Standard operating procedure · FI7C · Finance
Tax Position Paper
Judgment procedure owned by Tax in Finance. 7 numbered steps, 2 of them a person deciding and 5 of them agent work … more
Procedure code
FI7C
Judgment
Rule versions in force
v4.7 · v4.3 · v4.0 · v1.8
4 governing rules stacked over it
In force since
2024-12-17
Earliest effective date across those rules
Last reviewed
2026-08-05
Latest review date across those rules
Rules approved by
1
VP Tax
Rule health
4/4
0 under review · 0 superseded
There is no document register behind this header. The version, the dates and the approver names are read off the governing rules this procedure runs inside, which is the closest thing the estate holds to a document control record. Nobody wrote these procedures. There is no document library behind this page and no Word file anywhere in the estate. Every procedure below is generated from rows this platform already holds: the line and its ordered stations, the owning team and the person accountable for it, the policy items bound to that team, and the governance gates seeded against the function. The steps, the owners, the gates, the approvers, the dwell times and the volumes are read straight off those rows. The sentences that join them together are generated. Read a procedure as the estate describing itself, not as a document somebody signed.
Purpose and scope
What this procedure is for and where it stops
To run tax position paper to one repeatable standard inside Tax, part of Finance. more
Entry condition
Runs judgment. Starts when a leadership team frames the question.
Exit condition
The unit clears counsel concur, released by VP Tax. more
In scope
- Every unit of tax position paper raised inside Tax, from the trigger below through to the final step.
- 5 of the 7 steps, which run without a person present.
- 2 decisions that stop the line until a named person releases it.
Out of scope
- Anything outside the envelope set by the owning team. It leaves the line at a gate and becomes the named approver's decision.
- Work that belongs to another function. This line hands off to legal and does not follow the unit there.
- Shared-spine work. This line has none; every step is done inside the function.
Who owns it
Runs the line
Tax Orchestrator
Accountable person
VP Tax
The end of the escalation path. Above them sits Finance Chief of Staff for the function.
That team’s remit
Owns tax filing work end to end inside Finance. more
That remit describes the whole team, not this one procedure, so its counts are larger than the ones on this page.
Autonomy
60% now · ceiling 72%
Data assembly and computation are agentic. more
The procedure, step by step
7 numbered steps · 2 of them stop for a person
A step is one station on the line. more
| No. | Step | Who does it | What happens | System of record | Time on the step | In flight |
|---|---|---|---|---|---|---|
| 01 | Frame Agentstrategy | Provision Agent | Provision Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Enterprise Data Warehouse | 14.4 hrsstandard 17.5 hrs | 9 |
| 02 | Research Agentstrategy | Compliance Calendar Agent | Compliance Calendar Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Enterprise Data Warehouse | 2.9 daysstandard 5.0 days | 28 |
| 03 | Model exposure Agentstrategy | Indirect Tax Agent | Indirect Tax Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Enterprise Data Warehouse | 32.3 hrsstandard 2.4 days | 30 |
| 04 | Draft position Agentstrategy | Transfer Pricing Agent | Transfer Pricing Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Enterprise Data Warehouse | 2.2 daysstandard 5.0 days | 46 |
| 05 | Challenge Agentstrategy | Tax Authority Correspondence Agent | Tax Authority Correspondence Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Enterprise Data Warehouse | 30.5 hrsstandard 2.8 days | 1 |
| 06 | Tax director ratify HumanpolicyDecision | VP Tax Releases: VP Tax | Work stops. VP Tax reviews what the line has produced and either releases the unit or sends it back. Nothing downstream of this step runs until that decision is made.Holds until: Held for a named human when the unit exceeds the tax filing decision envelope, when confidence falls below the floor, or when a policy clause is engaged. | Group ERP — Financials | 2.8 daysstandard 3.5 days | 1 |
| 07 | Counsel concur HumanpolicyDecision | VP Tax Releases: VP Tax | Work stops. VP Tax reviews what the line has produced and either releases the unit or sends it back. Nothing downstream of this step runs until that decision is made.Holds until: Held for a named human when the unit exceeds the tax filing decision envelope, when confidence falls below the floor, or when a policy clause is engaged.Hands off to legal | Group ERP — Financials | 36.3 hrsstandard 3.4 days | 6 |
The swimlane
The same steps, laid out by who is holding the work
Three lanes: a person deciding, an agent working, and the shared services spine. more
Run the procedure
One unit walked along that swimlane on the happy viable agentified path
Press run and a single unit enters at station 01. Each station takes exactly the dwell this platform records for it and is held by whoever the estate says holds it. more
Nothing has happened yet. more
- The lanes are the recorded lanes. 2 of the 7 stations stop for a person and every one of them still does on this run.
