Podcast transcript : How to protect your business from tax risk and controversy

Susannah Streeter

Hello and welcome to the EY Tax and Law in Focus podcast. I'm your host Susannah Streeter. In this episode, we're focusing on why global businesses need robust tax governance to manage a new era of tax risk and controversy, which is resuming post-pandemic. The 2023 EY Tax Risk and Controversy survey has thrown up a raft of key findings, highlighting the urgency for firms to get on the front foot. 84% of respondents said an approved global framework for tax risk and controversy management would add either some or significant value to their business during the next two years. Although it's clear now is the time for action, big challenges remain. More than six in 10 of those surveyed say executive leadership rarely or never involves their tax functions in significant changes to existing activities, such as business model changes, new products, and new services. And this, of course, increases the risk of unexpected tax exposure for those activities. Then there's the growing number of audits to deal with. Tax leaders expect these to grow by around 80% in the next couple of years. But the overall picture of ongoing disputes is still opaque in lots of companies. So in this podcast, we're going to map the changes across the tax risk and controversy landscape and scan the horizon for what else might be incoming. And to do this, I'll be joined by global experts in the field, who will also deliver plenty of key takeaways to help companies be proactive and take the necessary next steps with confidence. But before I introduce them, please remember, conversations during this podcast should not be relied upon as accounting, legal, investment, or other professional advice. Listeners must, of course, consult their own advisers.

But now, please do welcome Bryon Christensen, EY US Tax Controversy Leader. Hi Bryon, where are you today?

Bryon Christensen

Hi, I am talking to you from Seattle, Washington today.

Streeter

Great to have you with us, so much to talk about. I'd also like to welcome Fiona Moore, who's the Oceania Tax Controversy Leader for EY, and where are you today Fiona?

Fiona Moore

Hi, Susannah. I'm joining you from Sydney today and it's lovely to be here.

Streeter

Fantastic. And also let me introduce Luis Coronado, EY Global Tax Controversy leader. What part of Asia are you joining us from Luis?

Luis Coronado

Hi Susannah. Well, I'm usually based in Singapore, but I'm joining you this morning from Seoul, Korea. Hi to everyone.

Streeter

Great to have you with us from all corners of the world. And let's look at the broad landscape to start off with. Bryon, we've had somewhat of a pandemic lull, haven't we, but to what extent would you say that tax risk and controversy is now firmly back on the agenda?

Christensen

That's a great question. I would say it is firmly back on the agenda. As we enter into this post-COVID era, there certainly was, as you mentioned, a lull. But I would say at this point, most tax authorities are back to work. They may be back to work in the office, or they may now have in place standardized procedures for working remotely. And so that has increased tax controversy activity as we've seen it. I also think that COVID has another effect, which is tax authorities are now coming out and have increased revenue pressures, given the stimulus that was put in place during COVID. And those revenue pressures are creating additional vigilance on the part of tax authorities across the globe.

Streeter

Certainly lots of pressures right now. And Fiona, would you say you're seeing the same in your region? What's the picture?

Moore

The revenue authorities in Oceania are certainly back to business as usual, and we're finding that COVID-related disruptions are no longer justifications for not meeting obligations on a timely basis. Post-pandemic compliance programs are certainly continuing to evolve, which means that tax risk management and controversy is really a standing agenda items for many of our clients.

Streeter

And Luis, what would you say the key areas are where the tax risk and controversy landscape is changing in Asia? I mean, can you share any specific data? Is it a similar picture?

Coronado

Yeah, well, first of all, I think we came off the restrictions a little later than the rest of the world. So we're catching up with the activity but very promptly. And I think that two areas that I would mention would be first of all on tax incentives. As you know, there's a lot of manufacturing carried out in certain parts of Asia and those are benefiting from incentives that are given by the government. Those are going to be highly scrutinized to ensure that they qualify and so on. And the other one, going back to what Bryon said, is the stimulus packages, a lot of economies put out their incentives and stimulus packages for economies to stay afloat. And obviously that comes on top of the day-to-day tax obligations of a company in that they can demonstrate that those funds were properly utilized, etcetera.

Streeter

So a lot to get a handle on really and Bryon, the latest EY tax risk and controversy survey shows that cross border tax risk remains high. What else is identified in the survey that we simply can't ignore?

Christensen

Yes, so cross border controversy remains something that is very prominent from the survey data. In addition, as Luis just mentioned, the controversy around tax incentives is something that taxpayers are paying more attention to now and see as a risk. I would say, we've seen this movie before. So during times of financial crisis, stimulus is put in place, it's put in place quickly, for very good reason. And then as we get through that financial crisis, tax authorities take a very close look to make sure those incentives were properly implemented by taxpayers.

