Corporate tax advisory

The question and deliverable

We establish the facts, applicable period and precise question, compare available positions and document assumptions, risks and implementation dependencies. The deliverable is agreed as a written note, computation or decision discussion.

Frame the decision in terms the company can act on: the alternatives under consideration, the intended implementation date and the commercial constraints. Identify which facts are settled and which depend on negotiations or future performance. The analysis can then show how a change in those assumptions affects the comparison, rather than presenting one estimate as a certain outcome.

Evidence to prepare

• Company structure
• financial projections
• contracts
• prior elections and returns
• transaction documents
• intended commercial outcome.

Provide the working financial model alongside the underlying accounts and agreements. Keep historical tax positions and elections identifiable by period, with the supporting acknowledgements where available. Reconcile material differences between the management forecast and the figures used in the tax calculation. Where a fact is supplied verbally, record who will confirm it before the advice is finalised.

A fact that can change the analysis

A tax choice that appears attractive in one year may affect later deductions or exit options. Model the whole decision rather than comparing one headline rate.

For example, an option may look preferable when the forecast assumes immediate profitability but compare differently if expansion costs delay that profit. A useful decision model shows the alternative operating assumptions separately and explains which questions need further investigation. The purpose is to make the dependency visible, not to treat an optimistic forecast as an established fact.

Engagement boundaries

A proposal identifies the questions covered. Valuation, foreign advice, filings and representation are separate workstreams.

The written proposal confirms the taxpayer, period, deliverables and fees. Identify any payment, response or appeal date at the start.

The written handover records the question answered, alternatives assessed, assumptions and recommended next actions. Assign responsibility for any election, document change or filing separately from the advice itself. If the final commercial terms differ from the reviewed proposal, identify the differences for reassessment before implementing the earlier conclusion.