- Every one of the 2 decisions is still taken by the people who hold them. The happy path is that each one is released first time, not that it is skipped.
- The owning team is held to a 72% autonomy ceiling and this run sits at 66% unattended, inside it.
- 2 systems are attributed across the stations, and 0 of them are connected. Nothing in this run has been watched executing against a real system of record.
Nothing moves. 66% of the worked time already runs unattended and the owning team is held to a 72% ceiling, so the next decision cannot be handed over until somebody raises that ceiling.
- 06 Tax director ratify — Handing this over would put 100% of the worked time in the unattended lane, past the 72% ceiling this team is held to.
- 07 Counsel concur — The last decision on the line. Something on every procedure ends with a person, so this one is never offered.
This is a run, not a forecast. more
Happy means nothing goes wrong: no station raises an exception, no gate sends the unit back, no rework loop fires and nothing sits in a queue between stations. more
The second clock is the allowance. more
A decision may be handed to the agent lane only if two things hold … more
The run reads the station rows only. more
What this run does not model: arrival patterns, contention between procedures for the same person, shift patterns, weekends, learning curves, and the cost of anything. more
Run it again, going wrong
The same unit, the same stations, broken the way the estate already records breaking
This is the same unit on the same stations, breaking. more
No break below was chosen. more
One play head, two tracks, the same scale. The clean run stops when it runs out of stations; the other one keeps going.
As written
7 stations, nothing waiting, nothing sent back
0 min of 12.7 days
now Frame · Provision Agent · 14 hrs
As the ledger has it
the same stations, plus 4 categories the estate already counts
0 min of 13.5 days
now Frame · Provision Agent · 14 hrs
What breaks, and where it is counted
No break below was chosen. more
What the two runs say together
4 counted categories land on this procedure. more
What this run cannot claim
These breaks are shown together on one unit so the shape of a bad day fits on one screen. more
Two clocks run. Worked time is the sum of the time the work is actually being done … more
Roles and responsibilities
7 named parties
The responsibility grid is assigned by a rule, not lifted from a chart. more
| Party | RACI | Steps | Duty | Escalates to |
|---|---|---|---|---|
Tax Orchestrator orchestrator | Runs the line | 0 | Sequences this line, holds its timetable and decides what has to surface to a person. more | Raises to VP Tax when a unit falls outside the envelope or confidence drops below the floor. |
Provision Agent agent A3% autonomy · ceiling A3% 92% clean · 3% overridden | Responsible | 1 | Runs the repeatable portion of tax inside the shared transaction spine at spine cost and spine controls. | Escalates to VP Tax when the unit falls outside the decision envelope or confidence drops below the floor. |
Compliance Calendar Agent agent A3% autonomy · ceiling A3% 89% clean · 6% overridden | Responsible | 1 | Executes the tax step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Tax when the unit falls outside the decision envelope or confidence drops below the floor. |
Indirect Tax Agent agent A3% autonomy · ceiling A3% 90% clean · 9% overridden | Responsible | 1 | Executes the tax step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Tax when the unit falls outside the decision envelope or confidence drops below the floor. |
Transfer Pricing Agent agent A2% autonomy · ceiling A3% 96% clean · 9% overridden | Responsible | 1 | Holds the rules that bind every other agent in tax. more | Escalates on any decision that would breach a live policy version, with the clause cited. |
Tax Authority Correspondence Agent agent A3% autonomy · ceiling A3% 98% clean · 7% overridden | Responsible | 1 | Executes the tax step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Tax when the unit falls outside the decision envelope or confidence drops below the floor. |
VP Tax person | Accountable and responsible | 2 | Holds 2 decisions on this line. more | Accountable to VP Tax for the decisions held here. |
Decision points and escalation
2 places this procedure stops
06 · Tax director ratify
2.8 daysHeld for a named human when the unit exceeds the tax filing decision envelope, when confidence falls below the floor, or when a policy clause is engaged.
VP Tax
07 · Counsel concur
36.3 hrsHeld for a named human when the unit exceeds the tax filing decision envelope, when confidence falls below the floor, or when a policy clause is engaged.