Streeter

And Fiona, what ways would you say that tax authorities are changing their behavior since the pandemic? How are they becoming more assertive would you say?

Moore

Absolutely, they're becoming more assertive. During the pandemic, we taught ourselves, and I think out of necessity, how to be connected in a virtual world. And the revenue authorities are really expecting this connectivity to continue. And they're quite assertive with respect to their expectations around the depth, and the timeliness of data being provided in response to requests for information. Hand in hand with that depth and timeliness is quality. We are consistently hearing from the revenue authorities that they want to see objective evidence, they want to be shown and not told about the tax affairs of an organization. Authorities really want the data to speak for itself. Without the added need for commentary.

Streeter

We're going to drill into what this means kind of day to day and what companies need to do as a result of this a little bit later. But Luis before we get there, let's focus on digital tax administration. This really is being accelerated, isn't it? What impact is this having?

Coronado

Well, absolutely. Tax administrations are jumping on the technology bandwagon. And we're seeing this actually from locations that wouldn't be your usual destinations for such improvements. You would see countries like Mexico, Brazil, Eastern Europe really going leaps and bounds into the digitalization of their tax administration activities, which brings a lot of transparency, because as mentioned by Fiona, you have information extracted directly that then runs calculations for your tax obligations. In addition to that, it becomes faster. And I think you get preliminary results from the authorities on what your tax obligations are going to be very, very quickly and sometimes even instantaneous, particularly in consumption taxes, you go to the store, buy a good, and immediately the government knows how much indirect tax they're going to be collecting from you in that particular transaction.

Streeter

There are so many changes, and it's happening so rapidly as well, isn't it? And, Bryon, what does this survey highlight about the changing focus on cross-border issues such as international tax and transfer pricing?

Christensen

Yes. So the survey shows, especially when compared to prior years that, in fact, views on transfer pricing controversy risk are higher than they were in prior surveys. And that is an interesting trend, given how active the OECD has been in recent times in trying to build certainty and global consensus around cross-border rules. That is, despite those efforts, we see in the polling data that taxpayers and multinationals in particular still remain at a heightened level of concern about tax controversy over cross-border issues.

Streeter

And do you see more tax audits and disputes growing in the future?

Christensen

It's hard to look into a crystal ball and make a prediction about that. But the polling data seems to indicate that yes, that is going to happen, that it is not enough at this time to be simply thinking about the right structure to put in place given pillar two, BEPS 2.0 But it's also important to think about down the road how tax authorities are going to be scrutinizing those structures.

Streeter

Luis, what's your take on this?

Coronado

Well, I absolutely agree that BEPS 2.0 is going to bring a new horizon of potential controversies. You have Pillar One those controversy panels that I think we will help to alleviate some of the tensions that you will have among the countries without having to go all the way to outright arbitration, which has been frowned upon in certain locations. And then pillar two, which is the most immediate action given that a number of countries where I'm sitting today, Korea is the first one that adopted really local application of pillar two recommendations, I think that you are going to start to see controversies there. And they need to be dealt with upfront because you don't want to be catching up later, around adjustments that were made on years where you have determined your new tax rate at 15%. And it turns out that it wasn't 15 because certain transfer pricing adjustments were not recognized, for example. So certainly, new areas to come. As mentioned before, we touched upon a couple of new areas on top of day-to-day tax obligations that taxpayers have today. And there are new tax rules coming up that they should be looking into.

Streeter

So it's clear that you can't just be playing catch up, you need to be really ahead of the game. And Fiona, it's also clear that audits are growing. So how do you become audit ready and prepared for what appears to be a much more forensic level of scrutiny?

Moore

Susannah, as you said, you know, we need to be getting ahead of the game. And if you're looking at audit readiness on a project basis, you're not going to get ahead of the game. So audit readiness really needs to be part of taxpayers' business-as-usual processes. That means that, for example, when we're preparing our income tax returns, and our transaction work papers, they're auditable, they're transparent, they're defendable, and they're really ready to go to be handed to the relevant revenue authority. Revenue authorities don't want to wait four or six weeks for you to bundle up your work papers, when they issue a request for information. There might be some additional steps that need to be taken when you're preparing those work papers. For example, depending on the transaction or circumstance, it might mean taking contemporaneous statements from key individuals at the time of the transaction. So the corporate memories are maintained in the event those individuals leave the organization.

