The Future of Tax Deliverables: Agility, Legal Design and Artificial Intelligence
In an increasingly complex tax environment, the expectations of Tax Departments towards their advisers are shifting rapidly. The era of 40-page academic memoranda is over. Companies, driven by the need for agility, now require concrete, immediately actionable solutions.
To unpack this transformation and highlight emerging best practices, Joëlle Bui, Group Tax Director at Publicis Group, and our tax partner, Pierre Bonamy, discussed the current demands of Tax Departments.
Listen the podcast:
What Tax Departments Want (and What They No Longer Accept)
Joëlle Bui, whose team manages the tax affairs of a group present in more than 80 countries, notes that client satisfaction varies. However, frustration often arises when the deliverable does not match the company’s practical needs.
From the discussion, several expectations clearly emerged:
Clear answers and solutions
Most clients expect a direct answer or a concrete solution to their issue.The Executive Summary
This is “extremely important”. Key answers must appear clearly and early in the document. Joëlle Bui cites a 25-page memorandum from an Indian law firm for which she had to request an executive summary before even beginning to read. It enables swift use of the information.A Practical Approach
Deliverables must help teams save time. The ideal memorandum, according to Joëlle Bui, provides: • a technical answer for the file, • a concise summary that can be forwarded to non-tax specialists, • the practical steps required for implementation.For example, in a VAT advisory note, the memo should specify how to report the transaction on a CA3 form (i.e., in which box). Without this, the deliverable is not usable by the accounting or finance teams.
Communication
If the Tax Department manages to express its expectations clearly from the outset (practical guide, decision tree, executive summary), the risk of disappointment is significantly reduced.The Era of Legal Design and Quantitative Modelling
According to our partner, Pierre Bonamy, experience shows that clients do not expect “a comprehensive academic treatise” nor multi-page memos reproducing applicable rules copied from the Bofip.
Expertise increasingly lies in the formal and quantitative adaptation of tax advice:
Integrating Quantification
Tax law offers the unique ability to quantify the impact of a tax rule. If the adviser does not do so, the client will inevitably ask: “How much will this cost?” or “What will be the cash impact?” It is essential either to provide figures or, at minimum, an order of magnitude. A number is “far more meaningful than lengthy technical developments”. Pierre Bonamy also notes that quantification sometimes needs to be integrated upstream of the analysis to ensure that the potential exposure justifies the level of fees.Adopting Legal Design
Although legal design is often associated with contract law, there are “real opportunities” in tax. Tax law is objectively complex and inherently quantitative.Tools valued by companies include:
- Decision trees: They map scenario by scenario to reach simple conclusions, particularly effective for complex topics such as VAT. Clients often respond much more positively to a summary visual diagram than to the preceding pages of analysis. - Modelling files: Simplified Excel tools using yes/no inputs to produce figures or recommendations. These deliverables are essential when the information must be used by operational teams, sales departments or CFOs. - Practical guides: Joëlle Bui recalls selecting a firm that proposed to present its memorandum in the form of a practical guide, which made a decisive difference.For Pierre Bonamy, this shift is even more necessary because legal practice remains heavily influenced by litigation formats (lengthy briefs and court-imposed structures), which are ill-suited to advisory work.
Artificial Intelligence: A Catalyst for Added Value
The arrival of AI is “not overrated”. AI can help structure formats and thinking. It is highly convincing for productivity and low-value tasks.
Joëlle Bui cites the example of a tax software tool that, using AI, can analyse a group structure (organisational chart) and rapidly answer compliance questions (e.g., applicable withholding tax rate on dividends between two entities, checking whether the tax residence certificate is on file).
For Joëlle Bui, “The adviser’s role will be to ask the questions the client did not see when framing their query.”
AI will “pre-process the work” and render redundant those who merely reproduced copied content. It re-centres the adviser on:
Reasoning and Anticipation
AI cannot yet connect multiple sources or anticipate the questions the client has overlooked. The adviser must ask the essential question: “You have considered this, but have you also considered this?”Experience and Trust
An adviser who works regularly with a client understands its structure and countries of operation, which is “hard to substitute”. This knowledge enables the adviser to go beyond the immediate answer, anticipating questions and identifying opportunities.The Future of Tax Advisory
The future of tax deliverables will be shaped by deliberate transformation.
Joëlle Bui believes that firms that adapt most quickly to new market expectations (legal design, clarity, quantification) will be best positioned to deliver added value.
Our Tax partner, Pierre Bonamy, is optimistic. He expects a “positive contagion” effect. In his view, “Pressure from clients and AI will create a selection effect, forcing the profession—historically somewhat more traditional—to adopt better practices.”
Ultimately, the future performance of tax advisory will depend on its ability to combine high-level technical expertise with presentation tools that guarantee clients’ operational agility.
Our Tax team advises executives and companies across all areas of tax law, with strengthened expertise in innovation tax matters, employee share ownership and the management of tax audits and tax litigation.