The Mechanics of Tax Risk Management – Agenda

COURSE AT A GLANCE – Over 16 weeks, you will study:

Unit 1: Introduction to Tax Risk Management

Aim

This unit provides an overview of the fundamental concepts and principles of managing tax-related risks within an organisation. It covers the identification, assessment, and mitigation of potential tax risks, emphasising the importance of compliance, strategic planning, and the role of tax governance in safeguarding an organisation’s financial health.

This unit lays the groundwork for understanding how effective tax risk management contributes to overall corporate risk management and sustainability.

Learning Outcomes

On successfully completing this unit, participants will be able to:

  • Implement the basic principles and concepts of tax risk management – including the identification and classification of tax risks
  • Develop the ability to assess and evaluate tax risks within an organisational context
  • Apply various strategies and approaches for mitigating and managing tax risks effectively
  • Recognise the importance of tax compliance and governance in the broader framework of corporate risk management
  • Highlight insights into the role of tax risk management in strategic business planning and decision-making
  • Apply theoretical knowledge to real-world scenarios through case studies, enhancing practical understanding and problem-solving skills
  • Improve the ability to communicate tax risk issues and strategies to stakeholders effectively

Unit 2: Tax Risk Assessment

Aim

This unit focuses on the methodologies and tools used to identify, evaluate, and prioritise tax risks within an organisation. It emphasises the importance of understanding the financial, operational, and reputational impacts of tax risks, and provides practical techniques for conducting comprehensive tax risk assessments.

Learning Outcomes

On successfully completing this unit, the participant will be able to:

  • Identify various types of tax risks – including financial, operational, and reputational risks.
  • Apply the methodologies and tools used to evaluate and measure the impact of tax risks.
  • Learn to prioritise tax risks based on their potential impact and likelihood, ensuring effective resource allocation.
  • Understand how to assess the financial, operational, and reputational consequences of identified tax risks.
  • Integrate tax risk assessments into broader organisational risk management and strategic planning processes.
  • Apply assessment techniques through case studies to enhance practical understanding and problem-solving abilities.
  • Improve the ability to communicate the findings of tax risk assessments to stakeholders clearly and effectively.

Unit 3: Transfer Pricing as a risk for MNEs

Aim

This unit examines the complexities and challenges multinational enterprises (MNEs) face regarding transfer pricing regulations. It explores how transfer pricing can pose significant tax risks, including compliance issues, financial penalties, and reputational damage.

Learning Outcomes

On successfully completing this UNIT, the participant will be able to:

  • Understand transfer pricing principles and regulations affecting multinational enterprises (MNEs).
  • Identify and evaluate the specific tax risks associated with transfer pricing in an international context.
  • Apply compliance requirements for transfer pricing and the potential consequences of non-compliance.
  • Develop strategies to manage and mitigate transfer pricing risks effectively.
  • Understand the financial implications of transfer pricing on an MNE’s overall tax burden.
  • Implement proper documentation and reporting practices to support transfer pricing policies and defend against tax authority challenges.
  • Apply theoretical knowledge to real-world scenarios through case studies – enhancing practical understanding of managing transfer pricing risks.
  • Improve the ability to communicate transfer pricing issues and risk management strategies to relevant stakeholders.

Unit 4: Working with Tax Authorities

Unit 5: Preparing for Tax Disputes

Aim

This unit focuses on the strategies and best practices for anticipating, preparing for, and managing tax disputes. It covers the procedural and substantive aspects of tax litigation, including evidence gathering, legal frameworks, and effective negotiation techniques.

This unit aims to equip participants with the necessary skills to navigate the complexities of tax disputes and achieve favourable outcomes.