VP Tax
Handoffs out of this procedure
Step 07 Counsel concur passes the work to legal.
The rules this procedure runs inside
4 governing rules
Tax Decision Envelope
activeFI7-POL-200 · envelope · vv4.7
Agents in this lane may act without a human when the tax filing sits inside the stated value, risk and confidence envelope. more
Approved by VP Tax · in force 2024-12-30 · reviewed 2026-05-25
Binds Provision Agent, Compliance Calendar Agent, Indirect Tax Agent, Tax Authority Correspondence Agent
LATAM · US
Tax Evidence Standard
activeFI7-POL-201 · evidence · vv4.3
Every autonomous decision writes inputs, the rule version applied, the model and prompt version, the output and a reversal path. more
Approved by VP Tax · in force 2025-06-26 · reviewed 2026-08-05
Binds Provision Agent, Compliance Calendar Agent, Indirect Tax Agent, Tax Authority Correspondence Agent
APAC
Tax Escalation Rule
activeFI7-POL-202 · escalation · vv4.0
Escalation is mandatory when confidence falls below the floor, when two options sit inside the confidence band, or when a break condition on a ratified position fires. more
Approved by VP Tax · in force 2026-04-05 · reviewed 2026-06-11
Binds Provision Agent, Compliance Calendar Agent, Indirect Tax Agent, Tax Authority Correspondence Agent
EU · UK
Tax Autonomy Ceiling
activeFI7-POL-203 · ceiling · vv1.8
The ceiling for this lane is 72 on the platform scale. more
Approved by VP Tax · in force 2024-12-17 · reviewed 2026-06-07
Binds Provision Agent, Compliance Calendar Agent, Indirect Tax Agent, Tax Authority Correspondence Agent
US · Canada
Systems this procedure touches
2 named · 0 connected
System attribution is a rule, not a reading. more
| System | Vendor | Domain | Criticality | Steps | Connection |
|---|---|---|---|---|---|
| Enterprise Data Warehouse | Snowflake | analytics | critical | 5 | modeled |
| Group ERP — Financials | SAP S/4HANA | ledger | critical | 2 | modeled |
0 of the 2 systems on this procedure is connected to the platform, and none of the twenty-six in the estate register is. 1 of them are marked as taking a write back, which is a property of the system, not a live path from here.
How it performs
End to end
12.7 days
Summed from the time each step sits, standard 22.9 days — running at 56% of the standard.
Touchless
37%
Agent share
71%
A week
2
In flight
121
Effort a week
6,262 human minutes · 12,038 agent minutes
Volume multiplied by the time on each step. more
Assurance over this procedure
4 governance gates sit above it
The twenty-four controls and eighteen exception classes in this platform are held at estate level … more
| Gate | What trips it | Who releases it | Clock | Waivable |
|---|---|---|---|---|
Payment above $100,000 approval | Any single payment or batch exceeding $100,000 | Controller and treasurer | 4 business hours | No |
Nonstandard journal entry approval | Any entry outside the approved recurring library, including estimates and reserves | Controller | 1 business day | No |
New or changed bank details approval | Any change to supplier or employee banking information | Treasury and supplier master owner | 2 business days | No |
External disclosure or board forecast approval | Any external report, statutory filing or board-committed forecast | CFO | 3 business days | No |
What this document is and is not
These procedures describe the modeled estate. more
Actions
What is waiting on a person
What one procedure document gives you, and what to check before you treat it as the standard.
named approvers appear across the library
Every decision point on every procedure carries a job title, not a queue. more
steps in the library hand their unit to another function
A handoff is where a procedure stops being one team’s problem. more
controls exist in the estate, and they belong to no procedure in particular
Controls and exception classes are held estate-wide. more
Operations
What this desk is allowed to start
A surface that only reports is not operable. more
Trigger and bound
A procedure document prints purpose, scope, entry and exit, the numbered steps with the actor on each, the roles and their RACI position, the swimlane, the decision points and escalation, the handoffs, the governing rules with version and approver, the systems by rule and the timings. more
Live observability
What the record shows right now
The whole library, by lane, so a single document can be read against the estate it came from. more
Current distribution
2,748 steps
Is policy and strategy coming to fruition
Whether the written intent is holding here
Half. The document is complete and every actor on it is measured more
Not holding on the record
A procedure here carries a version, an approver, an in-force date and a last-review date. more