Corporate Income Tax Workflow Base

Corporate Income Tax Workflow Base v0.1

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

What this file is

This is the Tier 1 workflow base for any corporate income tax content skill. It does not contain country-specific tax rules. It contains:

• The standard runbook for preparing a corporate income tax computation, return, and reviewer brief
• The structured intake form for gathering inputs from a corporate client
• The output specification for a reviewer-ready working paper
• The global refusal catalogue — situations a content skill must escalate to a credentialed practitioner without computing
• The 18 self-checks
• The citation discipline
• The Pillar Two interaction protocol
• The slot contract that every country-level content skill must fill

Every corporate income tax skill MUST be loaded alongside this base.

Section 1 — Audience and assumptions

This base assumes:

• The taxpayer is a corporation (incorporated entity) — not a partnership, trust, sole proprietorship, or individual
• The filing currency is the corporation's functional currency
• The corporation maintains accounting records under either local GAAP or IFRS (see ifrs-local-gaap-reconciliation.md for reconciliation)
• A credentialed reviewer (CPA / CA / CTA / Steuerberater / equivalent) reviews and signs off on every output before it is filed
• The corporation is in scope for the country's general corporate income tax — NOT a special regime (banking, insurance, REIT, fund, oil and gas, mining, shipping, aviation, charity — these require sector skills)

Section 2 — The runbook

Step 0 — Onboarding (always first)

Run the intake form (Section 4). Confirm:

• Country of incorporation
• Country of tax residence (place of effective management — POEM)
• Filing year-end date
• Corporate size and threshold tests (small / medium / large / MNE)
• Accounting framework (local GAAP / IFRS / Ind AS / etc.)
• Any consolidated / group tax filing status (Organschaft, intégration fiscale, group relief, etc.)
• Any in-scope regime overlays (Pillar Two, CFC, BEAT, GILTI)

If any of: cross-border activities; multiple shareholders with different tax residences; loss-making with restructuring; ongoing audit; M&A in the year → flag to reviewer before computation.

Step 1 — Reconcile accounting profit to tax profit

Start from the audited / approved profit-before-tax (PBT) per the corporation's accounting framework. Walk through:

Step 2 — Apply jurisdiction-specific rate

Apply the headline corporate income tax rate from the content skill. Where multiple rates apply (small-company rate, lower rate on first slice, surcharges), apply per the content skill's bracket schedule.

Step 3 — Apply credits and offsets

• R&D credits (see rd-tax-credits-matrix.md)
• Patent / IP box benefit (see ip-patent-box-matrix.md)
• Foreign tax credits
• Group relief utilisation
• Withholding tax credits on receipts
• Anti-double taxation relief

Step 4 — Compute and reconcile

• Tax liability before payments
• Less: provisional / advance payments made during the year
• Less: foreign tax credit utilisation
• Net tax payable / refundable

Reconcile to the corporation's accounting tax provision (current + deferred). Document material variances.

Step 5 — Pillar Two overlay (if applicable)

If the corporation is part of an MNE group with consolidated revenue ≥ EUR 750m (or local-equivalent threshold), apply the Pillar Two analysis from pillar-two-globe-minimum-tax.md:

• Compute Adjusted Covered Taxes
• Compute GloBE Income
• Compute jurisdictional ETR
• Apply SBIE and de minimis
• Compute Top-up Tax (IIR / UTPR / QDMTT)

Step 6 — Cross-border overlays

If the corporation has cross-border activity:

• Permanent establishment risk — see permanent-establishment-risk.md
• Withholding tax on outbound payments — see withholding-tax-matrix.md
• CFC inclusion — apply local CFC rules
• BEPS Action 5 IP regime nexus — see ip-patent-box-matrix.md
• DAC6 / MDR reporting — see dac6-mdr-reportable-arrangements.md
• CbCR / Action 13 — see CbCR skill (forthcoming)
• Transfer pricing documentation — see transfer-pricing-workflow-base.md

Step 7 — Deferred tax provision

Compute the deferred tax position under local GAAP / IFRS:

• Identify all timing differences (book-tax basis differences)
• Apply applicable tax rate (typically substantively enacted future rate)
• Recognise DTAs to the extent recoverable
• Track 5-year DTL recapture risk for Pillar Two (DTLs that do not reverse within 5 years are added back)

Step 8 — Filing assembly

Produce:

• The return / forms required by the jurisdiction
• The reviewer brief (Section 5)
• The tax provision schedule for the audit
• The tax payment schedule
• The supporting documentation index

Section 3 — Conservative defaults principle

When uncertain about any position, choose the treatment that costs more or imposes stricter compliance, never less. Your reviewer can correct an over-conservative position. They cannot easily recover from an aggressive one.

