Key takeaways:

• • • Stability is the story 鈥� The OBBB’s main value has been predictability for business planning, not sweeping new rules 鈥� a sharp contrast to the disruption of prior major tax legislation like the TCJA.

    • Section 1202 is a live opportunity 鈥� The expanded QSBS exclusion has reopened planning conversations around corporate structuring that had cooled in recent years.

    • Plan for both today and tomorrow 鈥� Practitioners should help clients capitalize on current certainty while preserving flexibility, and they should help clients build tax positions that can hold up to increasingly AI-powered IRS scrutiny.

When major tax legislation lands, the instinct is to brace for upheaval. But one year after the passage of the (OBBB) Act, the consensus among practitioners is notably different: The OBBB didn鈥檛 rewrite the rules so much as confirm them, and that distinction has mattered more than it might sound.

Certainty over seismic change

Unlike the (TCJA) 鈥� which was passed in 2017, mostly took effect the following year, and forced practitioners to relearn much of the code 鈥� the OBBB’s significance lies less in what it changed and more in what it settled. It gave businesses a stable set of rules to plan against, rather than a moving target to which to react.

“From a purely tax lens, it was… easier to unpack than in prior years because there are fewer seismic changes,鈥� says , Partner at Plante Moran, reflecting on the past year under the OBBB. 鈥淚t was providing a lot of clarity that just [meant], at least for the next several years, we had the rules.”

That clarity is not a small thing. Multi-year business decisions 鈥� around such big-ticket items as entity structuring, capital investment, and succession planning 鈥� depend on practitioners being able to tell clients that the rules will hold. Thus, OBBB’s real contribution was buying back that predictability.

Section 1202 comes back to life

If one provision captures the OBBB’s practical impact, it’s the revitalization of 鈥� the qualified small business stock (QSBS) gain exclusion. The expansion of this program has done more than simply adjust a technical detail; indeed, it has reopened a whole category of planning conversations that had gone quiet.

“The action around the qualified small business stock gain exclusion… has really reinvigorated the Section 1202 planning conversations,鈥� Eckert explains. 鈥淯ltimately, what we got was an expansion of the program. So, what that has done is reinvigorated those conversations around planning into corporate structures.”

For founders, investors, and the tax advisors who serve them, that means is back on the table 鈥� and often earlier in a company’s lifecycle than before, since the incentive to structure correctly from the outset is now more valuable.

A new kind of advisory opportunity

Of course, stability doesn’t mean passivity. If anything, the OBBB has expanded what tax professionals can offer clients. With a known set of rules, advisors can move beyond compliance and into genuine strategy by helping clients maximize their position under current law while still preparing for the fact that today’s certainty has a shelf life.

That balance 鈥� seize the moment, but don’t get comfortable 鈥� is a concept that isn鈥檛 lost on many tax specialists. “Maximize your opportunities today but also have a long-term view while having flexibility and preserving flexibility wherever you can, and knowing and anticipating that there could be future changes,” Eckert says, framing this moment as a broader opening for the profession, not just a technical one.

Legislative clarity, he argues, gives practitioners a reason to go deeper with clients than simply processing the next filing. “From a practitioner lens, I think [legislative changes] are a huge opportunity… giving us an opportunity to really bring value to our clients and to also get to know our clients better,鈥� he notes. 鈥淚t’s been, in a certain sense, a great opportunity to just build deeper relationships.”

In other words, the firms getting the most out of this environment aren’t the ones treating the OBBB as a compliance checklist; rather, they’re the ones using it as a reason to have a better conversation with clients about where they’re headed.

The IRS isn’t standing still either

The one area in which practitioners should definitely not get comfortable is enforcement. A smaller IRS workforce doesn’t mean lighter scrutiny 鈥� it likely means a different kind. As the agency leans more heavily on AI-driven tools, its ability to examine returns at scale is set to expand even as headcount contracts.

“I think across the board, we’re certainly aware of that and are counseling clients on the need to establish and build positions and think carefully about it,鈥� Eckert explains. 鈥淚n a world of AI-enabled tools, the scrutiny may actually increase, and the ability for the IRS to quickly and efficiently examine lots of data is something that could certainly exist.”

That means that tax advisors need to help their clients build positions that can withstand more sophisticated review, not less. Meticulous documentation and defensible reasoning matter more, not less, in an environment in which fewer human examiners can still cover more ground with better tools.

One year in, the OBBB’s legacy isn’t a story of dramatic reform, but rather it’s a story of tax firms and their clients finally getting room to plan. The tax advisors making the most of that room are the ones using it to build sharper strategies and deeper client relationships, all while keeping an eye on an IRS that’s quietly getting more capable of deeper examination.

You can find more of听our coverage of the One Big Beautiful Bill Act听here

Key insights:

• • • AI adoption has become an urgent business imperative 鈥� Enabling corporate functions are under pressure from leadership, business stakeholders, and employees to demonstrate tangible AI-driven value.

    • Slow AI adoption creates risk 鈥� Many professionals are frustrated by limited access to high-quality AI tools, which contributes to increased employee turnover and growing use of unauthorized shadow AI

    • Success depends on coordinated transformation 鈥� Organizations need a deliberate AI strategy rather than scattered experimentation to help guide responsible AI adoption across the organization.

Today, internal corporate enabling functions 鈥� such as legal, tax, global trade, compliance, and risk 鈥� find themselves at a crossroads as they face mounting pressures from three critical fronts: i) internal stakeholders that are demanding faster, more informed decisions; ii) finance departments that are expecting AI-driven efficiency and cost control; and iii) a professional workforce eager for tools that enhance the value of the work they do.

The message from the C-Suite is clear: AI must deliver tangible results now, according to the recent 成人VR视频听2026 Future of Professionals Report.

To help internal corporate function leaders manage this pressure and move forward with confidence into an AI-enabled future, 成人VR视频 has published a new action paper, Future of Professionals Report 2026: Actionable insights for corporate leaders, drawing on insights from hundreds of internal corporate professionals.

Facing down the triple pressures

The urgency that corporate function leaders are facing is underscored by those three areas of pressure. For example, almost half of professionals surveyed in enabling functions say they are either already experiencing the financial consequences of lagging AI adoption or are expecting to within a year. Many enabling functions have long been expected to absorb growing workloads without proportional increases in resources. Now, AI is increasingly viewed as a way to expand capacity and improve efficiency, making delaying its adoption a potential source of budgetary and competitive risk.

You can download your copy of the听2026 Future of Professionals Report听here

Stakeholder pressure is equally intense. As many business units accelerate their own AI deployments, they expect the organization鈥檚 other enabling functions to keep pace. If these functions become bottlenecks, they risk being sidelined or being perceived as obstacles rather than strategic partners. Indeed, more than half of corporate professionals say they are facing significant pressure from stakeholders to act faster on AI, with in-house legal teams feeling this most acutely.

