallel paths if dissimilar methods of consolidating tax-related data are required by the statutes of individual taxing authorities. The Tax Provision/Reporting component performs global tax accounting and reporting. And Tax Planning supports a company’s analysis and planning of its taxes.
Software vendors are taking two different approaches to dedicated tax management software. One mostly focuses on the needs of the finance department: It automates and simplifies incorporation of already calculated tax data into the financial consolidation and close process. This is useful for companies that operate in up to a handful of tax jurisdictions and have relatively simple legal entity structures. The other approach addresses the needs of the tax department as well as the rest of the finance organization. Longview’s tax offering falls into the latter category because it provides the functionality and data-handling capabilities that tax departments need to streamline their operations, enhance their ability to manage tax expenses and improve senior executives’ understanding of tax exposures and strategies to deal with them.
Longview’s tax software can replace desktop spreadsheets, which are the most common tool used for direct tax provisioning and planning in companies of all sizes. Spreadsheets are the wrong choice for managing taxes because they are so time-consuming. Tax departments use them to make often complex tax calculations, manage tax data and direct tax processes – these are tasks that dedicated software can handle easily but spreadsheets cannot. They are not well equipped to do these tasks quickly and accurately on a consistent basis. Consequently, facing looming deadlines, tax departments have little if any time left over to analyze and plan tax exposure and tax expense options more broadly and more intelligently. Spreadsheets also do not provide sufficient transparency or forward visibility in a timely fashion in the way that a dedicated system can. Spreadsheets make it difficult for companies to manage their tax risk exposure in a consistent fashion across all business units. They do not give executives sufficient insight into their risk exposure options. Our research on the financial close finds that a majority (53%) of finance executives believe that having better understanding of and deeper insight into their company’s tax positions would enable them to reduce their tax expense.
There are several other reasons why desktop spreadsheets are the wrong choice for handling taxes strategically. One is that tax laws and regulations are so fiendishly complex. For example, some countries have industry-specific statutory reporting requirements (for example, for insurance companies and other financial services). Tax calculations for subsidiaries in one country may not apply to those required for a regional headquarters or the parent company. There may be multiple tax rates applicable to a given legal entity and multiple bases or methods on which to apply each tax rate. Moreover, because book accounting for taxes and actual tax calculations almost always differ in multiple ways, it’s necessary to record and track these differences. Since rules, rates and assumptions will vary from year to year, it becomes necessary to adjust these differences. Desktop spreadsheets lack the dimensionality, data integrity and referential integrity necessary to be able to manage this level of detail easily. Dedicated tax management systems are designed to do it.
One reason why tax departments lag in adopting new tools is that until recently the technology necessary for managing the full range of requirements in direct tax analysis, provisioning and compliance was not mature enough for the organizations that needed it the most. Until recently, corporations that operate in multiple, worldwide jurisdictions with even modestly complex legal entity structures overtaxed the ability of IT systems to support them. However, using dedicated software for direct tax management enhances the efficiency of the tax department, enabling it to become more strategic and contribute to improving the company’s results.
Adopting a more strategic approach to managing direct taxes is an emerging trend in finance organizations, but it’s still at an early stage. Tax compliance is usually the main (and overwhelming) focus of tax departments. Most do this essential work reasonably well, but compliance is a tactical issue. To elevate tax management to a strategic level, tax and finance executives must have greater visibility into tax data and how operational decisions affect tax exposures. For example, finance and tax executives may construct a tax-optimized approach to transfer pricing, but their strategy may not be implemented if the company’s incentive compensation system is not aligned to this strategy. Operating managers in high-tax jurisdictions will try to maximize revenues because that’s what they’re rewarded for, even if it results in higher taxes than are necessary. Using spreadsheets is a significant barrier to tax departments taking a more strategic role in their company. When direct taxes are managed using desktop spreadsheets, there rarely is time for organizations to do much more than basic compliance. There’s usually not time to discover the fundamental disconnects between tax strategy and reality or other, similarly strategic activities such as analyzing and assessing the tax implications of long-term corporate plans.
Indeed, one sign of the tax function’s lack of strategic impact is its invisibility. There is a general lack of understanding of how the tax department functions, even within the finance department. For example, our research discovered that nearly two-thirds of finance executives (and, specifically, 60% of CFOs and controllers) do not know how long it takes their tax department to calculate tax liabilities.
Another reason is the relatively low status of tax departments in their company, which we can gauge through the distribution of titles and relatively low compensation for the highly credentialed individuals in these departments. Those that work in tax also tend to be tight-lipped and reluctant to reveal that their processes are time-consuming and difficult to manage, lest they be viewed as less than competent. The tax department’s invisibility contributes to a lack of focus on direct taxation by senior management, which also diminishes an understanding at that level of the potential benefits of investing in technology. Companies that are most likely to want to improve how they manage their direct taxes appear to be the ones where a senior finance department executive has spent time in tax and therefore has a firsthand appreciation for the challenges.
I’ve commented on the need to make tax more strategic. An increasing number of companies are finding that investing in dedicated software to improve the performance of their tax department is worthwhile. It gives them a deeper understanding of how best to manage what is usually one of their biggest expenses and enables them to make more optimal decisions about taxes. I recommend that all larger companies look into the benefits they can achieve by making their tax department more strategic and that they investigate dedicated software such as Longview’s that can enable them to have such a strategic tax function.
Robert Kugel – SVP Research