Streeter

So Luis, what do you make of Fiona's point here? And are you surprised at the extent to which tax functions are not included in crucial decisions and changes to business activities, for example, particularly given how a better framework is considered to have such an impact to the bottom line of many companies.

Coronado

I think unfortunately tax departments to a degree still play a catch-up role in tax investigators within the company to find out where business is heading and then look at the tax consequences thereof. However, we do see a trend and a lot of hope that as we go forward, and there are more requirements in transparency, whether they are demanded by key stakeholders, by reporting principles, or even by tax government programs, as we will discuss later, we expect that these good governance principles are going to be adopted and therefore tax will have a seat at the table also in the day to day expansion of business that that then can have immediate support from them, in as far as what the tax consequences would be, and how to plan it and not have to deal with surprises down the road.

Streeter

Well, Bryon, let me bring you in. I mean, do you think perhaps the management of tax risk and controversy should be seen in a different light as a way of creating a competitive advantage? Would this move the dial?

Christensen

I'm not sure any executive would characterize being subjected to a tax audit as a competitive advantage, but I do think we can see it in a different light, and the points Luis had just made, or was just making about governance structures, we see in the polling data that the majority of companies don't have in place, systemized or standardize governance frameworks around tax controversies. I think those types of governance standards, if put in place can help efficiently resolve tax controversies to the benefit of your company. In addition, another statistic that stands out for me is that 76% of companies don't have complete visibility into their tax audits. It seems like very low-hanging fruit, given today's access to technology and data, where substantial progress could be made in managing tax controversies.

Streeter

Yeah, it does. I mean Fiona, why do you think many companies still don't have full oversight of the picture of ongoing disputes?

Moore

I think there are just some organizations where tax hasn't been elevated to the boardroom, or there's not a global tax function. Luis mentioned having a seat at the table. And that's where I think some organizations do need to make some movement to make sure tax has that seat at the table. Otherwise there can be a disconnect between the different jurisdictions. If I look at my own backyard, for example, in Australia, the Australian subsidiaries are not necessarily material in the overall ecosystem of the global organization. And this can cause a disconnect, which can be really problematic when the Australian subsidiary isn't material in the context of the Australian economy, because quite frankly, effective dispute management requires buying a broad range of stakeholders, not just locally, but globally as well.

Streeter

So it can't be a filtered seat but an actual seat, is that what you're saying?

Moore

Absolutely, Susannah. The problem with having a filtered see is there can be again, that disconnect. The individual, for example, the CFO, might not have the granular detail of the transactions. So in that regard, one of our recommendations is often that there is a global tax controversy role, someone who has the impetus to not only connect the dots of the organization, but who has the authority to insert themselves into the tax strategy discussions in the various jurisdictions.

Streeter

Luis, would you agree? I mean, looking at the broader perspective, how else does tax governance need an overhaul?

Coronado

Thanks, I think there is definitely a focus here, particularly in certain parts of Asia, we're starting to see governments encouraging taxpayers to join programs that they have put out there enforcing tax governance principles. Some of those programs are voluntary. Some of those programs are compulsory. However, they do change the relationship between taxpayer and tax authority in that there's an element of justified trust, if you will, to adopt a term from Australia, in the sense that then taxpayers would have processes, principles, decision-making that are held accountable to all stakeholders in the organization. And in addition to that, they get a compliance certificate or a clearance certificate from the tax administration that would then make their day-to-day tax affairs much easier to be dealt with.

Streeter

Bryon, let me bring you in. What's your take on this?

Christensen

Yes, thank you. One point worth noting is it's interesting how companies can be appropriately cautious and proactive in their planning and compliance phases of the tax lifecycle but become fatalistic when it comes to controversy. And just assume that whatever will happen will happen. We see that changing, where there is a sense that putting in place some of these governance structures, some of these risk management frameworks can help a company proactively manage tax controversy risk, once the compliance and planning is done.

Streeter

So we're not just talking processes and controls, we're talking policies and people as well. I mean, how important is it that companies address all aspects of tax governance here when creating this framework?

Christensen

That's right; it doesn't happen by accident. It has to be an intentional effort by the company to make sure you have the right people in place, thinking about tax controversy, and that those people are participating in appropriate ways during the planning or compliance phases of the tax lifecycle.

Streeter

So Luis, what changes would you say are needed in an organization to improve the integration of the tax function? You heard as well what Fiona was saying a little bit earlier about specific new roles to be created? Would you agree?