Applied to corporate income tax:

• Where a deduction is uncertain → flag, do not claim
• Where income classification is uncertain → use the higher-taxed classification
• Where a provision could be deductible OR non-deductible → exclude from claim, document the alternative
• Where an exemption is uncertain → treat as taxable
• Where treaty access is uncertain → withhold at domestic rate
• Where loss carryforward is uncertain → defer recognition of the DTA

Section 4 — Structured intake form

Every corporate income tax computation begins with:

[BASIC INFORMATION]
1. Corporation legal name and tax ID
2. Country of incorporation
3. Country of tax residence (and any conflict with incorporation country)
4. Tax year-end (calendar year, financial year, accounting period)
5. Accounting period if shorter than 12 months (specify reason — first year, change of accounting reference date, liquidation)
6. Audit status (audited, reviewed, compiled, none) and auditor name if audited
7. Accounting framework (IFRS-IASB, IFRS-EU, local GAAP, FRS 102, Ind AS, ASBE, etc.)

[SCOPE]
8. Industry / sector — confirm not in special regime (banking, insurance, REIT, fund, oil/gas, shipping, aviation)
9. Workforce — number of employees by jurisdiction
10. Activities by country — sales, services, manufacturing, R&D, IP, finance, holding
11. Consolidated group status — is this entity part of a wider group? Top parent identity and country
12. Group's consolidated revenue (for Pillar Two scope test)

[OWNERSHIP]
13. Shareholders — name, country of residence, % held, voting rights
14. Subsidiaries — name, jurisdiction, % held, activity
15. Major intra-group flows — IP licenses, services, finance, goods
16. Permanent establishments in other jurisdictions

[PRIOR YEAR]
17. Brought-forward losses (by category and country)
18. Brought-forward credits (R&D, FTC, etc.)
19. Capital allowances pools and depreciation schedules
20. Provisional payments made in current year

[CURRENT YEAR]
21. Material new positions taken (M&A, restructuring, asset disposal, new operations)
22. Tax authority interactions in the year (audit, ruling, MAP, APA)
23. Known controversies or open assessments
24. DAC6 / MDR / similar disclosures filed in the year

[CONFIRMATIONS]
25. The user confirms they will have the output reviewed by a credentialed practitioner before filing
26. The user confirms they have the authority to provide the data above

Section 5 — Output specification

Every corporate income tax skill must produce a reviewer brief containing:

1. Executive summary (1 page)
   - Tax position: total liability, refunds, balance due
   - Year-over-year movement and key drivers
   - Reviewer attention items (flagged [T2] or [T3])

2. Computation walk-through
   - Profit before tax (per audited financials)
   - Reconciliation to taxable profit (line-by-line adjustments with citations)
   - Tax at headline rate
   - Credits and offsets
   - Net tax liability

3. Cross-border / Pillar Two analysis (if applicable)
   - Permanent establishment risk
   - Transfer pricing position
   - Withholding tax on outbound payments
   - Pillar Two scope, ETR, Top-up Tax

4. Deferred tax provision
   - All timing differences with measurement
   - DTA recoverability assessment
   - 5-year recapture risk register

5. Supporting schedules
   - Capital allowances / depreciation
   - Brought-forward losses and credits
   - Foreign tax credit utilisation
   - Group relief flows
   - GAAR risk register

6. Reviewer questions
   - All [T2] items requiring reviewer judgement
   - All [T3] items requiring escalation

7. Filing assembly
   - Forms required
   - Supporting documentation index
   - Payment schedule

Section 6 — Global refusal catalogue

Refuse to compute and escalate to a credentialed practitioner if:

Section 7 — 18 self-checks

Before delivering output, verify:

1. Country of tax residence confirmed against POEM and treaty tie-breaker
2. Functional currency identified per IAS 21 / ASC 830 / local GAAP
3. Audited financial statements available; opinion is unmodified or modifications documented
4. PBT starting point matches the audited financials
5. All material non-deductible items added back with citations
6. All tax-exempt income subtracted with citations
7. Depreciation reconciled: book vs tax with capital allowances schedule
8. Brought-forward losses validated against last filed return
9. Foreign tax credits supported by withholding certificates / receipts
10. Transfer pricing position documented or master / local file ready
11. Permanent establishment risk in any non-residence country assessed
12. Pillar Two scope tested if group revenue ≥ EUR 750m
13. Deferred tax: DTAs recoverable on more-likely-than-not / probable basis
14. DTL 5-year recapture register maintained for Pillar Two
15. GAAR risk identified contemporaneously, not retroactively
16. DAC6 / MDR / equivalent disclosure status confirmed for the year
17. Filing deadline, payment deadline, and instalment schedule plotted
18. Output flags every [T2]/[T3] item for reviewer judgement and includes the reviewer brief

Section 8 — Citation discipline

Every figure in the reviewer brief must trace to:

• A statutory section (e.g., IRC §163(j), CGI Article 209, KStG §8, ITA §247)
• A regulatory citation (Treas. Reg., DGFiP BOI, HMRC manual, ATO PCG)
• A judicial decision where positional
• The corporation's accounting records line item (general ledger account, journal entry)

No figure may rely on "general practice" or "common interpretation" without explicit reviewer escalation.

Section 9 — Slot contract for country content skills

Every country-level corporate income tax content skill must populate:

[REGIME IDENTIFICATION]
- Jurisdiction code (ISO 3166-1 alpha-2 or jurisdiction-specific)
- Statutory framework (act name, sections)
- Tax authority name and portal
- Filing form numbers
- Filing deadline
- Payment / instalment schedule

[RATES]
- Headline corporate income tax rate
- Small company / reduced rate (if any)
- Surcharges (national / regional / sectoral)
- Reduced rates by activity (IP box, R&D, manufacturing zone)
- Branch profits tax rate

[ADJUSTMENTS]
- Statutory list of non-deductible expenses
- Statutory list of tax-exempt income (participation exemption, etc.)
- Depreciation rules (tax life vs accounting life)
- Interest deduction limitation (ATAD-equivalent, §163(j), thin cap)

[LOSSES]
- Carryforward period
- Carryforward cap (% of profit, currency cap)
- Carryback availability
- Change of ownership restrictions
- Group relief mechanism

[CREDITS]
- R&D credit (cross-ref to skill)
- Patent / IP box (cross-ref to skill)
- Foreign tax credit mechanism
- Investment credits
- Withholding tax credits

[FILING MECHANICS]
- Form numbers
- Submission portal / format
- Supporting schedules required
- Audit thresholds

[ANTI-AVOIDANCE]
- GAAR text and key tests
- CFC rules
- Hybrid mismatch rules
- BEAT / GILTI equivalent if applicable

[PILLAR TWO OVERLAY]
- QDMTT in force?
- IIR in force?
- UTPR in force?
- Domestic top-up mechanism

[CROSS-REFERENCES]
- Withholding tax matrix (this skill)
- Pillar Two (this skill)
- DAC6 / MDR (this skill if EU)
- IP box (this skill if regime exists)
- R&D credit (this skill if regime exists)
- Free zone overlay (this skill if applicable)
- Transfer pricing workflow base

Section 10 — Disclaimer

This workflow base produces working papers for review by credentialed practitioners, not direct tax advice. Every output is subject to credentialed reviewer sign-off before filing or acting upon.

The most up-to-date, verified version of this workflow base is maintained at openaccountants.com.

Source: OpenAccountants — open tax Guides for AI, reviewed by named CPAs/CAs/EAs. Quality: source-cited draft. For always-current figures and named-accountant backing, connect the OpenAccountants MCP server (openaccountants-mcp).