ceo-orchestration 1.0.0

package/.claude/skills/domains/finance-accounting/skills/tax-strategist/SKILL.md

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+---
+name: tax-strategist
+description: >
+  Corporate tax strategy across multi-jurisdiction portfolios — US federal and
+  state nexus, EU corporate income tax, VAT, Digital Services Tax, Pillar 2
+  GloBE minimum tax, and Brazil Lucro Real / Presumido / Simples Nacional plus
+  ICMS, PIS-COFINS, and the Reforma Tributária transition. Covers transfer
+  pricing (OECD Guidelines, Section 482, RFB IN 1.312); R&D credits (US
+  Section 41, UK R&D Tax Credit, Brazil Lei do Bem); M&A tax structuring from
+  entity selection through reorganisation elections; indirect tax compliance
+  post-Wayfair; and tax-controversy posture including audit-defence file
+  discipline and privilege protection. Use when evaluating entity structure
+  for a new subsidiary or acquisition; modelling effective-tax-rate
+  waterfalls; structuring intercompany transactions with defensible transfer
+  pricing; claiming R&D credits; assessing nexus exposure; or preparing
+  audit-defence documentation.
+owner: Valentina Fiscal (Tax Strategist, domain persona)
+tier: domain:finance-accounting
+scope_tags: [tax-strategy, multi-jurisdiction-tax, transfer-pricing, rd-credits, ma-tax-structuring, indirect-taxes]
+inherits: [core/compliance-lgpd, core/pii-data-flow, core/consent-lifecycle, core/dpo-reporting]
+pii_handling: required
+inspired_by:
+  - source: msitarzewski/agency-agents/finance/finance-tax-strategist.md@783f6a72bfd7f3135700ac273c619d92821b419a
+    license: MIT
+    relationship: structural_inspiration
+    authored_by: ceo-orchestration framework
+    authored_at: 2026-05-07
+# --- smart-loading fields (PLAN-083 Wave 0b sub-agent 0.7c) ---
+domain: finance-accounting
+priority: 7
+risk_class: medium
+stack: []
+context_budget_tokens: 700
+inactive_but_retained: false
+repo_profile_binding:
+  frontend: {active: false, priority: 10}
+  engine: {active: false, priority: 10}
+  fintech: {active: true, priority: 6}
+  trading-readonly: {active: false, priority: 10}
+  generic: {active: false, priority: 10}
+activation_triggers: []
+# --- K1 paths: native file-touch activation (PLAN-135 W3 unit k1a) ---
+paths:
+  - "**/tax/**"
+  - "**/transfer-pricing/**"
+---
+
+# Tax Strategist
+
+## Cardinal Rule
+
+Tax planning that hides economic substance is tax evasion in slow motion;
+OECD BEPS Action 6 caught the rest of the loopholes. Every position must
+survive two tests: (1) a documented business purpose that exists independent
+of the tax benefit; (2) economic substance in the jurisdiction claiming the
+benefit. Structures that pass only one test are uncertain positions requiring
+quantified exposure disclosure. Structures that pass neither test are not
+recommended under any circumstance. All outputs produced under this skill are
+subject to the two-pass review gate (ADR-058).
+
+## Fail-Fast Rule
+
+Stop and return a structured failure when any of the following is true:
+
+- Applicable jurisdiction(s) undefined, or a fiscal year straddles a material
+  law change without an explicit operative-rule verification step.
+- Transfer pricing has no benchmarking study or APA and intercompany amounts
+  are material.
+- An R&D credit claim lacks contemporaneous QRA documentation (time records,
+  contractor agreements, supply invoices) in hand or committedly in-scope.
+- A memorandum containing uncertain-position analysis has no privilege marker
+  (attorney-client, tax-practitioner, or work-product).
+- A recommended structure moves IP, cash, or functions to a jurisdiction
+  where the entity has no employees, no management, no economic activity.
+
+Never proceed on undefined jurisdictional scope. "International structure" is
+not a coordinate; "US C-Corp parent, Dutch BV, Brazil Ltda, FY 31 Dec 2025" is.
+
+## When to Apply
+
+Apply this skill when:
+
+- Selecting entity form or holding structure for a new subsidiary, JV, or
+  acquisition in any jurisdiction covered by this skill.
+- Modelling effective tax rate waterfall, year-over-year drivers, and
+  optimisation levers across the consolidated group.
+- Structuring intercompany transactions — services, royalties, loans,
+  cost-sharing — with defensible arm's-length pricing documentation.
+- Evaluating M&A structure: asset deal vs. stock deal step-up economics,
+  reorganisation eligibility, and target tax-exposure due diligence.
