Jul 30, 2016 - incur a notably low tax bite and the ensuing BEPS project has forced boards to focus on their taxes as much as they do other areas of corporate ...
Reproduced with permission from BNAI European Tax Service Monthly Digest, 18 ets 7, 07/30/2016. Copyright 姝 2016 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com
Corporate ‘Tax’ Governance: A Necessary Addition to Best Practices for Businesses?
Steef Huibregtse and Avisha Sood TPA Global
Management of an entity’s tax strategy has historically been down to ﬁnance directors and has received little attention from boards. However, the growing reputational risk attached to strategies that incur a notably low tax bite and the ensuing BEPS project has forced boards to focus on their taxes as much as they do other areas of corporate governance.
I. What is Corporate Governance? Steef Huibregtse is the CEO and the founding partner of TPA Global and Avisha Sood is a Junior Associate at TPA Global in Amsterdam.
orporate governance broadly refers to mechanisms, processes and relations by which corporations are controlled and directed. Today, society is deﬁning that boards are explicitly accountable for the behavior of their employees and for the culture of their enterprise. Leading by example includes simple principles as ‘‘don’t lie, don’t steal and
don’t cheat’’. Ad hoc decision making in challenging business environments is a dangerous game if the rules of corporate governance are not followed. Three documents released since 1990: The Cadbury Report1 (UK, 1992), the Principles of Corporate Governance2 (OECD, 1999, 2004 and 2015), the Sarbanes-Oxley Act3 of 2002 (US, 2002) (SOX) deﬁne how companies are controlled and directed.
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II. Why Should Corporate Tax Governance be on the Boardroom Agenda? It is no secret that good corporate governance lies at the heart of every good business and in this era of tackling harmful tax practices that lead to base erosion and proﬁt shifting, good corporate tax4 governance is emerging as an additional compliance requirement that boards of MNEs must abide by. Managing the tax risks associated with a business has a direct correlation with ﬁnancial performance as well as the reputation of a company. With the focus of the OECD/G-20 on identifying and attacking tax evasion as well as tax avoidance, MNEs are forced to take a more proactive role in ensuring transparency in their conduct in order to prevent them from being caught in the web of regulations adopted in the wake of the BEPS project.5 Corporate tax governance is one such instrument that can provide the ﬁrst level of protection to corporate groups from an abrasive attack from the tax authorities. An example of such an aggressive and unexpected attack can be seen in the recent dispute6 between Google and the Italian tax administration, where the Italian tax administration demanded that Google pay 15% tax on its current proﬁts in Italy. This came as a surprise attack because only recently the multinational had settled a deal with the UK government setting payment of tax at 3%. Google tried using the same argument, claiming that its Italian presence merely provides consulting and marketing services for Google Ireland, the Middle East and Africa and therefore the proﬁts from royalties should not be allowed to be taxed in Italy. However, this argument is being criticized not only by the Italian administration but also by multiple lawmakers across Europe who are looking for ways to change tax rules which allow multinationals to shift untaxed proﬁts into low-tax jurisdictions. The Italian tax administration also investigated ﬁve Google executives for failing to declare 2009-2013 income and evading taxes of 227 million euros, who will soon be notiﬁed of the close of the investigation against them in the coming weeks. In Italy, such a notiﬁcation is usually a prelude to a (criminal) indictment.7 Another such example of incorrect transfer pricing arrangements leading to criminal liability can be seen in the case of Caterpillar Inc., where three shareholders have ﬁled a derivative lawsuit against current and former directors, ofﬁcers and executives over the company’s transfer pricing arrangement with a Swiss subsidiary, alleging a breach of ﬁduciary duty and unjust enrichment. The report charged that the arrangement with the Swiss subsidiary lacked economic substance and was created for the sole purpose of reducing the company’s U.S. corporate income tax. More recently, the structure has been the focus of a criminal investigation in Illinois.8
III. How the G-20/OECD Drives this Process? Corporate tax governance, in a nutshell, refers to maintaining trustworthy relationships with the tax authorities based on transparency. This can be done by maintaining a clear history of tax compliance, integrating the tax strategies with broader business strategies and ensuring clear and timely communication of the same to all stakeholders. In order to clearly under07/16 Tax Planning International European Tax Service
stand the meaning and scope of ‘corporate tax governance’, it is essential to delve into the history of this principle. OECD’s Forum on Tax Administration (‘‘FTA’’) ﬁrst conceptualized the idea of achieving an enhanced relationship between tax administrations and large business taxpayers during its meeting in Seoul in 2006. The global ﬁnancial crisis of 2008 further reinforced the importance of good corporate governance. Most recently, the OECD published a consultation document on the revised set of the Principles of Corporate Governance in November 2014 which were endorsed at the G-20 Leaders Summit in November 2015. The main changes to the principles include new reporting by companies on non-ﬁnancial information; a role for board directors in risk management, tax planning and internal audit; the establishment of audit, risk and remuneration committees; and recommendations on further board training.