Yet the pressure coming from the workforce may be the most alarming. The action paper shows that fully 30% of professionals say they are considering leaving their organizations within two years if the gap between the AI-driven value they expect and what is made available to them isn鈥檛 addressed. Access to professional-grade AI tools has become a key factor in job decisions, yet nearly 6-in-10 professionals say they lack access. This gap contributes to both retention challenges and the rise of unauthorized AI use, increasing compliance and governance risks.

Choosing the right path

Faced with the reality of these pressures, corporate function leaders must choose a strategic path for AI adoption. The action paper outlines three primary trajectories:

• • • Using AI to elevate by shifting human effort to high-value, judgment-based work.
    • Using AI to scale by leveraging AI to handle increased workloads without increasing headcount while optimizing for efficiency.
    • Using AI to reimagine by rebuilding workflows around AI鈥檚 capabilities, such as implementing shared data infrastructure and real-time dashboards.

However, knowing the path is not the same as walking it. The action paper also highlights a potential execution gap, in which a lack of coordination and shared accountability across functions derails any real progress. This is a particular problem for enabling corporate functions because many departments often operate in silos, using different AI tools and standards, which leads to fragmentation and operational bottlenecks.

The solution, as the paper outlines, lies in building a shared framework for AI governance and accountability, with fiduciary functions like legal, tax, and compliance taking the lead. Some critical recommendations outlined in the paper include advocating for professional-grade AI tools, planning for an evolutionary journey through AI adoption, and leading an organization-wide conversation about AI governance and standards.

Finally, the paper encourages corporate leadership teams to step back from daily pressures and engage in structured exercises to define a shared vision for AI within the organization. By developing a long-term roadmap that considers processes, data, technology, people, and risk, corporate leaders can ensure AI adoption delivers both immediate value and sustainable competitive advantage for the future.

You can read a full copy of the听Future of Professionals Report 2026: Actionable insights for corporate leaders paper here

Key takeaways:

• • • Understanding is not preparation 鈥� Most EU businesses are aware of 鈥� but not necessarily prepared for 鈥� the sweeping changes that ViDA is bringing.

    • Few businesses have a solid transition plan in place 鈥� Only 22% of tax and finance professionals surveyed say their organization has a formal, funded ViDA transition program in place.

    • Some key requirements are already changing 鈥� With e-invoice and real-time reporting requirements already shifting, businesses are in danger of falling behind, risking business continuity and non-compliance.

The European Union鈥檚 reforms around its value added tax (VAT) 鈥� known as VAT in the Digital Age (ViDA) 鈥� represent the most significant shift in tax compliance for businesses operating in the EU in a generation. ViDA is more than merely another new compliance requirement or technology upgrade. Indeed, many organizations will need to modernize their entire invoicing and tax reporting systems to get into compliance.

Jump to 鈫�

The new compliance horizon: 2026 ViDA Readiness Report

While ViDA鈥檚 EU-wide mandates for cross-border e-invoicing and digital reporting take effect in 2030, the pressure on organizations is already mounting as individual EU member states roll out a patchwork of national requirements.

Digging deeper on this, a new report from the 成人VR视频 Institute, , reveals a striking paradox in how EU tax and finance professionals are preparing for this overhaul. While awareness is nearly universal, a significant gap remains between awareness of ViDA and tax teams鈥� readiness for its changes.

Indeed, 86% of EU tax and finance professionals say they are familiar with ViDA; however, a deeper look reveals that only 35% possess a detailed understanding of the specific requirements of the regulatory reform package. This creates a state of “comfortable uncertainty,” in which high initial confidence can often mask a lack of preparation for the massive technological and operational changes ahead.

Riding the 鈥淐onfidence Curve鈥�

One of the most compelling findings from the report is the “Confidence Curve” that shows how many organizations often start their journey with high levels of optimism. In fact, even among respondents who say their organization does not yet have a transition program in place or has one that is fragmented across EU member states, 90% say they feel confident in their organization鈥檚 ability to achieve ViDA compliance.

However, the Confidence Curve shows that confidence often regresses during the assessment and planning phase. As teams begin to uncover the complexities of new multi-jurisdictional compliance and real-time reporting requirements, the percentage of respondents who say they are “not very confident” doubles. It is only after a program is funded and embedded into digital transformation strategies that confidence strongly rebounds.

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Despite the high stakes, the majority of organizations are still finding their footing, the report shows. Unfortunately, more than three-quarters (78%) of respondents say their organization has no formal, funded ViDA transition program with central governance in place, meaning that they鈥檙e working in a fragmented country-by-country fashion or are still in the assessment stage.

These delays are risky Many EU member states have already begun rolling out e-invoicing mandates. That leaves those organizations without programs in place at greater risk of falling further behind.

The ViDA-enabled opportunity

Despite the massive changes in VAT requirements that ViDA brings, the reform package also offers corporate tax functions a tremendous opportunity to elevate themselves from a cost center to a strategic business partner. As the report outlines, taking that path forward requires a cross-functional commitment across numerous corporate functions, including tax, finance, IT, and legal departments.

Yet, those organizations that move beyond providing the “minimum viable compliance” and instead take the opportunity to invest in standardized data and central governance will be better positioned to turn these regulatory mandates into a compliance advantage for the tax function and a competitive advantage for the organization going forward.

You can download

a full copy of the 成人VR视频 Institute’s 听here

Key takeaways:

• • • Mandatory compliance mandates are growing 鈥� Pillar 2, DAC6, and other real-time reporting mandates are increasing obligations in dozens of jurisdictions today, and those tax departments without the infrastructure to meet these obligations are already behind.

    • Real-time documentation is critical 鈥� The window between a transaction occurring and a tax authority scrutinizing it is shrinking to near zero in some markets, meaning that documentation must exist at the moment it is generated, not reconstructed afterward.

    • Data quality is compliance quality 鈥� Real-time compliance brings with it heightened pressure to avoid incomplete or inconsistent inputs, because increasingly sophisticated analytics used by tax authorities will find them.

In 2023, a major European manufacturer was hit with a seven-figure penalty not because its tax return was wrong, but because it couldn’t demonstrate how it arrived at the right answer. No documented governance framework, no clear ownership, and no audit trail. The numbers were defensible, but the process wasn’t.

That gap 鈥� between getting the right answer and being able to prove it 鈥� is where corporate tax risk now lives.

Governments and tax authorities worldwide are to self-report accurately. They are building legal frameworks, digital infrastructure, and enforcement mechanisms to verify compliance in real time. And for tax departments accustomed to managing compliance on their own terms, the window for a comfortable transition is closing fast.

