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From obligation to opportunity: The future of UK corporation tax compliance

As technology accelerates and tax authorities push towards real-time reporting, Adam Owen, Deloitte’s Business Tax Operate Lead, explains why firms need to adapt now or risk being left behind.

Over the past decade, there have been huge strides forward in how businesses deal with their corporation tax compliance.

There's now more visibility and control around compliance obligations, and the use of specialist tax platforms, like Deloitte’s Intela, facilitate greater governance and the ability to obtain valuable insight from compliance-driven data to inform strategic tax decisions. More generally, the use of technology – and automation in its loosest sense – is becoming widespread.

Progress versus pressure

However, the compliance landscape is only going to become increasingly difficult to navigate. There are two reasons for this.

Adam Owen notes: “Firstly, complexity will be driven by regulatory change and growing tax authority expectations. In particular, the OECD’s Tax Administration 3.0 vision, which aims to change how tax compliance works. It means that, at some point in the future, the annual tax return as we know it will disappear.

“Instead of periodic filings, tax will be calculated in ‘real time’ within integrated systems, making compliance a continuous, automated process rather than a once-a-year obligation.”

Some overseas jurisdictions are already moving toward real-time tax calculation within native systems, but for larger and more complex markets, such as the UK, the transition will take longer. And while the timeline is uncertain, the expectation is that businesses will eventually need to adopt this approach to remain compliant.

“Secondly, there’s the rapid acceleration of technology and AI, particularly agentic AI,” Adam adds. “The capability has supercharged over the past 18 months so it’s far beyond anything we’ve seen before. It means the potential for what technology can do is much more than it’s ever been, and that’s only going to continue.”

For corporates , this creates a pivotal choice.

“You can take an incremental approach, building on the progress you’ve already made and adopting new tools gradually,” continues Adam

“Or you can say, ‘tax authorities aren't demanding this of me today, but technology is allowing me to get really close to that position anyway.’ You can fully grasp these advanced technologies and move closer to a future where compliance is automated, integrated and aligned with your priorities.”

The next frontier

If there’s one thing that businesses should be thinking about now, in Adam’s view, it’s the potential of agentic AI.

“It will provide a framework to pull data classification and data enhancement together,” he explains. “This will harness the power of GenAI, which isn’t used extensively within tax compliance today, and bring it into a much more highly automated solution.”

But most businesses really don’t know where to start. While many are experimenting with GenAI tools like CoPilot or ChatGPT, few have a clear strategy for introducing agentic AI into their compliance framework.

“They’re grappling with things like, ‘what does it really mean for me and how do I embed it? How do I make a difference within my organisation? And how do I govern it?’” Adam explains.

Creating a strategic advantage

Tax compliance is non-negotiable. If businesses don’t get it right, errors, penalties and increased controversy with tax authorities could follow. But, beyond this, compliance is increasingly recognised as a catalyst for efficiency and value creation.

Adam Owen, Deloitte Tax Partner

For our Tax Operate team at Deloitte, we are working with businesses across a range of industries to ensure they can drive opportunity and mitigate risk.

“Firstly, there are compliance-led opportunities,” says Adam. “If you can harness all the data that you've got from the compliance, that will give you insights into the business, whether it’s from a domestic or global perspective.

AI in practice: Using Machine Learning to deploy at scale

AI in the form of Machine Learning (ML) is well utilised in many compliance processes. For example, Deloitte’s Mercury solution automates the production of a UK corporation tax return from the trial balance without mapping or other manual intervention. This has been deployed at scale, automating in excess of 25k returns. Time savings can be highly significant including the ability to ‘batch’ automate, in one instance moving the time of production of 40 draft computations from 40 hours to 40 minutes. ML will retain its role in an Agentic AI framework, with solutions like Mercury forming one of the tools the Agents will deploy when moving through the end to end process.

Transactional data analysis remains an important element of compliance activity and done manually can be exceptionally time-consuming and inefficient. Techniques including ML and rules are increasingly utilised being effective in driving efficiency and quality. There are many examples of weeks and weeks of manual analysis being replaced with an automated solution to great effect.

There are two key developments to come in this area: Firstly, expectations will consistently move beyond the immediate analysis to also obtaining increased insight regarding the nature of spend to inform wider decision-making. In a recent example, the ML analysis of IT expenditure to P&L identified that spend on a single supplier had exponentially increased but was ‘hidden’ across a large volume of smaller expense items and project names – this enabled a better evaluation of both the accounting and tax treatment that is unlikely to have been picked up through manual review.

Secondly, current techniques are often bespoke and either require rules-writing or specific training data. Through the increased capabilities of AI there is growing use of ‘generic’ ML models that require less specific training data but still produce impressive results and emerging use of GenAI to either replace or work in tandem with other techniques. This allows greater deployment at scale and again will form an important element within an Agentic framework.

Secondly, if internally all your bandwidth and capacity is taken up with your compliance obligations, noting that they're getting more complex, then you haven’t got the bandwidth to think about strategic priorities and business partnering. That’s why creating capacity matters.”

AI in practice: Governing compliance across borders

The central governance of compliance – especially global compliance – within a single platform (e.g. Deloitte’s Intela) is a facilitator to greater use of AI.

GenAI use cases, including the ability to quickly interrogate data within a tax computation irrespective of language or format, is a great example of the interaction between the human workforce and AI agents. This will drive value in a domestic context but also has great potential for tax functions operating across borders.

Not just now, but as we move towards the adoption of agentic AI, the tax professional will bring their deep specialist knowledge and understanding of the business combining this with the power of GenAI to have a “conversation with the tax return” probing data in order to identify new opportunities and/or manage risk. Early areas of focus include assessing the nature and quantum of innovation reliefs available and being claimed globally.

As AI becomes an everyday tool for companies, the tax professional is having to adapt too; it requires digital fluency on top of tax technical excellence. For Adam, this raises the critical question that if technology is taking over so much of the process and moving so fast, how do tax teams keep up and maintain their expertise?

Adam believes, in the new world, process will be much more accelerated and automated. But rather than devolving responsibility fully to machines, his view is that businesses will need to partner with advisers that can play three critical roles in transforming compliance:

  1. Implementation. Enabling businesses to move from where they are today to a highly automated, agentic solution, whether through outsourcing or implementing technology internally.
  2. Assurance and enhancement. Providing the human judgment as an extension of the in-house function that is essential in reviewing, guarding against potential AI inaccuracies and importantly providing strategic thinking and tax expertise beyond what machines can deliver.
  3. Managing controversy. Adam explains this as ‘when the corporate bot and the tax authority bot disagree with each other and get to different answers’. Resolving these disputes will require specialists.

While for some the journey is just beginning, the direction is certain: a future powered by automation, real-time reporting and strategic integration – with humans providing assurance and harnessing insights to generate value.

For Adam, one thing is clear, the future isn’t five years away, it’s already here.

Now is the time to act. Compliance is more important than it's ever been. It's getting more and more complex and technological advances are allowing businesses to deal with it in a transformed way.


Adam Owen, Deloitte Tax Partner