Pillar Two: What Your Finance Team Should Do First

Begin by agreeing what the first review must answer. Is management deciding whether the group is in scope, preparing a tax provision, arranging registrations or assessing an acquisition? These tasks share information, but they do not produce the same deliverable. Write down the tested financial year, the legal group being considered and the date by which the answer is needed.

Appoint one finance lead to maintain the group information and a separate reviewer to challenge assumptions. Ask for the ultimate parent’s consolidated accounts, a current ownership chart and a list of operating jurisdictions. Identify missing documents immediately. A working file that clearly distinguishes confirmed facts from open questions is more useful than a large spreadsheet containing unexplained estimates.

Treat the work as three connected questions: which rules could apply, what tax might arise, and what administrative obligations need attention? Keep a separate list for each. A preliminary view that the tax could be zero should not automatically close the registration or filing workstream. Local requirements need their own confirmation for the relevant period.

For example, a fictional group with manufacturing, sales and holding entities in four countries assigns its accountant to calculate an effective tax rate. The accountant cannot sensibly prioritise the work until headquarters confirms the ownership chain and reporting year. The better first deliverable is a jurisdiction matrix naming the entities, information owners and questions requiring local advice.

Request the information in stages. First establish the group perimeter and consolidated revenue history. Next obtain the tax and accounting schedules needed to identify potential areas of exposure. Only then request detailed calculation inputs or safe-harbour evidence. Explain why each item matters, who should supply it and whether it is essential to the immediate decision.

Keep an issues log alongside the request. Record uncertainty about entity classification, acquisitions, accounting periods, missing tax schedules and responsibility for local filings. Give every issue an owner and a next action. Avoid assigning a completion date that leaves no time for review, questions or corrections before an external deadline.

Escalate when the ownership chain is unclear, the group is close to the scope threshold, several jurisdictions may collect tax, or the finance team cannot reconcile its tax figures. These are reasons to resolve the foundations early, rather than force a provisional number into a final answer. Bring us the group chart, reporting year and the questions management needs answered; we can help define the next stage of work and coordinate the necessary local input.