A global tightening

Tax governance requirements are intensifying on multiple fronts. In the United States, for example, the IRS’s Large Business & International division has significantly expanded its compliance campaigns, targeting transfer pricing, research & development (R&D) credits, and multinational structures. Section 174 of the 2017 Tax Cuts and Jobs Act now requires companies to amortize R&D expenditures over five or 15 years depending on where research occurs 鈥� a change that many tax departments are still working through while absorbing new obligations on top of it.

Internationally, the pace is faster still. The framework that the Organisation for Economic Co-operation and Development (OECD) created for its base erosion and profit shifting (BEPS) rules has been adopted by more than 135 countries. Pillar 2 鈥� the global 15% minimum corporate tax rate 鈥� is already in effect in dozens of jurisdictions and is actively reshaping how multinationals structure their tax affairs. These are not coming changes 鈥� they are current ones.

Mandatory disclosure regimes have expanded in parallel. The European Union’s DAC6 directive requires intermediaries and taxpayers to report potentially aggressive cross-border arrangements, with penalties in some member states reaching hundreds of thousands of euros. The United Kingdom’s Senior Accounting Officer regime goes even further, placing personal legal accountability on named senior executives for the adequacy of their company’s tax accounting arrangements. Similar regimes are expanding in Australia, Canada, and Brazil.

These are not isolated experiments. They represent that is not going to reverse any time soon.

The real-time reporting challenge

That means, corporate tax departments must respond to this shift because the traditional audit model 鈥� authorities review historical returns and request documentation years later 鈥� is being replaced in a growing number of markets. Spain, Hungary, and South Korea already require taxpayers to submit transactional data directly to tax authorities through mandatory electronic systems. The EU’s Value added tax (VAT) in the Digital Age initiative will extend similar requirements across all 27 member states beginning in 2028.

For tax departments, this reporting compression is the central operational challenge of the next five years. A team that once had 12 to 18 months to reconstruct documentation for an audit now needs that documentation to be accurate and defensible at the moment it is generated. That requires a fundamentally different operating model 鈥� not just better record-keeping, but automated data capture and real-time reconciliation built into core financial systems 鈥� along with the ability to transfer that documentation electronically in real time.

3 actions tax departments must take now

To begin to address this dramatic change, corporate tax departments need to act now, taking steps that include:

1. Building a formal governance framework

Tax departments need written governance frameworks that clearly define what party owns each compliance decision, how decisions are reviewed and approved, and what controls exist to catch errors before filing. This means named ownership of obligations, documented sign-off processes, and regular internal reviews against a compliance calendar.

In the UK, this is already a legal requirement ; and similar standards are emerging in Germany, Australia, and across the EU. A framework should cover at minimum; the ownership of each material filing obligation; the review and approval chain for positions taken; escalation procedures for uncertain tax positions; and a schedule for internal control testing. Without these processes in place, tax departments could face regulatory penalties, personal liability for senior leaders, and reputational damage that may be difficult to recover from.

2. Fixing the data access problem

Tax departments consistently lack reliable, timely access to the financial data they need. This is primarily an organizational problem, not a technology one. Tax functions often sit downstream from finance systems designed without tax requirements in mind 鈥� meaning data often arrives aggregated, reclassified, or stripped of the granularity needed for compliance work.

Solving this requires tax leaders such as finance, IT, and business operations 鈥� not just to request data, but to influence how that data is captured at its source. That means participating in enterprise resource planning implementations, establishing data requirements for new business lines before they launch, and building direct feeds from source systems rather than relying on manual extracts.

3. Treating data hygiene as a compliance control

Tax authorities in the UK, the Netherlands, Germany, and the US are deploying advanced analytics to identify anomalies in corporate filings. Unexplained variances between statutory accounts and tax returns, inconsistencies in intercompany pricing, or mismatches between VAT and corporate income tax data could all trigger closer scrutiny.

Data hygiene must be treated as a compliance control, not an IT issue. In practice that means establishing reconciliation checkpoints between source data and tax inputs, maintaining documented data lineage so any figure in a return can be traced to its source, and conducting data quality reviews before filing deadlines 鈥� not after.

The bottom line

The regulatory trajectory is set, so that means the question for tax leaders whether their department will be ready when tested. Governance, data access, and data quality are no longer back-office concerns 鈥� they are the foundation upon which defensible compliance is now built.

Tax department leaders need to build that foundation now, before the examiner asks.

You can find out more about

Key insights:

• • • Real-time tax compliance has restructured the tax function 鈥� Dozens of nations now require structured invoice data in real time, with the EU mandating cross-border digital reporting by 2030. The traditional file-and-wait audit cycle is gone now, replaced by clearance regimes that can freeze multi-million-dollar invoices for nonconforming data.

    • Regulators have pulled ahead of the businesses they oversee 鈥� Tax authorities in mature CTC jurisdictions now arrive at audits with structured transaction data already processed by their own analytics. Government turnaround times that took months now take weeks, forcing multinational tax leaders to compress multi-year roadmaps into 12- and 18-month cycles to keep up.

    • The lessons travel beyond tax 鈥� There are two ways to lose this race: Outrun your own controls or surrender entirely. Both showed up in Las Vegas, and both will show up in every other regulated profession over the next decade.

LAS VEGAS 鈥� The听 sold out. A guest list that included tax directors from Amazon, Walmart, and Procter & Gamble, OpenAI’s tax department, the Big Four, 成人VR视频 and every other major tax software provider in the market spent three days at the Aria with pool deck, casino floor, and restaurants worth lingering over all a few steps away.

The room had every reason to spend its evenings somewhere else other than a sunless conference room talking about tax. Yet almost no one did. They were too busy grappling with an arms race the corporate audit side had begun to suspect it was losing.

And it鈥檚 one they cannot afford to lose.

End of the traditional model

The arms race is real-time tax compliance, and it has dramatically restructured the ground beneath the tax profession in less than a decade. By April, more than 60 jurisdictions have moved or are moving to continuous transaction controls. Italy and Hungary were early; Poland, France, Belgium, Brazil, Saudi Arabia, India, and Singapore are now operational or imminent, and countries like Spain, Germany, the United Kingdom and the United Arab Emirates are on the way. The European Union has locked onto a 2030 deadline for cross-border real-time digital reporting and a 2035 backstop for harmonizing what’s left.

The traditional model 鈥� issue an invoice, file a return weeks later, audit when the auditor gets around to it 鈥� no longer exists in those jurisdictions. Tax authorities now see the transaction as it happens, validates it in structured form, and pre-fills the return on the taxpayer’s behalf.

What this new process has done to the tax function is fundamentally alter its structure in a way leaves practitioners reeling. The job used to be a craft of Excel, judgment, and institutional memory. Now, at the high end, it has become as much a data science problem as an accounting one.

The arms race is real-time tax compliance, and it has dramatically restructured the ground beneath the tax profession in less than a decade.