IV. Which Stakeholders in an MNE Should be Involved? Tax has ceased to be something that just interests tax directors. The press is taking an increasing interest in tax issues and media attention on whether MNEs are paying their ‘fair share’ of tax is growing. Because of the overpowering techniques used by corporate groups over the last few decades, under the garb of tax planning, which have enabled them to save millions in tax, an aggressive attitude towards tackling all such arrangements is visible across the globe not only from the point of view of the tax authorities but also the general public at large which is becoming increasing agitated with multinational giants such as Apple and Google arriving at effective tax rates of less than 5% on their non-U.S. income. This is why the traditionally clear line between tax avoidance and tax evasion is blurring and the governments as well as the public is insistent on attributing individual liability for ‘criminal’ tax evasion to responsible persons within a corporate tax group. An example of this thinning line can be seen in yet another dispute9 between Google and the French tax authority which is seeking more than 1 billion euros ($1.12 billion) from the search ﬁrm in back taxes. France’s tax authority has been investigating Google since 2011 and is of the opinion that this high levy of tax is due to an aggressive tax evasion by the company over the years. The latest EU Member State to sharpen its focus on tax evasion is Spain which is alleging the same ‘aggravated tax fraud’ by Google as previously brought up by the French and Italian tax administrations.10 These recent raids are a new signal that Google’s and other tech companies’ long-simmering tax disputes in Europe are starting to boil. The French case is among biggest in a series that could lead other tax authorities to seek similar back taxes and tax evasion ﬁnes. Currently, in most MNEs the tax strategies are designed by the tax director in isolation from the rest of the Board and in absence of any clear communication of the same, there is often no understanding and agreement on the group’s tax strategy by the whole board. In such cases, it becomes difﬁcult to identify the concerned person for attributing individual criminal liability and therefore, we have recently seen many senior executives of large multinationals involved in
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such mitigation and/or evasion practices put in front of parliamentary or Congressional committees to explain their actions and, occasionally, comment publically on the tax affairs of individuals and companies. This not only creates a risk of serious reputational damage but also poses a very real risk of imprisonment for tax evasion. A clear example of reputational damage and even boycott was seen in the dispute11 between Starbucks and the U.K. tax authority which arose because, although Starbucks had sales of 400 million pounds in the U.K. in a year, it paid no corporation tax. It transferred some money to a Dutch sister company in royalty payments, bought coffee beans from Switzerland and paid high interest rates to borrow from other parts of the business. This led to a massive boycott of the coffee chain by local residents and Starbucks considered moving its tax base from the Netherlands to London in an attempt to banish its ‘immoral’ image. Journalists and newspapers also continue their own investigations on the appearances of Google, Starbucks and Amazon executives before the Public Accounts Committee, which in a report published in 2013, said the level of tax taken from some multinational ﬁrms was ‘‘outrageous’’ and that HM Revenue and Customs needed to be ‘‘more aggressive and assertive in confronting corporate tax avoidance’’. This increased aggression is now being seen at the grass roots level as well in the form of ‘tax shaming’ campaigns. Thus it is to be understood that corporate tax governance should be treated as tax risk management at the board level just like management of any other corporate risk for the enterprise.12 Tax risk is generally attributable to uncertainty about the interpretation of tax law in relation to particular transactions and the business’s view about whether a tax administration could have a different view to its own or the view of its advisors. To sum up, as the Director of the OECD Centre for Tax Policy, has observed, ‘‘What is clear is that the recent spate of corporate scandals, the success of a number of tax administrations in challenging aggressive tax schemes and the general change in attitudes towards tax planning, will all combine to produce a greater awareness in the Boardroom on the importance of tax issues.’’
