Tax Risk Management requires seven steps to ensure complete compliance by taxpayers, in an international environment where tax authorities are becoming better equipped and organized in closing tax gaps. Part of the process of tax authorities is the formation of Large Tax Units that expect to...

This paper examines how a functional tax strategy impacts the management control system (MCS) in a multinational enterprise (MNE) facing transfer pricing tax risks. Based on case study findings it is argued that the MCS in a multinational setting is contingent upon the MNE's response to its tax...

This paper was presented as part of a workshop to supply chain managers in 2006, on tax planning as part of a tax risk management process. The paper contains useful tools to conduct the appropriate tax risk management strategy, with tax planning as the focal point. The paper also deals...

This paper summarizes the key features of tax risk management and sets out the typical steps that should be followed. It follows a typical Six Sigma process in going about tax risk management. This paper discusses tax risk management, in particular, in the context of Section 404 of the U.S....

Our objective is to examine the ‘black box' of corporate tax risk management by providing unique insights into practitioners' tax risk perception, implemented tax risk management practices, and the internal dynamics leading to these practices. We perform our analysis based on 33 expert...

I've been asked for my perspective on the progress we have made since starting the journey over two years ago which raised with CEOs, company directors and Boards the consideration of tax risks as part of good corporate governance.Anecdotal evidence suggests that companies have made good...

In this paper I derive a straightforward condition, which I call the Arm's Length Dual Condition (ALD), for a controlled price to be, or not to be, arm's length. A proof of the validity of this condition is carried out with respect to the Resale Price, the Cost Plus and the Transactional Net...

The allocation of risk and of the income from risky investment and activities belongs to the central topics of international tax policy today. This fact is highlighted by the current BEPS initiative of G20 and OECD which casts doubt on the recognition of contractual risk allocation within...