Attendees at TEI鈥檚 2026 Tax Technology Seminar polled themselves on tooling, and the answers came back as a list of data pipelines that dozens of attendees seemed to favor: Alteryx, Power Platform, Snowflake, Databricks, Microsoft Fabric, & Palantir Foundry. These platforms are running agentic AI systems against historical filings, deploying validation agents to critique their own outputs, and using AI-driven image-to-text solutions to pull structured data out of state tax notices that never arrive in the same format twice. They are data integration pipelines in 15 minutes that would have sat in an IT queue for two months before being answered.

They have little choice as the stakes are far higher and the challenges far more demanding than they used to be. In a clearance regime, an invoice has no legal force until the tax authority returns its identifier. Did you submit the wrong VAT ID, malformed schema, or mismatched master data? Congratulations! Your invoice is rejected. That means the truck doesn’t move, the buyer doesn’t pay an invoice that may be in the millions of dollars and then the penalties stack on top. Italy, for instance, charges a fee of 70% of the disputed VAT.

And then there are the audits.

Outgunned

The audit isn’t an occasional event anymore. In government jurisdictions with mature continuous-transaction-control tax regimes, it is a conversation that started weeks before the auditor walked in, on data their analytics had already processed.

A speaker on a seminar panel led by Deloitte and 成人VR视频 described the dynamic plainly: Tax authorities in those jurisdictions have arrived at audits already knowing more about the transactions than the companies and their in-house audit teams sitting across the table. Not because anyone is hiding anything, but because the data arrived at the tax authority in structured form, in real time, and the authority had run its analytics on it before the meeting was even on the calendar. One panelist said this represents “a shift from us preparing returns to us answering notices on the data that’s been shared.”

What the room kept circling around, however, was that regulators have not just kept pace with their counterparties, they鈥檝e now pulled ahead. Singapore, one panelist noted, is doing more with AI than even major companies. Indeed, government turnaround times that used to take months are now closing in weeks, which is forcing multinational tax leaders to compress their multi-year roadmaps into 12- and 18-month cycles 鈥� not because they want to but because their counterparties already had.

The lesson that corporate tax functions have been forced to absorb is that there are two ways to lose this race, and both were on display at TEI鈥檚 2026 Tax Technology Seminar as cautionary tales.

This asymmetry is structural, and that is what makes it an arms race rather than a transition. There is no version of this dynamic in which the company being audited wins by being more careful, more thorough, or more well-prepared at the end of the quarter. The advantage now accrues to the side with the fastest and cleanest pipelines, that runs the smartest AI, and that understands the way these increasingly complex systems interact. Increasingly, that winning side is the government. And, more alarming, this isn鈥檛 just a problem for this particular industry 鈥� tax just happened to get here first. However, it鈥檚 coming for everyone.

Two ways to lose

The lesson that corporate tax functions have been forced to absorb is that there are two ways to lose this race, and both were on display at TEI鈥檚 2026 Tax Technology Seminar as cautionary tales. The first is to outrun your own controls. AI coding tools that let a tax analyst build a working data integration pipeline in 15 minutes are genuinely valuable; they also let that same analyst deploy something nobody else has reviewed, documented, or knows how to maintain. An OpenAI panelist conceded the point when an audience member asked about the security implications of vibe coding 鈥� clearly, a new capability is also a new problem.

The second way to lose is harder to talk about. One panelist described, to attendees鈥� general dismay, hearing of companies that have given up on compliance entirely 鈥� instead, they pad their numbers with a safety margin and treat the eventual audit as the cheaper of the two costs. The panel recoiled 鈥� one member responded with a flat “Do not do this.” However, the anecdote landed because it isn’t theoretical. When the gap between what regulators can see and what your team can produce becomes wide enough, surrender starts to look rational.

Playing to win

Of course, the attendees at TEI鈥檚 2026 Tax Technology Seminar were not surrendering. If they were, they’d have been at the pool deep into their third cocktail. Or they’d have been on the casino floor or were about to catch an afternoon show. Instead, day after day, the tables filled, the exhibit hall ran hot, and the room was buying, listening, and building.

The game has changed and the stakes have risen 鈥� and the room is dead set on playing to win.

You can find more of听our coverage of Tax Executives Institute events here

• • • The reactive phase is partly a mindset problem 鈥� More than half of tax departments remain stuck in reactive, compliance-focused operations, not only because of frozen budgets, but because of cost-center thinking that shapes cost-center behavior.

    • The value is there, but the measurement isn’t 鈥� Two-thirds of tax professionals say their department鈥檚 technology investment has already enabled more strategic work; yet 22% say they track no performance metrics at all, making that value invisible to the people who control the budget.

    • The rebrand starts internally 鈥� With AI integration timelines compressing to between 1 and 2 years, tax departments that shift their posture now by measuring wins, designating leadership, and building the business case will be better positioned to lead 鈥� and those that don’t will fall further behind, faster.

Apart from the sales department, most other departments within a business are simply viewed as a cost center, and the tax department is no exception. However, like so much of that thinking, this view isn鈥檛 quite accurate because it is the tax department that can uncover the most savings for the business.

You need not look further than recent data that shows while 67% of tax professionals say their department鈥檚 technology investment has already enabled them to do more strategic work, 22% say they track no performance metrics at all, making it difficult to demonstrate the tax department鈥檚 value to the C-Suite.

Given this, it鈥檚 somewhat unsurprising that this cost-center view persists. Worse yet, is often internalized by in-house tax teams themselves. It is one thing to be viewed and treated as a cost center but to act like one is a different matter.

So, what if the bigger problem isn’t how the rest of the business views the tax department but instead how the department views itself?

The , from the 成人VR视频 Institute and Tax Executives Institute, reveals a profession that knows it is capable of far more than it is currently delivering. And yet the same patterns repeat: Budgets stay flat, technology adoption stays slow, and a majority of departments remain stuck in a reactive phase in regard to their technological development that has “remained stubbornly consistent over the past few years,” according to the report.

That’s not just an organizational failure; rather, that’s a mindset problem 鈥� and it starts from within the tax department.

The choices we keep making

The report outlines a Technology Maturity Curve that maps a progression in tech development from chaotic through reactive, proactive, optimized, and predictive stages.

This year, 64% of respondents placed their tax department at the chaotic or reactive end of the spectrum 鈥� up from 57% last year. The reactive phase is the operational definition of a cost center: Heads-down, output-focused, and disconnected from the broader business.

The report reveals something even more important. In those cases in which the budget isn’t the primary constraint, behavior doesn’t change. Almost one-third of respondents (32%) said their strategy for addressing capacity constraints is process optimization 鈥� without new technology or additional hiring. Not because they can’t pursue more, but because that’s the default mode.

One respondent put it plainly: “鈥ur company as a whole is making significant changes, but the tax department is typically an afterthought in those decisions.”

This raises a question that鈥檚 worth asking: Who taught the company to treat tax as an afterthought?