The increase in related party trade as a consequence of globalization and digitization, coupled with the tightening grip of tax authorities around the globe after BEPS, has put the onus on the taxpayers to take a proactive role in efﬁciently managing their tax compliance as well as communicating the tax strategy to all stakeholders. Immediate action seems fairly appropriate because large businesses look for certainty about which of their actions and transactions are likely to be seen as risky by the tax administration and how the administration is likely to respond to those risks. Therefore, maintaining transparency in the tax strategies employed within the group should allow for an enhanced relationship with the tax authorities and should bring greater certainty to MNE groups enabling an earlier resolution of tax issues with less extensive audits and lower compliance costs.
VI. Are Country Speciﬁc Regulations on Corporate Tax Governance Published? The following countries have embraced the increasingly global view that tax risk management must be a part of good corporate governance and have issued some guidance in this respect:
A. Australia The Australian Tax Ofﬁce (‘‘ATO’’) has issued a guide (applicable to all business with a presence in Australia) on tax risk management and governance, detailing roles and responsibilities at Board and managerial level to assist corporate groups in developing their own tax control framework, testing their control framework and effectively communicating it to all stakeholders. The responsibilities allotted to the boards are: s endorse a formalized tax control framework detailing how the organization identiﬁes and manages tax risk and ensure that it is understood across the organization; s
understand and formalize company director roles and responsibilities for tax risk management;
familiarize itself with tax risk matters and the effectiveness of their tax control framework; and
conduct periodic internal control testing to ensure that the internal control framework is robust enough to effectively manage tax compliance risk.
V. Is There a Need for Immediate Action? The increased focus on tax risk management stems from the need for certainty in this area from the perspective of the taxpayers. In the post-BEPS world, MNEs are in constant fear of falling into disputes with the tax authorities in their various countries of operation because of the introduction of new rules without a clear interpretation of how they will be applied. Some such examples are listed below: s New Zealand’s Inland Revenue department proposed its intention to implement a new standard for exchanging cross-border information about tax rulings in 2016 in respect of high-risk transactions such as unexplained tax losses returned by foreignowned groups, cash pooling arrangements, payment of royalties at levels that are not sustainable, controlled foreign companies etc. s
The Australian tax ofﬁce has described a detailed process for case selection for an audit for companies engaged in the mining industry.
The UK diverted proﬁts tax has been enacted to curtail practices of tax avoidance and evasion.
Managerial-level responsibilities relate to ensuring sufﬁcient capacity and capability within the group to effectively manage the tax risk. Managerial responsibilities include ensuring that: s staff, management and board roles and responsibilities are clearly deﬁned and documented within the control framework; s
senior management, such as the CFO/CEO or Head of Tax, is conﬁdent in the capacity and capability of tax governance processes and personnel;
transactions or arrangements with a signiﬁcant tax impact are systemically identiﬁed, categorized and reported on;
data integrity as a result of data transfer between various accounting/subsidiary systems is subject to internal control processes;
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the organization employs procedures to support record keeping for tax requirements as prescribed by law and ATO guidelines; internal control framework includes the complete and accurate ﬂow of information from accounting records to the tax return and activity statements; there are procedures in place requiring explanations for signiﬁcant differences between accounting disclosures, ﬁnancial statements and the tax return; management is conﬁdent that tax disclosures have been accounted for properly and disclosed correctly in the relevant tax return; and tax corporate governance policies and procedures are required to be regularly reviewed and updated for law and administration changes.
B. EU—Overall On June 17, 2015 the European Commission had adopted a Communication on a Fair and Efﬁcient Corporate Tax System in the European Union, together with the establishment of the Commission Expert Group ‘Platform for Tax Good Governance, Aggressive Tax Planning and Double Taxation’. The Platform for Tax Good Governance assists the Commission in developing initiatives to promote good governance in tax matters in third countries, to tackle aggressive tax planning and to identify and address double taxation. It brings together expert representatives from business, tax professional and civil society organizations and enables a structured dialogue and exchange of expertise which can feed into a more coordinated and effective EU approach against tax evasion and avoidance. On January 28, 2016 the Commission presented a Communication on an External Strategy for Effective Taxation as part of its Anti-Tax Avoidance Package. This constitutes the next steps towards delivering effective taxation and greater tax transparency in the EU. The External Strategy outlines measures to promote tax good governance internationally and formally updates the overview of third country jurisdictions listed by Member States for tax purposes.
CRA in an open and transparent manner. The audits were to be eliminated or targeted to speciﬁc issues in case of strong governance and a willingness to work with CRA on an open and transparent basis. However, no further information is available on the current status of this policy.
