A more granular internal document which should build on and accommodate published tax statements. Coverage should extend across a broad range of risk types (e.g., compliance, evasion, planning, financial reporting, controversy), taxes, divisions, and jurisdictions. This will establish clarity over roles and responsibilities and describe how the elements of the Tax Control Framework (TCF) operate and interact.

Process documents, maps, narratives, standard operating procedures (SOPs) or similar documents outline processes and procedures for managing tax obligations. Such material can help maintain continuity of compliance in the event of unexpected absences. It can also help with training activity and provide a valuable summary of the current state to assist with process review and transformation.

An effective TCF relies on the accurate mapping of identified risks (or control objectives) to the actual controls which have been put in place. This cannot be a box-ticking exercise and needs to be kept up to date through a regular cadence of risk assessment. Control expectations should be clearly communicated through the organization as part of core training. Increasingly, control performance can be monitored through the use of “control workflows” which can automatically manage the required sign-offs and risk confirmations and thereby ensure that the TCF is effectively operationalized.

Independent testing of controls design and operating effectiveness is a strong indicator of maturity in a TCF and commitment to continuous improvement. Testing plans should be designed with care to ensure they make best use of limited time and resource and ultimately add value and strengthen the TCF.

Senior leadership should receive regular reporting in relation to emerging risks, uncertain tax positions, special projects, compliance status and the outcomes of testing activity. They should steer the direction both through direct feedback to issues raised and longer-term updates to the tax policy and public tax statement.