December 2025
Mastering new rules demands robust controls, cross-functional collaboration and auditor engagement.
This year’s Conference1 featured a session addressing the evolving tax landscape – focused on on how recent tax changes are moving beyond the tax function to influence broader business strategy, capital allocation and risk management.
Host Matt Drucker (KPMG Partner) was joined by panelists Marianne Deda (Liberty Global Inc. – Director, Global Tax & Financial Reporting), Agnieszka Samoc (Danaher – Vice President and Tax Counsel) and Rochelle Hodes (Crowe – Principal). The discussion centered on these critical areas:
Tackling the complexities of ASU 2023-09 and global tax shifts requires a truly integrated approach. It's essential to build robust internal controls, ensure open cross-functional coordination and strategically leverage technology. This isn't just about compliance – it's about turning these challenges into opportunities for balanced transparency and operational efficiency.
Matt Drucker
KPMG Partner, Department of Professional Practice
Panelists highlighted that the new income tax disclosure rules under ASU 2023-09 present substantial operational challenges. Compliance necessitates meticulous data management and robust control frameworks. Panelists also emphasized that early interaction with auditors is critical to a seamless implementation.
ASU 2023-09 requires companies to disaggregate certain income tax information, including the rate reconciliation and income taxes paid, into more detailed categories.
This increased granularity helps financial statement users better understand a company's tax position and cash flows, but it requires significant judgment in categorizing and presenting this disaggregated data.
Learn more about the new disclosures in our Hot Topic, Income tax disclosures.
A key theme was the integration of tax with business strategy. With regimes like the Corporate Alternative Minimum Tax (CAMT) using financial income as a tax base, tax is now a critical, early-stage input for capital allocation decisions. Panelists stressed that companies must holistically model how implications in one area might trigger unintended consequences elsewhere, making tax a proactive, strategic function.
The session addressed the transition from confidential tax reporting to public disclosure, primarily driven by Pillar Two and Country-by-Country Reporting (CbCR). This shift introduces new risks for organizations, compounded by significant legislative and judicial uncertainty.
The panel also discussed broad legislative and regulatory changes, including recent tax law changes. These changes are causing many companies to reevaluate their global treasury practices, international ownership structure (e.g. location of intellectual property) and tax planning.
Panelists identified two major sources of uncertainty. First, the Supreme Court’s overruling of Chevron deference in Loper Bright clouds the authority of future tax regulations, creating risk but also potential for challenge by taxpayers. Second, the uncertain US response to the global Pillar Two regime creates geopolitical tension, as US companies may face foreign taxes while negotiations for relief remain ongoing.
These shifts demand a proactive approach to risk assessment, strategic tax planning and expert guidance to navigate an increasingly complex and unpredictable regulatory landscape.
For Pillar Two implementation steps, and how accounting and finance may be impacted, download our executive summary, Pillar Two Gameplan. And for the latest on tax law implementation, read our Hot Topic, Checking in on Pillar Two and Accounting for One Big Beautiful Bill.
Pillar Two is a new global tax regime designed to ensure that multinationals pay taxes of no less than a 15% rate in every jurisdiction in which they do business. If that minimum tax rate has not been met in a particular jurisdiction, companies will pay a ‘Top-Up Tax’. The Pillar Two rules require complicated and data-intensive calculations of a new effective tax rate measure (the ‘Globe ETR’) for every single jurisdiction in which the company has operations.
CbCR is a global transparency initiative led by the Organisation for Economic Co-operation and Development (OECD) that requires large multinational enterprises (MNEs) to report their income, taxes paid and other indicators of economic activity on a country-by-country basis. This information is shared with tax authorities to help them assess transfer pricing risks and other tax avoidance-related risks.
The shift to public tax disclosure represents a pivotal moment for multinational organizations. It’s no longer sufficient to just report the numbers; companies must now be prepared to publicly articulate their global tax story with clarity and confidence. This requires a proactive, cross-functional approach to manage reputational risk and address increased scrutiny from stakeholders and the public.
Nick Tricarichi
KPMG Partner, Department of Professional Practice
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