E. Chile The Chilean Tax Administration (‘‘SII’’) launched the ﬁrst stage of the Project called RSET (Corporate social responsibility with tax MSMEs) in 2009 where it promotes the inclusion of tax risk control into corporate governance and suggested two methodologies for the same: s multidisciplinary working teams formed by highly qualiﬁed tax ofﬁcials, (hopefully with previous experience in the private sector), which creates greater willingness and a better afﬁnity with the business community; and s
The second stage of this project was underway between 2010 and 2014 that lead to a change in the Tax Reform Act (20.780) that was published in September 2014. Through this Act, SII was given the power to request information on transactions without it constituting, or making it obligatory to undertake, an audit. It could then carry on risk reviews which, among other beneﬁts, allow for determining and treating the noncompliance factors, strengthening the factors that promote compliance and, especially, certifying the risks in order to initiate massive or selective actions, including audits on probable or proven risks. Currently, the third stage of this project is ongoing the strategy and it is now focused on the company itself because through its corporate governance it may be capable of knowing its tax risks and gaps and determining functions and activities that may allow it to maintain an appropriate standard for tax purposes and thus continue in the lower area of the risks and treatments curve.
VII. Company Disclosures—Examples of Good Practices13
C. United Kingdom In the UK, Her Majesty’s Revenue and Customs (‘‘HMRC’’) released a consultation document in July 2015 seeking consultation on the potential for: s a legislative requirement for large businesses (turnover greater than 200 million pounds and/or assets greater than 2 billion pounds) to publish their tax strategies, where it is intended that a member of the Board should ‘formalise, articulate and own’ the tax strategy and sign off to HMRC to this effect; s a voluntary code of practice on taxation for large business; and s a set of ‘‘Special Measures’’ to tackle a small number of large businesses that habitually undertake aggressive tax planning.
The following examples present some ways to adhere to corporate tax governance practices, as seen in the case of companies listed below: s
Australia and New Zealand (‘‘ANZ’’) Banking Group has added a document on its website signed by the Global Head of Tax providing the reasons behind their tax policy, the application of the tax policy, the key obligations deﬁned under that policy and the role of the internal audit committee.
Another company that has included communication on its tax policy in its corporate governance agenda is H&M. Under the corporate governance section of its website, it provides details of its tax and transfer pricing model and the people/team responsible for managing such models.
Vodafone also has an extensive document describing the roles and responsibility of individuals and teams within the group in relation to the tax strategy of the group.
D. Canada In 2009, the Canada Revenue Agency (‘‘CRA’’) was revising its audit program to recognize the differences among large businesses with respect to the strength of their governance and their willingness to deal with 07/16 Tax Planning International European Tax Service
direct channels of communication between the tax administration and the corporation’s board, senior executives and their legal and tax advisors.
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These three companies are presented here due to the difference in the level of detail provided by them in their respective tax governance documents. The ANZ group provides a cursory glance at its tax policy without going into any detail about the content of its tax strategy or the people responsible for managing and implementing it. H&M, on the other hand, describes its tax and transfer pricing model in detail but falls short of providing information on the responsibilities allocated to various team/persons for executing the said model. Lastly, the Vodafone group provides an extensive level of detail on its page listing not only the main considerations of the tax policy but also the decision-makers behind it as well as the persons/ teams responsible for communicating with the tax authorities on various parts of the compliance cycle for the group. The differences seen in these companies demonstrate that there exists no clear guidance on what should form a part of good corporate tax governance and the companies have formulated their own principles regarding the same. This is why governments around the world are issuing speciﬁc guidance targeted at formulating a consistent reporting standard for corporate tax governance, as highlighted in the previous section. Multiple solutions in this regard are available to assist MNE groups of all sizes operating in high-risk industries. Some examples include: i. Setting up a ‘RACI’ (Responsible-AccountableConsulted-Informed) concept within an enterprise for all relevant tax/TP workﬂows to clearly allocate roles and responsibilities of all stakeholders with respect to each function.14 ii. Attaining an ISO 9001 Certiﬁcation on transfer pricing. The ISO Certiﬁcate focuses on Quality Management (ISO 9001)15 and Risk Management (ISO 31010)16 based on the analysis of the TP risk involved. Allowing their business processes to comply with ISO requirements, MNEs will integrally increase TP operational efﬁciency, and subsequently better mitigate the risks. The Indian tax authorities, for example, are of the view that ISO certiﬁcation could certainly be accepted as an evidence of conformity to good practice processes. iii. Deﬁning, in an explicit and transparent manner, in the annual report, not only ‘the rules of game’ but also how those rules are adopted by your enterprise i.e. deﬁning a clear accountability structure within your organization for each of the steps in your tax control framework.
