A Pillar Two Risk Checklist for CFOs and Audit Committees

Request the tested group, fiscal year, jurisdiction population and the basis for any scope conclusion. Ask how accounting figures were reconciled to the relevant tax inputs, which reliefs were claimed and which matters remain provisional. A dashboard percentage is useful only when management can explain what it measures. Require a summary of changes since the previous review, including acquisitions, incentives, amended tax positions and new guidance. Keep the report proportionate: the committee needs material decisions and uncertainties, not every working-paper line or a blanket assurance that a calculation tool has validated the group.

Ask who owns registration, notification, each return, payment, record retention and responses to authorities. A fictional committee receives a green status because headquarters has completed the GIR, while two local teams have not confirmed their notices. The right follow-up is a location-by-location completion map with supporting receipts or a documented basis for relief. Identify the earliest unresolved legal date and escalation owner. Do not let a group-wide project percentage obscure an individual entity’s missed duty. Verify that the approved adviser scopes cover the tasks management believes have been delegated.

Separate the tax estimate, potential penalties, interest and remediation costs. Ask which consequences are legally established, which are contingent and which amounts are statutory maxima rather than forecasts. Local relief should be supported by a specific provision or administrative approach and the relevant facts. If technical uncertainty is material, request advice on the alternatives and the decision needed. Avoid two extremes: assuming new rules mean automatic immunity, or treating the largest imaginable sanction as the expected outcome. The report should explain both the risk and the action that would reduce uncertainty.

Close the discussion with named owners, dated next steps and evidence required to change an item’s status. Include continuity arrangements for staff or adviser changes, correction procedures and access to historical records. Consider whether the process has adequate review independence and local expertise for the group’s complexity. Bring us the existing dashboard, responsibility map and unresolved questions if the reporting is long but decisions remain unclear. We can help organise a focused review with existing advisers. The objective is informed oversight of a traceable process, not an unsupported certification that every jurisdictional outcome or future authority response is guaranteed.