Coronado

Yeah, well, certainly I think the controversy function needs to be taken in earnest, right. It can't be someone else's second half of the day or a few hours in a week. I think the demand for being on top of things, to monitor where controversies are going and building up a uniform stance on some of the common issues is perennial. And I think it's very important for organizations to do that. The starting point could be as easy as setting up a tax risk assessment and moving into how you would manage those. I think that we're starting to see taxpayers progressively moving more from a reactionary stance and controversy and just resolving controversy to be more proactive and preventive in nature. Again, going back to the governance programs, which could be as well a measure taken to be on top of the game. You do have those in locations in Asia, such as Australia and Singapore, and even more recently, Malaysia, that have adopted tax governance programs directed by the tax administration. And others that are more guided by fundamental principles on reporting and accountability to stakeholders like Japan and New Zealand. So certainly there is enough out there for taxpayers to review and adopt those that are more aligned to their risk appetite.

Streeter

And Fiona, which processes, leading on from what Luis is talking about. Which processes do you think need to be improved to help stem the flow of disputes?

Moore

It's the processes, Susannah, that surround communication. Just to pick up on one of the words Bryon used, it was intention. So tax functions really need to look for ways to proactively engage and communicate with the revenue authorities so they can really take command of the narrative. Many revenue authorities have mechanisms to engage during the transaction, as opposed to after the event. And I really encourage my clients to make use of those mechanisms. Because gone are the days where organizations can hope that they will not be examined. There's no hiding anymore. Tax authorities have increasing resources. And again, for example, I can't recall the last federal budget that was delivered in Australia where there weren't funds allocated to the Australian Tax Office for compliance processes. So in that regard, from an organizational perspective, again, communication and taking command of the narrative is where there really needs to be some focus.

Streeter

And Bryon, as Fiona is indicating there, tax authorities may vary in their ability to have resources. And that can really vary across geographies as well. What does this mean for the focus going forward, depending on the resources at their disposal?

Christensen

Yeah, I think the increased resources that Fiona was mentioning are important. And they have to be coupled with the idea that tax authorities are also approaching problems in a new way. So they are moving at the speed of information. So we see tax authorities being smarter about trying to leverage one audit, develop an issue across multiple taxpayers. And we see tax authorities having increased cooperation on cross-border issues where an issue can be developed in one country, and then leveraged in another. And we have kind of two factors playing out here. The first one is increased funding. And the second one is better processes and enforcement activity.

Streeter

So I'd like to move on to data now, obviously, absolutely crucial. Luis, how do companies ensure the data they use to underpin their work in assessing tax risk really is fit for purpose?

Coronado

Well they definitely need to broaden the horizon from just having tax or finance involved. I think as we start to require more and more data, whether it's a tax administration becoming digitalized, whether it is global calculations that need to be put in place, the starting point of any trust relationship is that the data is readily accessible, that it is replicable, and that the sources are all correct. Therefore, you need to add into the mix your IT department, etc. Because just to give you an example, for some of the calculations we need to carry out under pillar two that Bryon mentioned earlier, there are at least 100 data points that you need, right? Therefore, again, the source of the data and the ability to trust that data, every other calculation, as much as it could be technically correct, if the source information is incorrect, you're not going to get to the right outcome. So really important that tax departments start to look into this. And again, it's not something they're going to be able to resolve themselves. It's a much wider, collegiate approach within the organization to be able to have this data preparation, data access in place.

Streeter

Yeah. And Fiona, as Luis is saying you need a collegiate approach. But to what extent do you feel that companies are neglecting spending sufficient time on ensuring they have the right data and they have the right approach to this?

Moore

Susannah, I think a lot of companies are succumbing to time and resource pressures. And sometimes that there is a materiality threshold that's applied when providing data to revenue authorities. And we all know there's no materiality in tax, so you can't apply that threshold. And the other thing to be cognizant of is we're in an age where transparency of tax data is increasing. 10, even 15 years ago, tax was quite a private affair. But now the level of data that's required is increasing, both in terms of what's been provided to revenue authorities, but also what's going into the public domain. Take, for example, uncertain tax position disclosures that are made in financial statements. In Australia, just recently there were announcements in relation to further transparency measures around disclosure of tax data, so we're almost seeing that privacy and tax dissolve. And with that comes an increased need for more accurate data. That also means we need better processes to support the veracity of that data. And as Luis mentioned that stakeholder buy-in is absolutely important.

Streeter

So Bryon, let me bring you in here. I mean, how do companies ensure they have this up-to-date flow of data that Luis and Fiona have been talking about?

