One minute with Emmet Bulman, director in PwC’s financial services tax practice in London.
What is keeping you busy at work
I spend most of my time supporting financial services clients in the strategic transformation and operational improvement in their approach to tax governance and risk management. This primarily involves the deployment of enterprise risk management, governance and operational risk tools and techniques as well as process, technology, data and people related improvements. More broadly, it involves working with clients as they undergo broader finance and tax function transformations, launch new products and enter new markets, manage tax authority relationships and compliance with tax governance regimes, as well as designing robust frameworks for preventing tax crime and delivering operational resilience across end-to-end processes.
What do you know now that you wish you’d known at the start of your career?
I would be more willing to take controlled risks and move outside of my comfort zone when seeking career development opportunities. As I have progressed in my career, I have become more confident in doing so and have seen the benefits – which leaves me wondering what if I started earlier!
Are there any new rules that are causing a particular problem in practice?
The policing of aggressive tax avoidance and evasion is increasingly converging, with expectations of financial services market participants increasing. This stems from the important role that they are deemed to play as intermediaries in and ‘gatekeepers’ of the financial system.
This is evident from the emergence of new national regimes, such as the DNB (Dutch Central Bank), guidance on customer tax integrity, CSSF rules on tax fraud in Luxembourg and the consultation on a potential new criminal offence for promoters of tax avoidance announced in the UK Spring Budget to potentially sit alongside the existing CCO rules. In addition, the European Commission launched a call for evidence in respect of a potential EU Directive on tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in H2 2022 with a decision on whether to proceed being imminent.
Financial institutions will need to consider their wider operating model in respect of how they manage financial crime and tax risk more generally to ensure they address this convergence in as effective and efficient a manner as possible.
What is a key difficulty with clients when managing tax risk?
It is probably the age-old problem that most tax related risks arise outside of the tax function in the broader end to end processes and systems that flow into and impact clients’ tax compliance and reporting processes – a point which is frequently not fully appreciated by non-tax stakeholders. Given the specialist nature of tax risk, collaboration between the tax function, market facing businesses and functions such as finance, operations, compliance and HR is vital. These areas need to ensure that all business activity with the potential to give rise to tax risk is brought to the attention of the tax function for review and assessment. In addition, they need to make sure that tax impacting operational and business processes for which those areas outside of tax are responsible for are operated in line with the control framework, policies and standards issued by the tax function.
You might not know about me but...
I am a passionate rugby union fan and avid supporter of the Ireland and Munster rugby union teams. This year I have been really lucky to be able to attend all five of Ireland’s Six Nations matches culminating in seeing them beat England on St Patrick’s weekend to win the Six Nations Grand Slam – the first time this has been completed in Dublin.
One minute with Emmet Bulman, director in PwC’s financial services tax practice in London.
What is keeping you busy at work
I spend most of my time supporting financial services clients in the strategic transformation and operational improvement in their approach to tax governance and risk management. This primarily involves the deployment of enterprise risk management, governance and operational risk tools and techniques as well as process, technology, data and people related improvements. More broadly, it involves working with clients as they undergo broader finance and tax function transformations, launch new products and enter new markets, manage tax authority relationships and compliance with tax governance regimes, as well as designing robust frameworks for preventing tax crime and delivering operational resilience across end-to-end processes.
What do you know now that you wish you’d known at the start of your career?
I would be more willing to take controlled risks and move outside of my comfort zone when seeking career development opportunities. As I have progressed in my career, I have become more confident in doing so and have seen the benefits – which leaves me wondering what if I started earlier!
Are there any new rules that are causing a particular problem in practice?
The policing of aggressive tax avoidance and evasion is increasingly converging, with expectations of financial services market participants increasing. This stems from the important role that they are deemed to play as intermediaries in and ‘gatekeepers’ of the financial system.
This is evident from the emergence of new national regimes, such as the DNB (Dutch Central Bank), guidance on customer tax integrity, CSSF rules on tax fraud in Luxembourg and the consultation on a potential new criminal offence for promoters of tax avoidance announced in the UK Spring Budget to potentially sit alongside the existing CCO rules. In addition, the European Commission launched a call for evidence in respect of a potential EU Directive on tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in H2 2022 with a decision on whether to proceed being imminent.
Financial institutions will need to consider their wider operating model in respect of how they manage financial crime and tax risk more generally to ensure they address this convergence in as effective and efficient a manner as possible.
What is a key difficulty with clients when managing tax risk?
It is probably the age-old problem that most tax related risks arise outside of the tax function in the broader end to end processes and systems that flow into and impact clients’ tax compliance and reporting processes – a point which is frequently not fully appreciated by non-tax stakeholders. Given the specialist nature of tax risk, collaboration between the tax function, market facing businesses and functions such as finance, operations, compliance and HR is vital. These areas need to ensure that all business activity with the potential to give rise to tax risk is brought to the attention of the tax function for review and assessment. In addition, they need to make sure that tax impacting operational and business processes for which those areas outside of tax are responsible for are operated in line with the control framework, policies and standards issued by the tax function.
You might not know about me but...
I am a passionate rugby union fan and avid supporter of the Ireland and Munster rugby union teams. This year I have been really lucky to be able to attend all five of Ireland’s Six Nations matches culminating in seeing them beat England on St Patrick’s weekend to win the Six Nations Grand Slam – the first time this has been completed in Dublin.