There鈥檚 evidence showing that tax departments are more

The data to challenge the cost-center identity isn’t missing; rather, it’s just not being captured or communicated to the C-Suite.

Two-thirds of respondents (67%) said their tax department鈥檚 technology investment over the past three years has already enabled a shift toward more strategic, proactive work, such as data analytics, forecasting, risk assessment, and decision-making support. Among larger departments, nearly half (48%) are now spending more time on these higher-value activities. This clearly shows that companies that have invested in tax automation are reporting real results, such as improved accuracy, reduced errors, lower costs, and streamlined workflows.

And yet, 22% of tax departments track no technology performance metrics at all, according to the report 鈥� not time savings, not error reduction, not ROI. Nothing.

While 67% of tax professionals say their department鈥檚 technology investment has already enabled them to do more strategic work, 22% say they track no performance metrics at all, making it difficult to demonstrate the tax department鈥檚 value to the C-Suite.

That is cost-center thinking in action 鈥� the belief that it鈥檚 the job of the tax department to do the work, but not to prove its value. However, what isn’t measured can’t be communicated 鈥� and what can’t be communicated can’t change the perception, either internally or externally.

The rebrand starts with how departments see themselves

The most important audience for the tax department’s rebrand isn’t the C-Suite. It’s the department itself.

That means tracking wins and building a formal business case for investment 鈥� grounded in hard ROI and cost savings, which the report identifies as the metrics that are most important to Finance and IT, the two functions that frequently share control of the tax technology budget.

It also means getting serious about leadership. The portion of tax departments with a designated person leading tax technology strategy jumped to 88%, from 51%, in a single year. However, a title only goes so far; and the report is clear 鈥� that role only works when backed by a team that believes it belongs at the decision-making table.

Finally, this rebranding means treating AI as an opportunity, not a threat. The majority of tax professionals have compressed their expectations for AI integration to 1鈥�2 years, from 3鈥�5 years, with 7% saying AI is already central to their workflow. Those departments still locked in cost-center mode are the least prepared for that shift 鈥� because cost centers don’t invest ahead of the curve.

The narrative changes when the mindset changes

No one is going to rebrand the tax department on its own, it has to come from within. Further, it has to be built through deliberate measurement, consistent communication, and a shift in how tax professionals think about our own work.

Your department is not a cost center. The work proves it, and the data backs it up. Now, you should act like you believe it.

You can download a fully copy of the , from the 成人VR视频 Institute and Tax Executives Institute, here

Key takeaways:

• • • The AI tools demonstrated at the 2026 TEI Tax Technology Seminar were genuinely capable 鈥� These included agentic systems running live, nine-year-olds building software by voice, and automation pipelines deployed by major tax departments. The question of Does this work? is effectively settled.

    • That progress shifted the conversation to harder problems 鈥� Some of these problems are hallucinations that fail silently, governance vacuums in which tax rarely owns AI implementation, training rollouts that collapse when people aren’t ready, and rising token costs that could entirely change the economic case for automation.

    • The community’s defining posture wasn’t skepticism or hype 鈥� Instead, it was honest reckoning. Tax leaders believe in the tools and were actively deploying them but also are refused to treat capability as a substitute for the institutional work of process, ownership, and oversight.

“I think you are a very bad man,” said Dorothy.

“Oh, no, my dear; I’m really a very good man, but I’m a very bad Wizard, I must admit.”

鈥� The Wonderful Wizard of Oz, L. Frank Baum

LAS VEGAS 鈥� I arrived in Las Vegas a day early for the , which gave me one free evening before three days of packed sessions. Little question as to what I was going to do: The Wizard of Oz show at the Sphere.

It’s spectacular. The Sphere wraps you in imagery at a scale so vast if feels like you鈥檙e going to fall into it. The tornado shakes you like it鈥檚 going to rip the entire building apart and fling you to Oz right alongside Dorothy. The technology is genuinely, thrillingly good鈥� and that’s what makes the fissures so disorienting when you spot them. A munchkin’s head rendered as a 2D .png with a visible gap where the neck should be. A bad CGI effect. Dorthy flickering at the edges like a bad cutout on a green screen. You don’t catch the tech glitches when the spectacle is unconvincing; rather, you catch them precisely because it’s so good that the gaps have nowhere left to hide.

The next morning, I walked into the TEI Tax Technoloy Seminar and found three days of panels that played out the exact same dynamic 鈥� except the stakes were far more real.

A very good man

TEI organizers opened with the obvious joke: “We’re careful to limit the number of AI sessions,” they noted, before audibly pondering whether it was time to just rename the whole thing. Fair question, given how much has changed over eight annual iterations of this get-together. Indeed, if you’d been dropped into this event from its first meeting nearly a decade ago, you’d think you’d been dropped into Oz.

One presenter described her elementary-school-aged children building video games by dictating instructions to a coding tool, then showing the games running. That alone would have been science fiction five years ago. However, the room was full of it. OpenAI sent four members of its own tax department to demonstrate live automation pipelines. Google and Microsoft walked attendees through building AI agents with nothing more than a mouse and keyboard, making it look so easy my grandmother could have made it work.

One presenter described her elementary-school-aged children building video games by dictating instructions to a coding tool, then showing the games running. That alone would have been science fiction five years ago.

Down the hall, the advanced tax systems that many industry visionaries were dreaming about just two years ago weren’t theoretical anymore 鈥� they were running live. Tax directors from Amazon, Walmart, and a dozen other household names sat alongside Big Four advisors and every major tax software provider through three days of sessions, all of it sold out.

We were definitely not in Kansas anymore. Nor was this the AI of two years ago, the one that could draft a passable email or a poem but couldn鈥檛 so much as parse a spreadsheet. This was something materially different. The tools had crossed a threshold. They worked, and everything the profession had been promising for years was alive and functioning in the room.

And that changed the conversation entirely.

A very bad wizard

When the technology was half-baked, the debate was simple: Is this even possible? Skeptics said no, enthusiasts said give it time, and everyone argued about capability.

The 2026 TEI Tax Technology Seminar was the place where that argument effectively ended 鈥� not because the skeptics lost, but because the question became irrelevant. The tools were plainly, demonstrably good 鈥� indeed, a nine-year-old could use them and was.

The new question that arose was harder and less comfortable to discuss: What can’t AI do?

The room answered honestly and brutally. Someone described uploading a tax schedule to an AI agent and getting numbers that didn’t look right. When challenged, the AI confessed: I couldn’t open your file, so I was just telling you what you wanted to hear.

That anecdote landed differently than it would have two years ago. Back then, it would have been evidence that AI wasn’t ready. At the 2026 TEI Tax Technology Seminar, in a room in which people had just watched live agentic demos and were actively deploying these tools, it was evidence of something more unsettling: AI doesn’t fail loudly anymore. It fails quietly and even politely.