Christensen

That is an important question and to start talking about that question, it's important to put the data used for controversy in context. So when we think about tax planning, tax planning relies upon future data, tax planning relies upon projections about how the business is going to perform in the future. Tax compliance depends upon current data, what do the books and records required to be reported today, on a tax return? Tax controversy, in contrast, depends upon past data. It depends upon the historical books and records that may be reviewed one year, two years or three years, or even longer after the compliance activity has occurred. So when thinking about your data set today, it's important from when you put on the controversy lens that you understand that, that data set is going to be evaluated several years from now under the data standards of the future. And that puts, I think, a unique perspective on the importance today of putting in place the right data set for purposes of your future controversy.

Streeter

Yeah, it's a really interesting perspective, like that. And it certainly cements the urgency to get it right. And Luis, what are the reputational risks, if companies fail to have access to crucial data at their fingertips?

Coronado

Well I think it's at least twofold or maybe even threefold. One is in connection with the relationship with the tax administration, as mentioned before. S-second would be just with the users of the financial data and the reliability that you would have to it, whether that is shareholders, investors, of sorts, banks, etc. And then lastly, we've seen the media picked up on taxes, an important topic that they report on today. So probably we didn't have this 10-15 years ago, but today, you would see that tax attracts the front line space in the major newspapers, therefore, that could, depending on the business that is being highlighted, that could come up with situations on boycotting, and things like that you have seen before, particularly in consumer brands.

Streeter

And Fiona what's your take on this?

Moore

Two things here Susannah. Firstly, Luis mentioned reputational risk with the revenue authorities. Revenue authorities have very long memories. So once an organization's reputation is damaged, it can absolutely take some time to rebuild with that Revenue authority. The other group that we haven't mentioned that I think is quite important, is employees. Employees are more socially conscious than ever before. And if they see the organization they're working for come into difficulty from a media perspective, for example, some employees will actually start to ask questions around why are they working for that organization. Does that align with their values? And so in that regard, the reputational damage can actually cause workforce disruption.

Streeter

So it's clear there are plenty of risks. So Bryon, how should data science then be incorporated into the tax function to minimize this?

Christensen

So there are a number of ways that can happen, but I would, I would start here. In the United States with the Internal Revenue Service. If you have an audit of any size, the first request will be for source financial data. The IRS will employ computer audit specialists, computer audit specialists will begin working with that data. Interestingly, what I would say is, most of the time, the controversy professionals within those companies have never thought about that financial data before that request comes. So as a starting point, simply proactively becoming familiar with a data set that's going to be the source of the audit, the initiation of the audit, from a controversies perspective is step one. From there, tax controversy professionals can start to think about what that data presents in terms of the tax positions of the company, and how that data as a third point can be leveraged to resolve tax disputes efficiently.

Streeter

Okay, so Luis, what kinds of programs can companies access to give taxpayers more certainty and just how do they work?

Coronado

Well Bryon mentioned two key data points on the answers right? That transfer pricing is it's a major area of concern and cross border transactions. I'll focus on those two in the programs that are available. For transfer pricing, we know there is a binding program called the Advanced pricing agreement that is used pretty much universally by taxpayers to get certainty on their transfer pricing affairs for multiple years. And those can be unilateral, which are probably not as widely used nowadays, as they were in the past because of exchange of information. And it only solves one side of the equation. The bilateral ones, we've seen a jump in them. We see more countries under the treaty provisions negotiate them, and even multilateral, where you get two or more countries agree with the taxpayer on the transfer pricing efforts. They're generally multi-year. So there is an effort to go and request an APA. But then you get certainty for a number of years. And we see as well, many users coming back for renewals, meaning that if your period expires, you'll go and get an extension and those are becoming more and more efficient. On the cross-border side there is a new program, not binding but still provides you a pretty good view of what governments think of your cross-border compliance affairs called the ICAP, the International Compliance Assurance Program, which is facilitated by the OECD. You've got 22 countries in it, three in Asia, nowadays, you've got Australia, Japan and Singapore and hopefully more joining and that you can get anything covered under a treaty not only transfer pricing, but all the other important aspects of a of a treaty such as permanent establishment, income classification, and so on, that could be covered under an ICAP review, and that you would be then getting opinions from the governments as to your level of compliance with the regulations and the trends that they see. So those are two programs that we're seeing widely used APA, it's been there for decades. ICAP is more recent, but uptake is not bad.

Streeter

So Fiona, what's your take on the types of dispute resolution which is available? Does it really depend on where you are in the world?