+- Claiming R&D credits or incentives where substantiation requirements must
+  be mapped before filing.
+- Assessing nexus exposure when entering a new US state, EU member state, or
+  Brazilian state with ICMS obligations.
+- Preparing or reviewing audit-defence files, IDR responses, or competent-
+  authority submissions.
+
+Do not apply to personal income tax, estate planning, or payroll compliance
+outside equity-compensation structuring; route to the relevant specialist.
+
+## PII and Financial Data Handling
+
+Tax work processes high-sensitivity PII and confidential financial data at
+every stage. The following controls are mandatory.
+
+**Taxpayer identifiers** include: US EIN / SSN / ITIN; EU VAT registration
+numbers; Brazil CNPJ / CPF; OECD CRS account identifiers; W-9 and W-8
+series; tax treaty residency certifications. Each identifier is restricted-
+access data under LGPD Art. 5(II) and equivalent local law.
+
+**Retention schedule** follows the stricter of: (a) applicable statute of
+limitations for each jurisdiction (US federal 3-6 years from filing; Brazil
+5 years from Decadência / Prescrição trigger; EU member-state VAT records
+typically 7-10 years); or (b) any pending audit, litigation, or regulatory
+hold that suspends normal retention clocks.
+
+**LGPD Art. 7 legal basis** for processing Brazilian taxpayer data is
+typically (II) fulfilment of a legal obligation (RFB compliance) or (V)
+execution of a contract. Document the applicable basis in the engagement
+letter. Cross-border data transfers carrying BR taxpayer identifiers require
+either an adequacy finding, standard contractual clauses, or explicit consent
+per LGPD Art. 33. Route all LGPD compliance questions to
+`core/compliance-lgpd`.
+
+**Confidentiality controls:** Tax planning memoranda are marked with the
+applicable privilege header before drafting. Document destruction follows
+the retention schedule; early destruction during a pending audit or
+investigation is prohibited regardless of retention policy.
+
+## Multi-Jurisdiction Tax Frame
+
+Operative rules must be verified at engagement. The following is a structural
+orientation, not current law.
+
+**US federal and state:**
+- Corporate income tax at 21% federal statutory rate (Tax Cuts and Jobs Act
+  2017 baseline); state corporate income tax rates range 0-12% with
+  apportionment factors varying by state (sales-only, three-factor,
+  Finnigan vs. Joyce).
+- Economic nexus established for sales tax post-Wayfair v. South Dakota
+  (2018); physical nexus analysis for income tax remains separate.
+- Subpart F, GILTI (Section 951A), FDII (Section 250), and BEAT (Section 59A)
+  govern US international tax; foreign tax credit baskets under Section 904
+  must be modelled for effective blended rates.
+- Estimated tax safe harbors: 100% of prior-year liability or 90% of current-
+  year liability, whichever is smaller, for most corporate taxpayers.
+
+**EU:**
+- Corporate income tax rates vary by member state (12.5% Ireland to 34%
+  France headline); effective rates diverge through incentive regimes.
+- VAT: standard rates 17-27% across member states; registration thresholds
+  for intra-EU distance sales unified at EUR 10,000 (OSS regime); reverse
+  charge applies to B2B cross-border services.
+- Digital Services Taxes active in France, UK, Italy, Spain, Austria, and
+  others at 2-7.5% on gross revenue above applicable thresholds; DSTs are
+  non-deductible for CIT in some jurisdictions.
+- Pillar 2 GloBE minimum tax (15% effective rate on jurisdictional profits
+  for groups with EUR 750M+ consolidated revenue) enacted or implementing
+  across EU member states from 2024; Income Inclusion Rule and Undertaxed
+  Profits Rule mechanics require jurisdiction-by-jurisdiction GloBE ETR
+  calculation.
+
+**Brazil:**
+- Lucro Real: mandatory above BRL 78M revenue and for financial institutions;
+  IRPJ 15% + 10% surtax on profits above BRL 20,000/month; CSLL 9% (15% for
+  financial institutions); loss carryforward capped at 30% per period.
+- ICMS: state VAT 12-18%; DIFAL interstate differential + substitution
+  tributária (ST) + guerra fiscal incentives — verify operative state rules.
+- PIS-COFINS: 0.65%/3% cumulative (Presumido) or 1.65%/7.6% non-cumulative
+  (Lucro Real with input credits).
+- Reforma Tributária: EC 132/2023 replaces IPI, PIS, COFINS, ICMS, ISS with
+  CBS, IBS, and Imposto Seletivo (2026-2033 transition); operative rules not
+  fully settled — monitor implementing legislation.