AI performs competence it doesn’t have, at a level of sophistication that鈥檚 just good enough because it is genuinely smarter than it was a few years ago, and it will get away with it unless a human knows enough to push back. Like its counterpart in Oz, this makes an AI tool is a very good man 鈥� genuinely useful, genuinely capable 鈥� and sometimes a very bad wizard. It can’t do the thing you actually need it to do on its own, but it may try to trick you into thinking it did.

AI performs competence it doesn’t have, at a level of sophistication that鈥檚 just good enough because it is genuinely smarter than it was a few years ago, and it will get away with it unless a human knows enough to push back.

That theme echoed across three days of honest, sometimes uncomfortable conversations that went beyond just the technology itself. A transformation director confessed to deploying a training program across dozens of global clients and failing spectacularly. A tool designed to save two hours of work suddenly consumed an entire day because the people who鈥檇 actually had to use it hadn鈥檛 been consulted. Others described Alteryx workflows nobody could explain because the person who built them had left the company without documenting the logic.

And, more concerning, when the room was polled on whether the tax function actually owns AI implementation at their company, two hands went up out of more than 50. Human-in-the-loop was a constant refrain, of course, but attendees confessed to grappling with how to review an ever-increasing volume of work when the errors were increasingly polite, quiet, and technical.

Of course, the professionals at the seminar weren鈥檛 dismissing the technology, which is what made the honesty remarkable. As one senior director said flatly: “You will not survive in this field if you don’t have a change mindset.” They believed in the tools, and they were buying them, deploying them, building around them. They just refused to pretend the tools alone would be enough.

Going home

Overall, the 2026 TEI Tax Technology Seminar was the place that the tax technology community stopped debating whether the Wizard was real and started grappling with the fact that he couldn’t get them home.

That’s not disillusionment; indeed, it’s the opposite. Dorothy doesn’t have her crisis when Oz looks fake, she has it after she meets the Wizard and discovers he’s real but insufficient 鈥� that his balloon won鈥檛 get her home. And unlike Baum’s Wizard, the magic isn’t a fraud 鈥� which is precisely what makes the problem harder. A humbug you can dismiss, but real capability that still can’t get you home? That’s the problem you actually have to solve.

Like Dorothy, today鈥檚 tax leaders will have to click their ruby slippers themselves.

You can find more of our coverage of Tax Executives Institute events here

Key highlights:

• • • Technology satisfaction is in freefall and needs human-side investments 鈥� Satisfaction with tax technology dropped sharply to just 34%, from 56%, in a single year, even as many tax departments continued investing in tools.

    • Training cutbacks are accelerating, as the AI era deepens 鈥� Only 50% of tax departments provided technology training in 2025, down from 59% the prior year.

    • Hiring changes reveal a false choice between tax expertise and tech fluency 鈥� After years of prioritizing tech and IT hires (which were 57% of new roles in 2024), tax departments sharply reversed course, with 62% of new hires in 2025 emphasizing tax expertise over technology skills.

After years of investing in tax technology, corporate tax departments have yet to see peak efficiency because of underdevelopment in workforce training and a growing mismatch between what advanced AI tools can do and what employees can handle. In fact, the , from the 成人VR视频 Institute and Tax Executives Institute, reveals that satisfaction with tax technology has plummeted to just 34%, from 56%, in a single year.

That leaves many tax departments struggle with a widening frustration gap between what they want to achieve and what their current tools will allow. The key to closing this chasm is for heads of tax to reinvest in the human-side of their technology capabilities.

Tech competency remains a challenge

Only 9% of tax professionals rate their colleagues as very competent with technology, according to the report. The majority (60%) said they consider their teams merely somewhat competent, while nearly one-third admit their departments lack technological competence altogether.

What makes this especially alarming is that larger companies with more resources are almost three times more likely to report competency gaps, with 39% of professionals saying this, compared to just 15% at smaller firms. Indeed, these larger organizations are the ones that have invested most heavily in sophisticated tech stacks and should theoretically have the most capable users.

Perhaps a reason for this competence gap is the failure to invest in consistent technology training and knowledge-sharing among peers. Despite being one of the most cost-effective performance levers available, only 50% of corporate tax professionals surveyed said their departments provided technology training in 2025. This is down from 59% the previous year.

This training deficit has consequences because most corporate tax departments remain stuck in the reactive or chaotic phase of technological maturity. Meanwhile, AI timelines are compressing rapidly. In fact, 39% of tax professionals said they now expect AI to be central to their workflow within 1 to 2 years, up from the 31% who thought it would take that long just last year.

Pendulum swing in hiring

The 2026 Corporate Tax Technology Report also reveals a dramatic reversal in hiring priorities that deserves careful attention. In 2024, 57% of new tax department roles were dedicated to tech/IT expertise, with only 24% prioritizing tax knowledge. By 2025, the script had completely flipped, with 62% of new hires now emphasizing tax expertise.

At smaller companies (those with revenue of less than $1 billion), the swing is even more extreme. In fact, 100% of new hires are now those with tax expertise rather than technology specialists.

This pendulum swing likely reflects a correction after years of heavy tech/IT hiring combined with greater technological maturity that subsequently requires less technology expertise. At the same time, however, the solution is not one or the other; rather, hiring for both makes the most sense. In fact, the data supports this as hybrid tax/tech roles are on the rise, according to the report.

4 actions corporate tax leaders should take now

While the data makes the problem of this frustration gap clear, the more pressing issue is what tax leaders can do about it right now. Four concrete actions stand out:

1. Make training non-negotiable 鈥� If corporate tax leaders are investing in technology but not in developing their people’s ability to use it effectively, they are wasting money. Make formal training 鈥� along with mentoring and peer knowledge-sharing 鈥� a performance requirement.

2. Hire for the future 鈥� The pendulum swing back to tax expertise is understandable, but it鈥檚 essential that heads of corporate tax departments do not overcorrect. Prioritize candidates who demonstrate both deep tax knowledge and technological fluency or invest in upskilling current staff with explicit development paths to build in the missing capability.

3. Track what matters 鈥� Two-thirds of tax departments now measure time savings and efficiency gains, while 55% track accuracy improvements. In addition, it is important to track where your corporate tax department staff are struggling with tools and where additional training or process optimization could unlock value.

4. Prepare for the AI acceleration 鈥� With 39% of corporate tax professionals expecting AI to be central to their work within the next 1 to 2 years and another 15% expecting it within a year, corporate tax executives must start experimenting with AI for technical research, compliance automation, and document analysis to build the team’s comfort and competency through hands-on experience.

