Issue 2 - 2013—It’s not that often that an organization will implement or enhance an enterprise resource planning (ERP) system. However, significant acquisitions, migrating from a mainframe system, the desire for a common platform, and increased functionality are some of the key drivers that will compel organizations to undertake this significant effort. There is no greater opportunity than during an ERP implementation or enhancement for the tax department to lay the foundation for achieving significant improvements in quality, time and cost, but only if the tax department is integrally involved and not left behind when the ERP implementation/enhancement bus leaves the station. In this edition of Tax Advisor Weekly, I discuss the direct tax challenges and best practices for a tax department relating to ERP implementations and enhancements. The indirect tax challenges and best practices will be addressed in a future Tax Advisor Weekly.

If You Miss the Bus, You’ll Be Dealing with Manual Workarounds and Subpar Solutions

Often, we are called in to help tax departments improve quality, reduce time and cut costs related to the global tax provision and income tax compliance. In many cases, the organization has already spent a lot of time, effort and money to implement a global ERP system. However, as we are defining the tax business requirements and developing the design for bolt-on tax provision and compliance software, we seem to regularly discover the following:

• The general ledger (GL) accounts were not tax-sensitized during the ERP system implementation, and we now need to beg and plead with the accounting and IT departments to see if they are willing to begrudgingly create new, tax-sensitized GL accounts so that we can reach best-practice, domestic and international, book-to-tax difference automation levels of 75 percent plus.
• The data fields common in sophisticated ERP systems for GL accounts either were not designed or are not being used to properly capture transaction type, fiscal year or sourcing, all of which would enable best-in-class automation for tax purposes in complex areas such as UNICAP, transactions, apportionment and taxes payables.
• Specific reports that could save the tax department a lot of crunch time during the ever-shrinking provision cycle, and which could have easily been designed as a report during the ERP implementation, are not currently supported, and now the tax department needs to have them designed “after the fact.” 

These are just some of the common difficulties we encounter when reengineering tax provision and compliance processes and while trying to achieve significant levels of automation during provision and compliance software implementations. Oftentimes, these difficulties that arose from not paying enough (or any) attention to the tax department’s business requirements during the ERP system blueprint and realization (i.e., implementation) phases can only be resolved through manual workarounds and other subpar solutions, which will inhibit the automation potential. But it didn’t have to be so!

How Do ERP Implementation or Enhancement Projects Work?

When organizations decide to implement an ERP system, a lot of time is spent to determine what the key objectives and definitions of success are. Because the project is so important, a governance board and a steering committee are normally appointed to oversee the project throughout all of its phases. A systems integrator is hired to design, implement and test the project. Often, a third-party consultant is hired to provide oversight so the project remains within its original scope and is not needlessly delayed or way over budget.

The phases of an ERP system implementation are usually as follows:

• Preparatory Phase: The organization gathers the information, begins to understand what the business needs are and makes a concerted effort to prioritize them.
• Blueprint Phase: The organization develops its business requirements and works with the systems integrator to design the blueprint that, if properly executed, will achieve the desired business requirements.
• Realization (Implementation) Phase: The organization and the systems integrator execute the blueprint (work plan) previously developed.
• Testing Phase: All the required testing is developed and done, and any defect remediation is completed to ensure the ERP system is performing as intended and internal control tests, including Sarbanes-Oxley, are satisfied.
• Training Phase: The organization is trained to use the ERP system effectively.
• Go-Live Phase: The organization rolls out the new ERP system.
• Post-Go-Live Support Phase: The systems integrator, software provider and/or outside consultant assist the organization for some period of time after go-live to fix any hitches and finalize change management.

You would think that in a process as important to an organization as an ERP system implementation, the tax department would be one of the players helping to determine the key objectives and the definitions of success. After all, doesn’t the income tax expense on the income statement range anywhere from the low 20 percent to the high 30 percent of net income? Aren’t failed tax provisions one of the largest contributors to material weaknesses and financial statement restatements? And, even though I don’t address indirect taxes in this Tax Advisor Weekly, aren’t global organization responsible for millions of dollars in sales and use and value-added taxes, oftentimes managed in a decentralized manner? 