Appendix A: Company Disclosures: Example of Good Practices17 This section presents some excerpts from the annual reports of companies engaging in good corporate tax governance practices:
1. Unilever NV/PLC ‘‘The tax Unilever pays is an important part of its wider economic impact and plays a key role in the development of countries where we operate. We are supportive of international tax reform and believe public trust in tax systems for companies is essential. We have published a set of global tax principles covering issues including transfer pricing, use of tax havens and relationships with tax authorities that represent
good corporate practice. They also balance the interests of our various stakeholders.’’
2. Koninklijke DSM NV ‘‘DSM believes that a responsible tax approach is an integral aspect of sustainable business. DSM views the fulﬁllment of its tax obligations as part of the process of creating long-term value for all stakeholders. . . DSM supports the idea of a global solution for fair tax policies and systems. Thus, DSM closely monitors and provides input on the OECD initiative on Base Erosion & Proﬁt Shifting.’’ ‘‘The Tax Control Framework is a tax risk management and control system, which ensures that the DSM tax team is aware of the worldwide tax risks for DSM, risks for which the tax function is responsible based on the DSM Corporate Requirements. The tax team possesses sufﬁcient insights to adequately manage these risks. The key stakeholders in the Tax Control Framework are well established and include: Supervisory Board, Managing Board, tax team, business, external auditors, as well as the tax authorities in countries where DSM is operating.’’
3. Koninklijke Philips NV Philips’ Tax Principles can be elaborated as follows: s Philips acts in accordance with applicable tax laws and regulations s Philips seeks an open and constructive dialogue with the tax authorities s Philips reports income in the countries where the value is created in accordance with internationally accepted standards, applying the arm’s length principle s Philips does not use legal entities in secrecy* countries18 and does not use legal entities in countries without commercial and/or economic activities, solely for tax avoidance s Philips recognizes the importance which tax plays in the area of advancing local and global economic development s Disclosures are made in accordance with applicable regulations and reporting requirements such as IFRS.
4. Barclays PLC ‘‘Arrangements that artiﬁcially transfer proﬁts into a low jurisdiction would not be compliant with the Tax Principles. . . Our Tax Principles make it very clear that all tax planning must support genuine commercial activity. . . The total amount of proﬁt not taxed in the UK, in respect of all our entities incorporated in low tax jurisdictions where we do not have a substantial business, was less than £2m in 2014 (less than 0.09% of the Group’s proﬁt before tax). We continue to have an objective of reducing the number of entities that we operate in low tax jurisdictions, but recognise that many such companies were established for a genuine commercial purpose that is consistent with our Tax Principles.’’
5. Statoil ASA Statoil provide detailed reporting for all countries, with separate tables and contextual information for each individual country. Payments are disclosed at the
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project and country level, split into the following types: taxes; royalties; fees; bonuses; host governments entitlements (value); host governments entitlements (Million barrels of oil equivalent / mmboe). Steef Huibregtse is the CEO and the founding partner of TPA Global and Avisha Sood is a Junior Associate at TPA Global in Amsterdam. They can be contacted at [email protected]
; and [email protected]
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10 Buck, T. (June 30, 2016). Spanish tax inspectors raid Google’s Madrid ofﬁce. Financial Times. Retrieved from http://www.ft.com/cms/ s/0/a1c6e3c2-3eb1-11e6-9f2c-36b487ebd80a.html#axzz4DRy08MjE 11 Barford, Vanessa, and Gerry Holt. ‘‘Google, Amazon, Starbucks: The Rise of ’tax Shaming’ ’’ BBC News. BBC, May 21, 2014. Available at: http://www.bbc.com/news/magazine-20560359 12
Examples of other ‘Enterprise Risk Management’ efforts:
s The Volkswagen Group’s responsible and forward-looking approach to risks is supported by a comprehensive risk management and internal control system (RMS/ICS). This is based on the internationally recognized COSO Enterprise Risk Management Framework (Committee of Sponsoring Organizations of the Treadway Commission). It pursues a holistic, integrating approach that combines the risk management system, internal control system and compliance management system in single Governance, Risk & Compliance