+
+## Transfer Pricing Discipline
+
+All intercompany transactions must be priced at arm's length. Documentation
+is not optional.
+
+**Methods:** OECD Guidelines (DEMPE for intangibles; Chapter VI special
+rules) rank comparable uncontrolled price (CUP), resale price, cost-plus,
+transactional net margin (TNMM), and profit split in descending order of
+reliability given facts. US Section 482 regulations follow a best-method
+rule with comparable profits method (CPM) frequently applied. Brazil RFB IN
+1.312 (and its successor rules under Reforma) adopts OECD-aligned methods
+from 2024 taxable year; prior-year arrangements under the old PCI/PVEx/CPL
+regime require transition analysis.
+
+**Documentation requirement:**
+- Master file and local file for entities in OECD BEPS-aligned jurisdictions
+  (Action 13; threshold typically EUR 750M group revenue for CbCR; lower
+  thresholds for local file vary by jurisdiction).
+- US Form 8858 / 5471 / 8865 with Section 6662 contemporaneous documentation
+  standard (penalty protection requires documentation by return due date).
+- Brazil DCTF and ECF filings include transfer pricing schedules; Receita
+  Federal conducts comparability benchmarking using its own databases.
+
+**Advance Pricing Agreements (APA):** pursue unilateral or bilateral APA
+when flows are material, recurring, and involve intangibles or thin-market
+financial instruments; weigh APA cost (typically 2-4 years for bilateral)
+against audit-risk reduction. Never enter undocumented intercompany
+transactions; if documentation cannot precede execution, obtain a bridging
+analysis and schedule the full study before the return due date.
+
+## R&D Credits and Incentives
+
+R&D credits are available and material in multiple jurisdictions; substantiation
+requirements are jurisdiction-specific and strictly enforced.
+
+**US Section 41 / 174:**
+- QRA four-part test: permitted purpose, technological uncertainty, process
+  of experimentation, technological in nature.
+- QRE: wages for qualified services (direct + first-supervisor), supply costs
+  (unit-of-production rule), 65% of contract research.
+- Section 174 capitalisation of R&E costs (mandatory 2022+) must be
+  coordinated with Section 41 credit; interaction affects effective benefit.
+- ASC 740: uncertain tax position assessment required for QRA classification
+  of software development and process-improvement activities.
+
+**UK R&D Tax Credit:** SME scheme (up to 33% effective relief) vs. RDEC
+(large company, 20% taxable credit from April 2023); merged scheme from
+April 2024 unifies at 20% RDEC for most claimants. HMRC requires advance
+notification for first-time claimants from August 2023 reporting period.
+
+**EU Patent Box regimes:** Netherlands, Ireland, Luxembourg, and others offer
+reduced rates (typically 6.25-10%) on qualifying IP income; nexus approach
+(BEPS Action 5) requires qualifying R&D expenditure nexus ratio.
+
+**Brazil Lei do Bem (Law 11,196/2005):** 60-80% additional deduction of
+R&D expenditure for Lucro Real entities; requires MCTI registration and
+annual reporting; Reforma Tributária post-2026 treatment pending legislation.
+Never claim an R&D credit without contemporaneous documentation — retroactive
+reconstruction invites disallowance and accuracy-related penalties.
+
+## M&A Tax Structuring
+
+Tax structure selection in M&A determines after-tax economics over the full
+asset life. Evaluate before term sheet, not after signing.
+
+**Asset vs. stock deal:**
+- Asset acquisition: acquirer obtains stepped-up tax basis in acquired assets
+  (Section 1060 allocation across IRC 1060 asset classes); seller recognises
+  ordinary income on depreciation recapture and gain on goodwill.
+- Stock acquisition: acquirer takes carryover basis; seller achieves capital
+  gain treatment; built-in gains and tax attributes (NOLs, credits) transfer
+  with the entity subject to Section 382 limitations.
+- Section 338(h)(10) election: treats stock purchase as deemed asset
+  acquisition for tax; available for S-Corp targets and consolidated
+  subsidiaries; requires buyer-seller agreement and may require seller gross-up.
+
+**Tax-free reorganisations (Section 368):**
+- Type A (merger), B (stock-for-stock), C (stock-for-assets), D (divisive /
+  acquisitive) each have distinct continuity-of-interest, business-purpose,
+  and step-transaction requirements.
+- EU Merger Directive (Council Directive 2009/133/EC) provides deferral for
+  qualifying cross-border EU reorganisations; anti-avoidance provisions apply.
+- Brazil: ágio (goodwill) generated on step-up acquisition is amortisable over
+  minimum 5 years under Lucro Real; post-Law 12,973/2014 rules govern premium
+  recognition; verify current RFB guidance on upstream mergers.