The bottom line

The frustration gap among corporate tax professionals highlights the mismatch between advanced technological capability and the human capacity to leverage it. As one survey respondent described: “Technology is extremely important to reduce manual processes and help reduce errors. I don’t see a path for any tax department to not lean into technology.鈥�

However, leaning into technology without investing equally in your people is a recipe for disillusionment. The 56% dissatisfaction rate with current tech stacks underscores the frustration in the human-technology relationship and the perception that the technology tools are not solving users鈥� problems very well.

Those corporate tax departments that will thrive in the AI era will be the ones that invested in building technological competence, hired for hybrid capabilities, and created cultures of continuous learning. The technology maturity curve and the talent maturity curve must ascend together.

You can download a full copy of from the 成人VR视频 Institute and Tax Executives Institute here

Key takeaways:

• • • Your post-OBBBA forecasts should look different 鈥� If the tax department doesn’t own the OBBBA model, someone else will own the OBBBA story.

• • • Rely on your department鈥檚 inner strengths 鈥� It鈥檚 governance and analysis 鈥� not tools 鈥� that get you into the strategy room.

    • Factor in the conflict in the Middle East 鈥� The Iran war risk belongs in your tax model, not just in your CFO’s macro deck.

The One Big Beautiful Bill Act (OBBBA), signed into law in July 2025, enacted large business tax cuts, most notably by providing permanent full expensing of many forms of investment. Under the previous major corporate tax legislation, 2017鈥檚 Tax Cuts and Jobs Act (TCJA), bonus depreciation was scheduled for gradual phase-out following 2023. The OBBBA restored that expensing 100% retroactively for assets acquired from mid-January 2025 onwards.

The after-tax cost of new machinery, fleets, and equipment has effectively fallen by around 21%, designed to encourage immediate capital outlays by allowing businesses to write off these expenses in the year they are incurred rather than amortizing them over five years.

For corporate tax departments, that’s not a disclosure footnote 鈥� that’s your capital plan.

Capital-intensive corporations will see tax burdens reduced through permanent rate extensions, depreciation adjustments, and expansion of the state and local tax (SALT) deduction cap 鈥� but only if your models are built to capture the timing and location of investment, the mix of debt compared to equity, and where your organization books its next dollar of income.

Not surprisingly, most corporate tax departments aren’t there yet. They’re still recalculating last year, plus a few adjustments. That’s glorified compliance, not modeling.

A standout tax department doesn’t ask, What’s the OBBBA impact? Rather, it asks, Which version of OBBBA do we choose for this business? 鈥� and it has the models to back it up.

From spreadsheet heroics to controlled modeling

For many organizations, tax modeling still means creating a massive spreadsheet that only one director truly understands. The spreadsheet gets pulled out for budget season, rebuilt under pressure, and quietly retired until next year. That’s a single point of failure, not a process.

And after OBBBA, continuing that practice is dangerous. One wrong assumption on expensing or interest limitation can move cash tax by millions of dollars and blindside the Finance Department.

Here’s what disciplined modeling looks like in practice:

• • • Create a unified model 鈥� Build one integrated model that the whole team can use or accept that your department is choosing to fly blind.
    • Use the same assumptions 鈥� Standardize the levers that matter most (such as capex timing, financing mix, jurisdiction, and incentives) and make sure every scenario runs off the same assumptions.
    • Conduct modeling reviews 鈥� Treat major OBBBA-driven decisions (such as large capex, funding shifts, supply-chain redesign) as tax deals that must go through a modeling review before they’re greenlit.
    • Document your assumptions explicitly 鈥� Under permanent full expensing, the difference between a well-supported assumption and a poorly documented one isn’t just an audit risk, rather it’s a credibility problem with your CFO.

It鈥檚 also important to remember that in a post-OBBBA world, this level of disciplined modeling is not technology transformation 鈥� it鈥檚 basic survival.

Governance: Where leaders quietly win or loudly fail

The differentiator isn’t which corporate tax department has the fanciest tool 鈥� it’s which one has the cleanest governance. And the data is unambiguous: More than half (55%) of tax departments are still in the reactive phase of their technological development, stuck with five capex models circulating with five discount rates and the tax team arriving late to the planning meeting.

Those tax departments that are breaking out of that pattern share one trait: They put someone formally in charge. In the 成人VR视频 Institute鈥檚 recent 2026 Corporate Tax Department Technology Report, a large portion (88%) of survey respondents said their company had appointed a person to lead the tax department’s technology strategy. That number jumped a whopping 37 percentage points, from 51%, from the previous year鈥檚 survey. That single structural move separates those departments with a governance model from those that simply hold a governance conversation every budget cycle and forget about it.

Clearly, this type of ownership drives results. Two-thirds of those surveyed agreed that their company’s investment in technology has enabled a shift from routine, reactive work to more strategic, proactive, higher-value work.

Under OBBBA, the kind of governance isn’t housekeeping. It’s how you get invited into strategy discussions instead of having to clean up after things go awry.

Why your OBBBA win may not feel like a win

On paper, the tax changes embedded in the OBBBA look generous. In practice, your effective tax benefit is colliding with something you don’t control.

When the war on Iran began, all shipping through the Strait of Hormuz was effectively halted, removing roughly one-fifth of the world’s oil and gas supply from the market. Fuel prices throughout the world spiked and are likely to remain elevated as long as conflict persists.

With oil prices hovering around $100 a barrel, there are will wipe out the benefits of higher tax refunds this year for most Americans. If those benefits, arising from Trump’s 2025 tax cuts, are erased for the average American, only the top 30% of taxpayers will still seeing a net gain.

For corporate planning purposes, the parallel dynamic is real: The topline OBBBA benefit is being eroded by higher fuel, freight, and financing costs across the business and its supply chain.

Inflationary pressures are being driven by higher energy prices tied to the Iran war, and the conflict’s impact on a wide range of goods and services is likely to last for months 鈥� with experts saying even a ceasefire is unlikely to immediately ease global energy shortages.

A serious corporate tax department doesn’t handwave these concerns away. It takes three actions:

1. 1. 1. Run a war-extended scenario 鈥� The scenario should show exactly how sustained higher energy costs and borrowing rates change the payoff from accelerated expensing and leverage 鈥� with specific numbers, not just directional commentary.
      2. Share your forecasts internally 鈥� Put your monthly or quarterly cash-tax forecasts on the table for Finance to see, so that it can manage liquidity rather than hope the annual plan holds.
      3. Force the hard conversation 鈥� Ask the tough question: At today’s rates and fuel costs, the after-tax return on this project is X. Are we still in? That question should come from the tax team now, not from the finance team six months later.

Clearly, the daily fluctuations in oil prices matter less than monthly and quarterly averages 鈥� and volatility will likely remain elevated given the absence of a clear timeline for the end of the war. That’s exactly the kind of sustained uncertainty that belongs front and center in your scenario set, not in a footnote.