Learning Outcomes

On successfully completing this unit participants will be able to:

  • Understand the legal frameworks governing tax disputes.
  • Apply their skills in gathering and organising evidence to support a position in a tax dispute.
  • Implement various techniques and strategies for effectively managing and resolving tax disputes.
  • Acquire knowledge of the procedural aspects of tax litigation, including timelines, filings, and court procedures.
  • Understand how to assess the risks and potential outcomes associated with tax disputes.
  • Improve negotiation skills to achieve favourable settlements in tax disputes.
  • Apply theoretical knowledge to real-world scenarios through case studies, enhancing practical understanding of managing tax disputes.
  • Enhance the ability to communicate effectively with legal advisors, tax authorities, and other stakeholders during a tax dispute.

Unit 6: Tax Dispute Engagement

Aim

This unit delves into the proactive and reactive strategies involved in managing tax disputes with authorities. It covers the entire dispute resolution process, from initial engagement and communication with tax authorities, through to negotiation, mediation, and litigation.

This unit aims to equip participants with the knowledge and skills to effectively handle tax disputes, while minimising risks and achieving favourable resolutions.

Learning Outcomes

On successfully completing this unit, participants will be able to:

  • Understand the processes involved in tax dispute resolution, including negotiation, mediation, and litigation.
  • Develop strategies for effective engagement with tax authorities during disputes.
  • Improve communication skills to clearly and effectively present arguments and positions to tax authorities and other stakeholders.
  • Identify, assess, and manage risks associated with tax disputes.
  • Acquire advanced negotiation techniques to achieve favourable outcomes in tax disputes.
  • Apply knowledge through case studies to understand practical aspects of managing tax disputes.
  • Understand the legal and procedural frameworks governing tax dispute resolution.
  • Enhance skills in preparing documentation and gathering evidence to support dispute resolution efforts.

Unit 7: Dispute Options

Aim

This unit explores the various pathways available for resolving tax disputes, including administrative appeals, mediation, arbitration, and litigation. It provides an in-depth analysis of the advantages, disadvantages, and strategic considerations of each option.

This unit aims to equip participants with the knowledge to choose the most effective dispute resolution method tailored to specific situations and organisational needs.

Learning Outcomes

On successfully completing this unit, participants will be able to:

  • Implement the different tax dispute resolution methods, including administrative appeals, mediation, arbitration, and litigation.
  • Develop the ability to evaluate and choose the most appropriate dispute resolution option, based on specific circumstances and organisational needs.
  • Understand the advantages and disadvantages of each tax dispute resolution method.
  • Apply their knowledge of the procedural requirements and processes involved in each dispute resolution option.
  • Learn to assess the risks, costs, and potential outcomes associated with various dispute resolution methods.
  • Apply theoretical knowledge to real-world case studies to enhance practical understanding of choosing and managing dispute resolution options.
  • Improve skills in communicating the chosen dispute resolution strategy and its rationale to stakeholders.
  • Understand how different dispute resolution options can be integrated into broader tax risk management and corporate strategies.

Unit 8: Going to Trial and thereafter

Aim

This unit focuses on the final stages of the tax dispute resolution process – including preparing for trial, conducting trial proceedings, and post-trial activities. It covers trial strategies, the role of legal representation, and the steps taken after a court decision.

This unit aims to equip participants with the skills needed to navigate the complexities of tax litigation and manage the aftermath effectively.

Learning Outcomes

On successfully completing this unit participants will be able to:

  • Develop skills in preparing for tax litigation, including evidence compilation, witness preparation, and crafting legal arguments.
  • Apply the procedures and strategies involved in conducting a tax trial.
  • Understand the importance of, and how to effectively work with, legal representation during trial.
  • Learn the action-steps following a court decision, including compliance with judgments, filing appeals, and managing outcomes.
  • Acquire the ability to assess and manage risks associated with going to trial and post-trial scenarios.
  • Improve the ability to communicate trial strategies and outcomes to stakeholders clearly and effectively.
  • Apply theoretical knowledge to real-world scenarios through case studies, enhancing practical understanding of trial and post-trial processes.
  • Understand how trial and post-trial activities integrate into broader tax risk management and corporate strategies.