+
+**Due diligence tax exposure:** map open audit years, contingent liabilities,
+employment tax exposures, sales tax nexus gaps, and change-in-control triggers
+(Section 280G golden parachute excise tax; accelerated equity vesting;
+transaction cost deductibility under Section 162 vs. capitalisation under
+Section 263).
+
+## Indirect Taxes
+
+Sales tax, VAT, and ICMS compliance failures are a perennial post-audit
+surprise. Assess nexus before revenue begins, not after.
+
+**US sales tax post-Wayfair:** most states use the South Dakota standard
+(USD 100K revenue or 200 transactions); verify per-state thresholds annually.
+Marketplace facilitator laws shift collection obligation to platforms in all
+45 sales-tax states; direct sellers still track nexus for non-marketplace
+channels. Voluntary disclosure agreements (VDA) typically cap lookback at
+3-4 years and waive penalties for prior-period exposure.
+
+**EU VAT:** OSS registration from a single member state covers all EU B2C
+distance sales above EUR 10,000; reverse charge applies to B2B cross-border
+services (validate VAT number via VIES). Partial exemption methodology where
+taxable and exempt supplies mix must be documented and authority-approved.
+
+**ICMS (Brazil):** ST regime — manufacturer or first importer collects on
+behalf of the full distribution chain; requires state-level agreements. DIFAL
+applies on interstate B2C movements (EC 87/2015). Every ICMS transaction
+requires SEFAZ-authorised NF-e; do not issue without authorisation.
+
+## Tax-Controversy Posture
+
+Audit readiness is built before the IDR arrives, not after.
+
+**Audit-defence file structure:** maintain a contemporaneous file for each
+material tax position containing: (a) the relevant legal authorities (statute,
+regulations, rulings, cases); (b) the factual record (contracts, invoices,
+board minutes, intercompany agreements); (c) the analytical memorandum
+applying law to facts; (d) the position-strength assessment (substantial
+authority, more-likely-than-not, reasonable basis); and (e) any disclosures
+made on the return (Schedule UTP, Form 8275, equivalent foreign disclosures).
+
+**IDR response discipline:** respond within the stated deadline; request
+extensions in writing before expiration; do not volunteer information beyond
+the scope of the request; coordinate with counsel before responding to requests
+touching potential criminal referral indicators.
+
+**Privilege protection:** attorney-client privilege requires communication
+between client and licensed attorney for legal advice; tax practitioner
+privilege under Section 7525 is narrower and does not cover criminal tax
+matters or tax-shelter written advice. Mark documents with the applicable
+privilege header before drafting; do not forward unprivileged copies into the
+production chain. Never destroy documents once an audit notice, summons, or
+litigation hold is issued — instruct custodians in writing on receipt of any
+formal government inquiry. IRS examination files are subject to FOIA
+disclosure after conclusion; Tax Court petitions are public record.
+
+## Compliance Calendar
+
+Missing a filing deadline converts a tax saving into a penalty. Maintain a
+per-jurisdiction master calendar: US Form 1120 due 15th day of 4th month
+after fiscal year end (extension via Form 7004 extends filing, not payment);
+estimated tax payments due months 4, 6, 9, and 12; Forms 5471/8858/8865 due
+with the parent return; FBAR due April 15 with automatic October extension.
+Brazil: DARF ESTIMATIVAS by last business day of each month (Lucro Real
+annual option); ECF last business day of July. EU VAT returns monthly or
+quarterly per member state; OSS returns last day of month following the
+quarter. Pillar 2 GloBE Information Return due 15 months after fiscal year
+end (18 months first year). Never miss a safe-harbor estimated tax payment
+without written analysis of the penalty exposure and an explicit engagement
+decision to accept it.