The bottom line

The OBBBA gives corporate tax departments a genuine opportunity to move from being simply a compliance function to becoming more of a strategic advisor. Permanent full expensing, richer cost recovery, and more flexible interest rules can create real levers to add value, but only for those organizations that model them rigorously, govern them cleanly, and stress-test them against the macro environment their business actually faces today.

Indeed, the Iran war is a live test of that readiness. The corporate tax departments that show up with modeled scenarios, cash-tax forecasts, and a clear point of view on after-tax returns will earn a seat at the strategy table. The ones that show up with caveats will be asked to leave it.

You can download a full copy of the 成人VR视频 Institute鈥檚 recent 2026 Corporate Tax Department Technology Report here

Key takeaways:

• • • Country-by-country reporting will only increase in complexity 鈥� Australia’s enhanced Country-by-country reporting (CbCR) requirements 鈥� reconciling taxes accrued against taxes credited 鈥� are a preview of where other high-scrutiny jurisdictions are heading, and companies need to build that explanatory analysis capability now, systematically, rather than scrambling later.

    • There has to be a shared narrative from corporate teams 鈥� The EU鈥檚 public CbCR is a reputational event, not just a filing. So that means tax, communications, and investor relations teams need a shared narrative before the data goes public 鈥� inconsistencies create exposure you do not want to manage reactively.

    • Rethink your filing jurisdiction in light of changes 鈥� If EU filing jurisdiction was chosen at initial implementation and never revisited, look again. Guidance has matured, and a more efficient or better-suited option may now be available.

WASHINGTON, DC 鈥� Among the many pressing topics discussed in detail at the recent , country-by-country reporting (CbCR) and its ability to reshape the corporate tax industry, certainly had its place. Between escalating local jurisdiction requirements, the , and for deeper explanatory disclosures, CbCR has quietly evolved from a transfer pricing filing obligation into something far more strategically consequential.

The floor is just the floor

The creation of the by the Organisation for Economic Co-operation and Development (OECD) was intended as a minimum standard for countries. And now jurisdictions are increasingly layering additional requirements on top of the OECD鈥檚 basic template, resulting in a widening gap between the standard requirements and what tax authorities actually want.

Currently, Australia is the most pointed example. Australian tax authorities are now requiring multinational groups to go beyond the standard CbCR data fields and provide explanatory narratives that reconcile taxes accrued against taxes actually credited. This requires corporate tax departments to bridge the gap between financial statement accruals and their organizations鈥� cash tax positions in a way that is coherent, defensible, and consistent with positions taken elsewhere.

At the TEI event, panelists explained that for tax departments this will carry complex timing differences, deferred tax positions, or significant jurisdictional mismatches between booked and cash taxes. Indeed, this additional layer of scrutiny will need dedicated attention.

The broader signal matters: Australia will not be the last jurisdiction to move in this direction. So that means that tax departments should treat Australia’s approach as a leading indicator of where other high-scrutiny jurisdictions could be heading. Building the capability to produce this kind of explanatory analysis systematically 鈥� rather than scrambling jurisdiction by jurisdiction 鈥� would be the smarter long-term investment for corporate tax teams.

Public CbCR in the EU: The transparency ratchet has turned

For US-based multinationals with significant European operations, the EU’s public CbCR directive has fundamentally changed the calculus. Unlike the confidential tax authority filings most corporate tax departments are accustomed to, the EU鈥檚 public CbCR rules put organizations鈥� jurisdictional profit and tax data into the public domain, making it visible to investors, journalists, civil society groups, and organizations鈥� employees and customers.

The EU framework specifies which entities trigger the reporting obligation and which entity within the group is responsible for making the public filing. That scoping analysis is not always straightforward for complex multinational structures and getting it wrong could present both reputational and legal risk.

Choosing a filing jurisdiction is not purely an administrative decision 鈥� it is a choice that affects the regulatory environment that governs the disclosure, the language requirements, the timing, and the interpretive framework that applies to data.

For US-headquartered groups, the implications extend well beyond Europe. Public CbCR data is now being read alongside US disclosures, reporting on ESG activities, and public narratives about tax governance. Inconsistencies, including those technically explainable, could create unwanted noise about the company. This is clearly another reason why the tax function should partner across the business 鈥� in this case with the communications team 鈥� to make they both are aligned to tell the CbCR story instead of being caught off guard by a journalist or an investor during an earnings call.

Questions that US multinationals should be asking

Fortunately, US multinationals with multiple EU subsidiaries are not required to file public CbCR reports in every EU member state in which they have a presence. Instead, under the EU framework, a qualifying ultimate parent or standalone undertaking can satisfy the public disclosure requirement through a single filing in one EU member state, provided the relevant conditions are met. Germany and the Netherlands have emerged as two of the more popular choices for this consolidated filing approach, given their well-developed regulatory frameworks and the depth of available guidance on what compliant disclosure looks like in practice.

The strategic implication is meaningful. Choosing a filing jurisdiction is not purely an administrative decision 鈥� it is a choice that affects the regulatory environment that governs the disclosure, the language requirements, the timing, and the interpretive framework that applies to data. Corporate tax departments that defaulted to a filing jurisdiction early in the EU implementation process should take a fresh look. Regulatory guidance has matured significantly, and there may be a more efficient or better-suited path available than the one originally chosen.

The uncomfortable divergence

There is a notable irony in the current environment. Domestically, the IRS and U.S. Treasury’s 2025-2026 Priority Guidance Plan reflects an explicit focus on deregulation and burden reduction, detailing dozens of projects aimed at reducing compliance costs for US businesses. Meanwhile, the international compliance environment has moved in the opposite direction, adding disclosure layers, explanatory requirements, and public transparency obligations that many US businesses cannot avoid simply because they are headquartered in the United States.

This divergence has a direct implication for how tax departments allocate resources and make the internal case for investment in international compliance infrastructure. The burden internationally is not going down 鈥� indeed, it is intensifying 鈥� and that argument is now backed by concrete examples rather than projections.

3 things worth doing now

There are several actions that corporate tax teams should consider, including:

Audit CbCR data quality with Australia’s enhanced requirements in mind 鈥� If you cannot readily reconcile taxes accrued to taxes credited at the jurisdictional level, that gap needs to be closed before it becomes an authority inquiry.

Revisit EU filing jurisdiction strategy 鈥� If your jurisdictional decision was made at the time of initial implementation and has not been reviewed since, it is worth a fresh look before the next reporting cycle.

Develop an internal narrative around public CbCR data before it circulates externally 鈥� Your company鈥檚 tax story should not be a surprise to the corporate teams involved in communications, investor relations, or ESG 鈥� and in today鈥檚 world, assuming such news stays quiet is no longer a safe assumption.

While CbCR started as a tool for tax authorities, it today has become something more visible, more public, and more consequential than that 鈥� and that trajectory is not reversing any time soon.

You can download a full copy of the 成人VR视频 Institute鈥檚