NOTES 1 Cadbury, Adrian. Report Of The Committee On The Financial Aspects Of Corporate Governance. London: Gee, 1992. Print. 2 OECD. (2015), G20/OECD Principles of Corporate Governance, OECD Publishing, Paris.DOI: http://dx.doi.org/10.1787/9789264236882-en 3 ‘‘H.R. 3763—107th Congress: Sarbanes-Oxley Act of 2002.’’ www.GovTrack.us. 2002. June 28, 2016 4 At present, an OECD estimate suggest that 70% of global cross-border trade is between related parties, which places transfer pricing (‘‘TP’’) at the center stage of any tax risk mitigation strategy. Therefore, in this article ‘tax risk management’ is understood to include TP risk management as well. 5 TPA Global has authored a booklet titled ‘2016 Handbook for dispute avoidance and resolution after BEPS’, enumerating strategies for corporates to avoid disputes with the tax authorities and/or battle them successfully. (BEPS: Base Erosion and Proﬁt Shifting) 6 Balmer, Crispian. ‘‘Italian Tax Police Believe Google Evaded 227 Million Euros in Taxes: Sources.’’ Reuters. Thomson Reuters, 28 Jan. 2016. Available at: http://www.reuters.com/article/us-google-italy-taxidUSKCN0V614L 7 Five Google execs probed for tax evasion—English. (2016, February 11). Retrieved July 1, 2016, from http://www.ansa.it/english/news/2016/ 02/11/ﬁve-google-execs-probed-for-tax-evasion_2d152e94-a7cf-4d72aadd-38a3a335fdce.html 8 Gregory, D. W. (2016, June 28). Shareholder Suit for Caterpillar, IRS Brief in ‘Altera’ Appeal. Transfer Pricing Report: News Archive, 25(266). 9 Schechner, Sam. ‘‘Google’s French Headquarters Raided by Tax Investigators.’’ The Wall Street Journal, May 24, 2016. Web. Available at: http://www.wsj.com/articles/googles-french-headquarters-raided-bytax-investigators-1464096931
strategy. As a result, the RMS/ICS ensures full coverage of all potential risk areas. The central body responsible is the Group Board of Management, which is informed about risks and opportunities in connection with a wide variety of processes. The Supervisory Board’s Audit Committee receives regular reports on the effectiveness of the RMS/ICS.
s The IKEA business is focussed on opportunities and involves risk taking every day. In the IKEA Group, these risks are taken in a compliant and responsible way. Group Risk Management & Compliance leads, steers and supports the business to strengthen the IKEA values and improve the level of efﬁciency by identifying, anticipating, and navigating through opportunities and risks. Together with effective monitoring and following-up, this leads to practical business control. Risk Management & Compliance works closely together with the various management level and provides support to ensure a safe and secure environment for visitors, customers and co-workers, strengthens the IKEA brand and protects its assets, maintaining an overall risk aware culture and driving compliance activities. 13
Examples of disclosure by some prominent MNEs in this ﬁeld are provided under Appendix A.
An illustration of the RACI concept is captured in Appendix B.
International Organisation for Standardisation. Geneva. ISO 9001:2015 Quality Management Systems — Requirements. ISO, 15 Sept. 2015. Web. .
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Appendix B: Illustration of the RACI concept (2/2) Lead Group
1. Consultancy— Advisory and implementation 2. Development/ maintenance of TP documentation 3. Risk Management 4. Audit support 5. Systems (central data management & retrieval) 6. Capacity planning— Insource/ outsource 7. Global benchmarking platform (outsourced to third parties) 8. Sign-off TP documents 9. Legal agreements— set up and implementation R (Responsible): Person who is assigned to perform part or all of the work, A (Accountable): Person who has the authority to sign off on the work before it is effective (ONLY ONE PERSON!), C (Consulted): Person who provides information or expertise necessary to complete the project, I (Informed): person who needs to be notiﬁed of results but need not necessary be consulted.
International Organisation for Standardisation. Geneva. IEC
31010:2009 Risk Management — Risk Assessment Techniques. ISO, 1 Nov.
United Nations. UNEP Finance Initiative & UN Global Impact. En-
gagement Guidance on Corporate Tax Responsibility. By Athanasia Karananou and Anastasia Gutha. Ed. Mark Kolmar. Available at: https://www.unpri.org/news/pri-launches-engagement-guidance-oncorporate-tax-responsibility. 18
Tax havens / blacklisted nontransparent regimes.
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