This assessment evaluates the maturity of an organization's tax strategy across five dimensions: entity structure and tax planning, transfer pricing, tax credits and incentives, compliance and reporting, and Pillar Two / international tax readiness. The output identifies where tax value is left on the table and compliance risks exist. [src2]
What this measures: How strategically the entity structure is designed for tax optimization while maintaining compliance.
| Score | Level | Description | Evidence |
|---|---|---|---|
| 1 | Ad hoc | Structure evolved organically; no tax planning beyond filing | Entities without tax analysis; no intercompany agreements |
| 2 | Emerging | Basic tax considerations; some awareness of efficient structures | Advisor consulted for new entities; basic holding company |
| 3 | Defined | Structure designed for efficiency; holding/IP strategies evaluated | Documented rationale; intercompany agreements; annual planning |
| 4 | Managed | Multi-jurisdictional optimization; regular reviews; Pillar Two modeled | Tax-optimized structure; repatriation planning; GloBE assessment |
| 5 | Optimized | Dynamic modeling; continuous optimization; tax influences strategy | Scenario modeling; structure adapts to changes; strategic tax input |
Red flags: Structure not reviewed in 3+ years; no jurisdiction rationale; missing intercompany agreements. [src2]
Quick diagnostic question: "When was your entity structure last reviewed for tax efficiency?"
What this measures: How effectively intercompany pricing complies with arm's length while optimizing tax position.
| Score | Level | Description | Evidence |
|---|---|---|---|
| 1 | Ad hoc | No TP policy; arbitrary pricing; no documentation | No TP docs; prices set without analysis |
| 2 | Emerging | Basic awareness; some docs for largest transactions | Basic policy; local file for primary jurisdiction |
| 3 | Defined | Comprehensive policy; master + local files; annual benchmarking | OECD-compliant files; annual benchmarking; HTVI documentation |
| 4 | Managed | APAs for key transactions; monitoring; CbCR filing | APAs; real-time monitoring; CbCR filed; dispute resolution |
| 5 | Optimized | Dynamic models; AI comparable analysis; GloBE integration | Automated monitoring; dynamic adjustments; TP-GloBE integration |
Red flags: No TP docs despite material intercompany transactions; same markup for all; no CbCR above threshold. [src3]
Quick diagnostic question: "Do you have a TP policy, and when were benchmarking studies last updated?"
What this measures: How effectively the organization captures available credits — R&D credits, investment incentives, jurisdiction-specific programs.
| Score | Level | Description | Evidence |
|---|---|---|---|
| 1 | Ad hoc | No credit identification; R&D credit not claimed despite eligibility | No credits claimed; no qualifying expenditure tracking |
| 2 | Emerging | R&D credit claimed for obvious activities; documentation reactive | Annual R&D credit; docs assembled at tax time |
| 3 | Defined | Systematic R&D process; contemporaneous documentation; Form 6765 Section G ready | Project-level docs; incentive register; quarterly tracking |
| 4 | Managed | Cross-jurisdiction optimization; Section 174 strategy; OBBBA impact modeled | Multi-jurisdiction credits; 174A strategy; carryforward tracking |
| 5 | Optimized | AI-assisted activity identification; predictive modeling; credits influence decisions | Automated R&D capture; predictive models; location decision input |
Red flags: Eligible activities unclaimed; no contemporaneous docs; Section 174 not addressed post-OBBBA; Form 6765 Section G not prepared. [src1]
Quick diagnostic question: "Do you claim R&D credits with project-level documentation?"
What this measures: How effectively the organization meets filing obligations, manages provision, and maintains audit readiness.
| Score | Level | Description | Evidence |
|---|---|---|---|
| 1 | Ad hoc | Returns filed late; no provision process; no audit readiness | Late filings; penalties; no supporting schedules |
| 2 | Emerging | Returns on time; basic provision; limited workpapers | Timely filings; external preparer; basic provision |
| 3 | Defined | Tax calendar; quarterly provision (ASC 740); audit-ready docs | Calendar system; quarterly provision; organized workpapers |
| 4 | Managed | Automated provision; real-time ETR; proactive audit prep | Provision software; real-time dashboards; FIN 48 analysis |
| 5 | Optimized | Continuous monitoring; AI-assisted review; predictive audit risk | Tax platform; automated checks; predictive audit models |
Red flags: Extensions by necessity; annual-only provision; cannot produce supporting docs; frequent prior-period adjustments. [src4]
Quick diagnostic question: "Is your provision quarterly, and can you document top 5 tax positions within a week?"
What this measures: Preparedness for OECD Pillar Two global minimum tax and evolving international requirements.
| Score | Level | Description | Evidence |
|---|---|---|---|
| 1 | Ad hoc | No Pillar Two awareness; no scoping; no GloBE capability | No assessment; cannot determine if in scope |
| 2 | Emerging | Basic awareness; scoping done; safe harbour assumed unvalidated | Scoping complete; CbCR safe harbour assumed |
| 3 | Defined | Impact assessment done; data collection for GloBE; safe harbour validated | GloBE assessment; data templates; ETR thresholds tested |
| 4 | Managed | Regular GloBE calculations; SbS safe harbour; structure optimization | Regular computations; SbS analysis; optimization modeling |
| 5 | Optimized | Automated GloBE engine; dynamic optimization; Pillar Two shapes decisions | Automated platform; real-time ETR by jurisdiction |
Red flags: Revenue >EUR 750M with no assessment; safe harbour used without ETR validation; no data collection; unaware of 2026 SbS changes. [src5]
Quick diagnostic question: "Have you completed a Pillar Two scoping assessment?"
Overall Score = (Entity Structure + Transfer Pricing + Credits & Incentives + Compliance + Pillar Two) / 5
| Overall Score | Maturity Level | Interpretation | Recommended Next Step |
|---|---|---|---|
| 1.0 - 1.9 | Critical | Tax function compliance-only; significant optimization missed and exposure | Engage advisor for structure review; implement R&D credit; establish TP docs |
| 2.0 - 2.9 | Developing | Basic management; value leakage likely; reactive approach creates risk | Formalize TP policy; optimize credits; build provision rigor; assess Pillar Two |
| 3.0 - 3.9 | Competent | Well-managed with documented positions; shift to strategic optimization | Deploy tax technology; optimize structure; build GloBE capability |
| 4.0 - 4.5 | Advanced | Strategic function integrated with business planning | Fine-tune Pillar Two; pursue APAs; build predictive analytics |
| 4.6 - 5.0 | Best-in-class | Tax as competitive advantage with dynamic optimization | Maintain; innovate on tax technology; shape best practices |
| Weak Dimension (Score < 3) | Fetch This Card |
|---|---|
| Entity Structure | Entity Structure Optimization Guide |
| Transfer Pricing | Transfer Pricing Policy Development |
| Tax Credits | R&D Tax Credit Optimization Guide |
| Compliance | Tax Compliance Modernization Playbook |
| Pillar Two | Pillar Two Readiness Playbook |
| Segment | Expected Average Score | "Good" Threshold | "Alarm" Threshold |
|---|---|---|---|
| Startup/SMB (<$10M revenue) | 1.5 | 2.2 | 1.0 |
| Growth ($10M-$100M) | 2.2 | 3.0 | 1.5 |
| Enterprise ($100M-$1B) | 3.0 | 3.8 | 2.2 |
| Large enterprise ($1B+) | 3.6 | 4.2 | 2.8 |
Fetch when evaluating tax strategy, optimizing entity structure, assessing R&D credit programs, preparing for Pillar Two, or benchmarking tax function maturity. Critical during international expansion, M&A, and annual tax planning.