In some ERP system implementations, the tax department plays a key role and is involved in all of the phases. But, unfortunately, as we repeatedly see during tax provision and income tax software implementations, either the tax department was involved but not fully aware of all the best-practice possibilities available from an ERP system implementation and also severely resource constrained throughout the project or, most likely, the tax department was rarely, if at all, consulted during the ERP system implementation. 

Oftentimes, because the tax department is getting the job done with its existing resources, why fix what’s not broken? Yes, the CFO wishes that the provision cycle could be shortened by a week or two. Yes, the organization does seem to be paying a lot of annual, local-country provision preparation, review and compliance fees to local-country accountants. And what value, if any, would the tax department add to the ERP system implementation? Besides, isn’t the tax department always swamped? It wouldn’t have available resources to commit to the ERP system implementation anyways! So, let’s just invite the tax department to a few meetings and that should suffice, right?

What Should the Tax Department Do to Enable Best-Practice Outcomes?

Consolidated and local-country tax provisions are prepared on a quarterly and year-end basis. In most organizations, local-country controllers, working in conjunction with their U.S. tax department, have developed a process whereby the local-country provision is computed, local-country statutory-to-GAAP adjustments are made, and some information package is provided to the tax department containing these quarterly/year-end results and other necessary data that may be needed back in the U.S. to compute income inclusion, foreign tax credits, etc. Everyone knows what GL accounts to look at, how to perform the computations and create the special reports that are required, and where to obtain the data. A similar process has been developed in the U.S. as to which GL accounts to review, how special reports are prepared by the accounting or sales department and where to obtain the data. Then it’s all consolidated. Maybe Microsoft Excel is used to assemble the consolidated provision. Maybe some tax provision software is used. But when the ERP system is rolled out, the organization will have a new GL. The old GL accounts that all of these time-challenged professionals have been accustomed to using will have disappeared or changed, or have been renamed and reconfigured. Perhaps some key tax-sensitive GL accounts will no longer even exist. Perhaps important sourcing data that was previously collected in another department will no longer be available to the tax department.

Consequently, from a direct tax perspective, the most crucial task for the tax department during an ERP system implementation is to ensure that the tax provision and income tax compliance processes can continue to be done timely and correctly after the go-live phase and that they will take less time than past efforts. The second most crucial task from a direct tax perspective is to make sure that the ERP system implementation anticipates the future needs of the tax department (e.g., implementing a provision software and a compliance software) so that costly and time-consuming rework, manual workarounds and subpar solutions won’t need to be done when the time comes to move from the current state to the desired future state. The third most crucial task is adequate training to best use the new ERP system and to achieve self-sufficiency.

Let’s go into more detail by phase.

Preparatory Phase: Use this crucial time to document every GL account and data source currently being used to prepare the quarterly and year-end provision as well as the income tax filings domestically and internationally. How can you ensure these key data items will survive the transition if you don’t track them? Ideally, a domestic and foreign tax adjustment matrix should be developed listing each book-to-tax difference and what GL accounts, methodology, additional computations and reports are currently being used to compute it. With the domestic and foreign tax adjustment matrix, you can then begin developing the tax business requirements. The tax business requirements are what the tax department will need to ensure that the ERP system implementation meets its definition of success. During this phase, it is also best to envision the desired future state of the tax department to ensure that the tax business requirements will lay the foundation for seamless future implementations of tax provision and compliance software. To truly envision the possibilities, it may be best to meet with a third-party advisor who can share best practices in ERP system implementations for facilitating leading-edge automation for future tax provision and compliance software implementations. Finally, make sure that direct tax is properly represented in the organization’s ERP system implementation lead team. 