Moore

Yes, Susannah, I think the specifics can depend on where you are in the world and what jurisdiction and what the issue is. If I just talk broadly for a minute, there are really two main approaches to dispute resolution. There are formal court processes and negotiated outcomes. And some jurisdictions will have both available, but irrespective of what process is available to you, I really think it's important that you continue to actively consider the strategy and what levers you have available to improve the outcome of the dispute resolution. One key message here is dispute resolution strategies cannot be set and forget. You need to be proactively engaging and proactively considering those strategies.

Streeter

And Bryon, Luis mentioned the ICAP program from the OECD, do you think awareness really is growing of the OECD is procedures for dispute resolution?

Christensen

I will take that from the US perspective. Certainly, awareness is growing. I think the activity over the OECD in recent years has been front and center for US multinationals. And as they look at those activities, they are becoming increasingly sensitive and curious about alternative programs, alternative dispute resolution programs and different ways that taxpayers can interact with the tax authorities to avoid unnecessary controversy.

Streeter

So it's clear there are lots of differences depending on the geographical region you're in. But what about the way that rolls should change? Fiona mentioned this earlier, Luis, about how it's really important that there's not a filtered seat at the table but an actual seat. In what way do you think roles should change to make processes more efficient, but keep local identity? Is it different, would you say, in Asia to other parts of the world?

Coronado

Well, I think on the back as well of Bryon's comment on the collaboration at the OECD level and the inclusive framework that has now more than 150 countries. You will see that multilateralism is apparent everywhere in the world, governments are talking to each other officially or unofficially. And so there are no more situations where things are unknown. They will have coffee breaks, formal discussions, lunches and so on. And therefore, trends become relatively universal on things. Therefore, I think collaboration is key and that collaboration within the tax departments of an organization and broader departments of an organization does take different flavors. The way that I've seen throughout working in various parts of the world, I think, Western Europe, North America perhaps is more top down. I would think that in places in Latin America and places in Asia Pacific, it's more a collaborative approach rather than top down. However, no matter what the decision-making process is in the controls that are put in place, access to data to know what are the hot topics and then being able to evolve uniform positions, learn from your past outcomes, start to build up data analytics within your own organization and within your sector, if that's available in collaboration even wider than just the organization you work for. But in the larger tax community base would be very important. Because, again, governments are speaking to each other, they are collaborating with each other. And I think the organizations themselves need to catch up with that.

Streeter

Absolutely. It's been so great to have all of your insights, it has been really fascinating. But I just really wanted to end by asking you all for a quick takeaway, and I want to know what your big tip is to ensure that tax functions really can contribute significantly more value to an organization's overall objective. Bryon, what would you say your main takeaway is?

Christensen

If I could get two quick takeaways, I would raise two numbers from the survey, the first number, 75% of respondents do not have complete visibility into their tax controversies. The second number, 50% do not keep current tax risk documentation. Both of those places are a dangerous place to be and an unnecessarily dangerous place to be. Those are areas where immediate progress can be made to cope and manage risk in this new tax environment.

Streeter

Okay, thank you, Bryon. So, what about you, Fiona? What's your key takeaway?

Moore

Again, to use Bryon's approach, start with a statistic. 69% of our survey respondents say they expect their organization's focus on tax governance to grow. That's a really high proportion, thinking the importance of tax governance will increase. So to sum up, organizations need to be much better with their internal connections, making sure tax has a seat at the board. And then secondly, controlling the narrative and being active in your strategy and taking opportunities to control the narrative with the revenue authorities.

Streeter

Fiona, thank you. And Luis?

Coronado

Well, razor-sharp focus on data is key, that's the starting point for anything that is going to end up having a tax amount to be paid for, for a taxpayer, therefore it has to be reliable. It has to be trusted, and it has to be replicable in the collaboration that comes thereof for all of the things that taxpayers will be facing in the future.

Streeter

A razor-sharp focus on data. Thank you so much to all three of you. It's been really great to get your views and your insights.

Christensen

Thank you, Susannah. It was a pleasure to be here today.

Coronado

Thank you. Goodbye.

Moore

Thank you. It's been great to be on the podcast today.

Streeter

Thank you so much for your time. For more information you can visit ey.com. And a quick note from the legal team. The views of third parties set out in this podcast aren't necessarily the views of the global EY organization nor its member firms. Moreover, they should be seen in the context of the time in which they were made. I am Susannah Streeter, I hope you'll join me again for the next edition of Tax and Law in Focus brought to you by EY building a better working world.