Tax Risk in the Boardroom - Deloitte & Touche Canada

Number Specific Risk Exposure %1Unexpected tax costs and missed opportunities arising from complex,historical transactions, claims and elections - -2 Transfer pricing adjustments or errors due to cross border transactions, f 10,000,000 803 Inadvertent creation of CFCs or failure of CFCs to meet exemptions - -4 Inadequate or inappropriate provisions 5,000,000 805 Tax exposures arising from Treasury policy - -6 Inaccurate valuation of IP 5,000,000 707Tax law & environmental changes impacting Group tax profile &/orincreasing risk of additional challenges - -8 New tax products and services launched without adequate tax analysis- -9 Advers e impact arising from inadvertent change in company residence- -10 Tax risks arising from joint ventures (eg. Timing/flow of money) - -11Failure to maximize use, or lack of consideration outside tax function,of tax attributes & assets - -12 Management fees 5,000,000 9013 Loss of tax knowledge when people leave - -14Additional tax costs due to insufficient/in effective implementation &maintenance of planning & strategies - -15 Withholding tax errors on royalties and interest 4,000,000 8016 VAT errors on financing and cash-pooling - -17Tax costs arising due to inaccurate/unrealistic forecasts & financialinformation - -18Unexpected tax costs and missed opportunities on fixed assetpurchases, leasing or financing - -19Tax compliance inefficiencies/inaccuracies caused by inefficientaccounting systems & local GAAP reporting - -20 Availability of historical information & inadequate document retention - -21Tax advisers unaware of cross-border transactions or other significanttransactions - -