Blueprint Phase: Finalize the tax business requirements for the ERP system implementation. This is what the tax department “needs” and the ERP system must do upon roll-out, if the tax department is to continue preparing the tax provision and global compliance under its existing processes. It is also important to include within the tax business requirements what the tax department “wants” the ERP system to do upon roll-out, so as to anticipate and be ready for moving towards the desired future state of the tax department without requiring rework, manual workarounds and subpar solutions. It would also make sense to prioritize these needs and wants, in case budget and time constraints force reductions in the tax business requirements. Finally, during the blueprint phase, the tax department should ensure that its business requirements are properly designed (i.e., built into) the work plan. For all of these reasons, the tax department will need to designate a lead team member, or hire a consultant, who can fluently speak and understand “IT” and “Tax” and who can communicate in both worlds. Without this ability, critical miscommunications and incorrect redirections occur during the design, something that may result in the eventual misimplementation of some of the tax business requirements. 

Realization Phase: The same tax department representative or team, fluent in IT and Tax, should attend all of the lead team meetings to ensure that the tax business requirements are implemented as designed and approved by the tax department. This person or team should also assume responsibility for coordinating implementation steps assigned to the tax department. This is a long, drawn-out phase, but not “being at the table” will jeopardize the implementation of the tax business requirements.

Testing Phase: Who better than the tax department to help design the tests that will check whether the data and reports being generated by the new ERP system are correct and will meet the tax department’s provision and compliance needs and wants? The tax department will need to provide personnel to conduct the tests and, if necessary, reconcile and mitigate discrepancies. This process serves as good hands-on training.

Trainin​g Phase: Corners should not be cut here, or else the tax department will always underutilize the sophisticated and complex ERP system that the organization has just implemented. The more important the training topic, the less effective remote, web-based training is, especially if multiple hours will be required. In-person training reduces the risk of the common Internet distractions to which we often succumb. 

Go-Live and Post-Go-Live: If the tax department was integrally involved throughout the previous phases and provided lead team members (and/or outside advisors) who had experience with ERP system implementations and related best practices, the roll-outs during go-live and the tweaking during post-go-live should proceed as anticipated. 

Overall: Implementing an ERP system is a tough challenge for an organization and for a tax department. Everyone already has full-time responsibilities that will not disappear during the implementation. Consequently, it is best to focus a tax department’s limited and stretched resources on the ERP system implementation and to forgo implementing, at the same time, bolt-on applications for substantially automating your global provision and compliance functions. If you’ve been thinking of automating your tax provision and compliance functions, do so after the go-live of the ERP system implementation. Nevertheless, you should most certainly bake into your tax business requirements such future implementations so as to lay the foundation for maximizing the automation potentials. 

Alvarez & Marsal Taxand Says:

An ERP system implementation or enhancement is both a potential risk and a change enabler for the tax department. The core data you depend on to prepare the tax provision and compliance is being touched and changed. Will some key items disappear or become unusable because of the implementation? 

At the same time, the opportunities to lay the foundation for driving through best-practice savings in time and money and improvements in quality with respect to the global tax provision and compliance, without rework, manual workarounds and subpar solutions, are at their peak. Don’t be left behind when that ERP implementation/enhancement bus leaves the station! You’ll be risking a lot and passing on some very good opportunities.

For more information:

Michael Stenftenagel
Managing Director, Houston
+1 281 782 2476
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Thomas Burton
Senior Director, Houston
+1 713 249 0472
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Mark Guevin
Director, Dallas
+1 214 438 8425

Disclaimer

As provided in Treasury Department Circular 230, this publication is not intended or written by Alvarez & Marsal Taxand, LLC, (or any Taxand member firm) to be used, and cannot be used, by a client or any other person or entity for the purpose of avoiding tax penalties that may be imposed on any taxpayer. 

The information contained herein is of a general nature and based on authorities that are subject to change. Readers are reminded that they should not consider this publication to be a recommendation to undertake any tax position, nor consider the information contained herein to be complete. Before any item or treatment is reported or excluded from reporting on tax returns, financial statements or any other document, for any reason, readers should thoroughly evaluate their specific facts and circumstances, and obtain the advice and assistance of qualified tax advisors. The information reported in this publication may not continue to apply to a reader's situation as a result of changing laws and associated authoritative literature, and readers are reminded to consult with their tax or other professional advisors before determining if any information contained herein remains applicable to their facts and circumstances.