Executive Briefing · Tax Governance
Tax Governance for Large Companies: Making Tax Risk Visible to the Board
A tax governance framework clarifies who identifies tax risk, who decides, and how decisions are documented.
PrimeTax Editorial Team
01 — Tax Advisory
Corporate Tax Advisory for Decisions That Matter
Understand the tax implications of business decisions, evaluate available options, and document the reasoning behind material tax positions.
Client situations
When Companies Engage Us
A material transaction is being negotiated
Contract terms, payment flows, and entity choices can change the tax outcome. Management needs the implications before signing, not after.
Tax positions rely on interpretation
Some positions depend on how regulations are read. Finance teams need a documented basis that can be explained to auditors, boards, and the tax office.
Uncertainty about historical exposure
Differences between commercial reporting and tax filings, or changes in business model, can create exposure that has not yet been quantified.
Governance expectations are rising
Boards and regional headquarters increasingly expect a clear framework for how tax risk is identified, escalated, and decided.
Scope of assistance
What We Cover
- Tax Health Check
- A focused diagnostic of key tax areas to identify potential exposure, documentation gaps, and priorities for attention.
- Corporate Tax Review
- Review of corporate income tax, VAT, and withholding tax positions against supporting records and applicable regulations.
- Tax Planning
- Evaluation of lawful options for structuring transactions and operations, with the risks and assumptions of each option set out clearly.
- Tax Opinion and Second Opinion
- Written analysis of a specific tax question, including facts relied on, regulatory basis, interpretation, and limitations.
- Tax Risk Assessment
- Identification and prioritisation of tax risks by likelihood and potential impact, presented in a format management can act on.
- Tax Governance
- Design or review of tax policies, roles, controls, and escalation procedures appropriate to the size and complexity of the group.
Engagement process
How the Work Is Structured
- 01
Understand
Clarify the business question, the decision timeline, and the agreed scope of review.
- 02
Assess
Review facts, contracts, filings, and records against applicable regulations.
- 03
Advise
Present findings, options, and risks in writing, with a clear recommendation where appropriate.
- 04
Support
Assist with agreed implementation steps or follow-up questions from management and auditors.
Considerations
Regulatory and Technical Context
Regulatory change
Indonesian tax rules have changed significantly since the Harmonisation of Tax Regulations Law (UU HPP, Law No. 7 of 2021) and the move to the Coretax administration system. Positions taken under earlier rules may need to be revisited.
Documentation matters as much as the position
A defensible position depends on contemporaneous documentation of facts and reasoning, not only on the conclusion reached.
Planning must have commercial substance
Tax planning is evaluated against the commercial purpose of an arrangement. Options that lack substance carry heightened risk and are not recommended.
Summary for general information only. Regulations are applied to the specific facts of each engagement.
How we present exposure to management
Likelihood
Reconciliations
Intragroup charges
Treaty documents
Filing timing
LowMediumHigh
Impact
FAQ
Frequently Asked Questions
What is the difference between a Tax Health Check and a Corporate Tax Review?
A Tax Health Check is a focused diagnostic designed to identify priority areas quickly. A Corporate Tax Review goes deeper into selected taxes and periods, testing positions against records and regulations. Many clients start with a Health Check and then scope a review of the areas it highlights.
Can PrimeTax provide a second opinion on advice from another advisor?
Yes. A second opinion reviews the facts, assumptions, and regulatory basis of an existing position and states whether we agree, disagree, or see additional risks. We will ask to see the original analysis and the underlying facts.
Do you guarantee tax savings?
No. We evaluate lawful options and explain their risks and assumptions so management can make an informed decision. Outcomes depend on facts, implementation, and the position taken by the tax authority.
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PrimeTax Editorial Team
Request a Tax Risk Diagnostic.
Share the context of your matter. We will propose a scope and approach for an initial discussion.