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2025 tax planning: The four boxes you need to check

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Agility and planning are king in the world of taxes. As the tax regulatory landscape continues to evolve in the U.S. and the world, it is critical that tax teams are thinking ahead and checking the boxes for a successful tax year in 2025.

Transfer pricing enforcement: The IRS brings the hammer

On Oct. 20, 2023, the IRS announced it would increase its compliance efforts to ensure that U.S.-owned multinational enterprises (MNEs) that distribute goods in the U.S. “pay their fair share of taxes on the profits they earn from their U.S. activities.” 

What does this mean for your business? Ultimately, you and your team should be prepared for the IRS to become more aggressive on stamp transactions and assert transfer pricing penalties, especially in the absence of thorough and comprehensive transfer pricing documentation studies.

In addition, the IRS is taking swift action to close gaps following decades of budget cuts. Large foreign-owned and U.S.-owned corporations should be prepared for a more aggressive battle with the IRS and work with industry experts who understand the ins and outs of audit-ready compliance deliverables. Furthermore, the IRS has announced that some foreign-owned companies are reporting losses or exceedingly low margins, which can be driven by transfer pricing. Foreign-owned distributors should be prepared for audits and implement internal procedures to monitor intercompany pricing.

Global minimum tax (yes, we are still talking about it)

While you’re likely tired of discussing the global minimum tax, it’s a critical component of your tax preparations. The Global Anti-Base Erosion Model Rules under the Organisation for Economic Co-operation and Development’s Pillar Two seeks to introduce a minimum effective corporate tax rate of at least 15%.

As countries prepare to implement these concepts in their local tax regulations, tax professionals must navigate the complexities of compliance, including the intricacies of determining effective tax rates and understanding how the minimum tax interacts with local tax laws. The adoption of the global minimum tax could reshape corporate tax planning strategies, requiring tax advisors to rethink approaches to cross-border transactions, transfer pricing and risk assessment, all while staying attuned to evolving legislative developments and the implications for their clients’ international operations.

Using technology to inform accurate data, planning opportunities and compliance are a few strategies that can set your company up for success. Continually assessing and monitoring these complex and evolving concepts will be critical as companies move into 2025.

The IRS GLAM on financial transactions

On Dec. 29, 2023, the IRS issued General Legal Advice Memorandum (GLAM) AM 2023-008 titled “Effect of Group Membership on Financial Transactions under Section 482 and Treas. Reg §1.482-2(a).”

The GLAM provides nonbinding legal guidance with respect to the effects of group membership on related party financial transactions under Section 482. The GLAM provides guidance which aligns with the IRS’ position in various controversies in this area and highlights the importance of obtaining outside technical advice in this area. 

Transfer pricing and sustainability go hand in hand

When it comes to sustainability and transfer pricing, there is not a one-size-fits-all approach. Partnering with a trusted and experienced transfer pricing team that can advise you on models that reflect sustainable practices, such as eco-friendly production processes or ethically sourced materials, is a valuable way to build a company’s sustainability hub, or microbusiness, within its current organization.

Furthermore, regulatory developments around transfer pricing are increasingly emphasizing transparency and accountability. This shift encourages companies to disclose more information about their environmental impact and to consider how their pricing strategies affect local communities and ecosystems. As a result, businesses that proactively integrate sustainability into their transfer pricing practices may enhance their reputation, mitigate risks, and create long-term value while appealing to a growing base of environmentally conscious consumers and investors.

As your tax team prepares for compliance in 2025, considering and planning for the multifaceted challenges and opportunities presented by transfer pricing, IRS enforcement, GLAM and sustainability is essential. Establishing strategies that meet regulatory requirements as well as your organization’s needs will serve your team well as it navigates the international tax landscape.

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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