Tax Compliance Checklist (Pillar Two / Transfer Pricing)

1) Governance Scope
- Identify entities in scope and effective tax rate baseline.
- Confirm reporting owners across finance, tax, legal.

2) Risk Signals
- ETR below 15% without monitoring model.
- Related-party transactions without local files.
- Filing process split between systems.

3) Required Deliverables
- Pillar Two impact model (base / stress scenarios).
- Transfer pricing policy and documentation package.
- Filing SOP and quarterly risk dashboard.

4) Milestone Cadence
- Week 1-2: baseline and risk mapping.
- Week 3-4: structure and policy design.
- Week 5-8: remediation and execution.
- Ongoing: quarterly monitoring.