Tax risk register for cross-border groups — can I handle this myself?
Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: the register records each exposure, the jurisdictions affected, the quantum, the mitigation and the evidence held.
What if I have already filed and got it wrong?
That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.
How long will it take?
It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.
What is a tax risk register and why does a board need one?
It is a single ranked list of the group's tax exposures with a named owner against each one. Without it, tax risk lives in separate heads in separate countries, and the board meets it for the first time when a revenue authority or a buyer raises it. The register records each exposure, the jurisdictions affected, the quantum, the mitigation and the evidence held. That turns a set of unrelated worries into something a board can approve, defer or fund, rather than something it discovers.
How is a tax risk register different from a tax provision?
A provision is an accounting figure for a reporting date. A register is a live management document saying what the exposure is, where it arises, who owns it, what has been done about it and what evidence sits behind the position. The two overlap but answer different questions: the provision asks what to book, the register asks what to do and who does it. Groups that keep only a provision usually cannot produce the evidence for a position when it is finally challenged, because nobody was ever made responsible for holding it.
Who should own each risk on the register?
A named person, not a function. Group finance owning a permanent establishment question means nobody owns it, and the item survives from review to review untouched. Ownership belongs with whoever can actually act - the person who can commission the advice, change the process, or gather the evidence. Where that person sits outside the tax team, the register says so explicitly. Part of the work in building a register is settling those names with the people concerned, because an owner who first learns of the item in a board pack will not act on it.
How often should a tax risk register be reviewed?
On a fixed rhythm, with an additional review whenever the group does something structural - a new entity, a new country, a change in where people work, an acquisition. The rhythm matters more than the interval. A register reviewed on a schedule accumulates evidence and shows movement; one revisited only when something goes wrong is a snapshot of the last crisis. Reviewed regularly it also becomes the audit-readiness file for the positions the group has taken, which is its second and often more valuable use.
Where do we start if the group has no tax function?
Start with an inventory rather than an opinion. List every entity, what it does, where its people actually are, what it files and what it has never filed. Most groups find their first exposures in that list alone - an entity filing nothing in a country where someone works, a treaty position nobody has tested, a filing calendar with no owner. Only then is it worth ranking anything. Assessing risk before the inventory exists produces a register of the things the person writing it happened to know about.
Will a buyer or lender ask to see our tax risk register?
They will ask the questions the register answers, and in a diligence exercise the difference is visible. A group that can hand over a ranked list with owners, mitigations and the evidence behind each position is answering from a file. A group without one is reconstructing its own history under time pressure, and gaps found that way tend to be priced into the deal or held back in escrow. Building the register before anyone asks is cheaper than building it while a data room is open.
How do I actually stop being taxed twice?
In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.
Is the sale of foreign property taxable where I live?
For a resident, yes — worldwide gains are taxable, and the gain is computed in your own currency, so the exchange rate at purchase and at sale changes the number even when the local-currency price did not move. The country where the property sits usually taxes it too, often with a withholding or clearance step before closing, and that tax becomes a credit. A principal residence relief may apply to a home abroad on the same terms as one at home. See principal residence and foreign property.