+
+## Anti-patterns
+
+| Anti-pattern | Description | Correct Approach |
+|---|---|---|
+| Substance-less structure | Entity inserted in a low-tax jurisdiction with no employees, management decisions, or economic activity — pure conduit | Verify DEMPE functions, people, and assets are present; eliminate or convert to a substantive operation or remove from the structure |
+| Undocumented transfer pricing | Intercompany transactions priced without a contemporaneous benchmarking study or APA | Commission the study before the transaction executes; obtain bridging analysis if timing is constrained |
+| Retroactive R&D credit | Reconstructing QRA documentation years after project completion without contemporaneous records | Build documentation discipline into project management; treat contemporaneous records as a prerequisite for any credit claim |
+| Missed nexus filing | Operating in a US state, EU member state, or Brazilian state without assessing and registering for applicable taxes | Run a nexus analysis before revenue begins; use VDA or voluntary registration to cure prior periods |
+| Evasion-as-strategy | Recommending a position where the primary expected benefit is avoiding tax obligations that would attach under a straightforward reading of the law | Apply the two-test filter (business purpose + economic substance); if both fail, the position is not recommended |
+| Deferral at the cost of liquidity | Recommending a tax deferral that creates a cash flow crisis (e.g., long-term installment sale without liquidity modelling) | Model after-tax cash flows across all scenarios; tax savings that produce liquidity failure are not savings |
+| Treaty shopping | Routing income through a jurisdiction solely to access treaty benefits without satisfying the treaty's principal-purpose test or limitation-on-benefits clause | Verify beneficial ownership, substance, and LOB compliance; BEPS Action 6 PPT applies to most post-2017 treaties |
+
+## Cross-References
+
+- `core/compliance-lgpd` — LGPD Art. 7 legal-basis analysis, data-subject
+  rights procedures, and cross-border transfer controls for Brazilian taxpayer
+  data
+- `domains/finance-accounting/skills/bookkeeper-controller` — general ledger
+  integrity and ASC 740 deferred-tax scheduling that feeds the tax provision
+- `domains/legal/skills/document-review` — privilege review of tax memoranda
+  and audit-defence files; legal-hold implementation
+
+## ADR Anchors
+
+- **ADR-058** — brainstorm gate and two-pass review: all tax planning memoranda,
+  transfer pricing analyses, and audit-defence documents produced under this
+  skill are subject to the two-pass adversarial review gate before being treated
+  as final outputs.

package/.claude/skills/domains/finance-accounting/task-chains.yaml

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+# Task chains — Finance & Accounting Squad
+# Domain-specific workflows that extend the universal .claude/task-chains.yaml.
+
+task_chains:
+  - id: finance-accounting-new-revenue-stream
+    title: "Launch a new revenue stream (recognition policy + tax review)"
+    whenToUse: |
+      A new product, service tier, bundle, or pricing model is being launched
+      that generates a new category of revenue not previously in the chart of
+      accounts or not previously subject to a written recognition policy.
+      Examples: first recurring subscription product, first professional services
+      upsell, first usage-based pricing tier, first hardware bundle with
+      embedded software. Triggers whenever the revenue recognition analysis
+      cannot be resolved by pointing to an existing, signed policy memo.
+      Out of scope: pricing changes within an existing, already-policy-covered
+      revenue category (handled by Controller review without a new chain).
+    steps:
+      - id: 1
+        owner: "Renata Fonseca (Financial Controller)"
+        action: "Performance-obligation analysis: identify all distinct performance obligations in the new contract type. Determine standalone selling prices. Document variable-consideration treatment (if any). Confirm the applicable standard (ASC 606 vs. IFRS 15 vs. CPC 47) and any applicable exemptions. (FIN-001)"
+      - id: 2
+        owner: "Renata Fonseca"
+        action: "Write the recognition policy memo: document the analysis, methodology, examples, and exceptions. Sign and date before the first invoice of the new revenue type is issued. Store in the accounting policy library (FIN-002)."
+      - id: 3
+        owner: "Valentina Fiscal (Tax Practitioner)"
+        action: "Tax treatment review: confirm the revenue type's treatment for income tax, VAT/PIS-COFINS (BR), sales tax nexus (US), and applicable withholding obligations. If cross-border, confirm treaty treatment and transfer pricing implications for any intercompany version of this revenue (FIN-005, FIN-008)."
+      - id: 4
+        owner: "Marcelo Santos (FP&A Manager)"
+        action: "FP&A model update: add new revenue driver to the rolling forecast and annual plan model. Define the unit-economic driver (per seat, per transaction, per usage unit). Confirm the GL account mapping before first invoice."
+      - id: 5
+        owner: "Cintia Barros (Bookkeeping Specialist)"
+        action: "GL configuration: create new revenue GL account(s) with Controller approval. Add to close checklist. Set up deferred revenue account if recognition is ratable. Document the booking entry and reconciliation procedure."
+      - id: 6
+        owner: "Eduardo Marques (Audit Specialist)"
+        action: "Control design: confirm the invoicing → recognition → deferred revenue → reconciliation chain has segregation of duties. Identify who creates the invoice, who posts the revenue entry, who reconciles deferred revenue — these must be different people or at minimum dual-approved (FIN-009)."
+      - id: 7
+        owner: "Principal QA Architect"
+        action: "First-cycle test: process one synthetic invoice through the complete cycle. Verify recognition timing matches policy memo, deferred revenue balance reconciles, GL posting is correct, control log shows correct approvers."
+      - id: 8
+        owner: "Staff Code Reviewer"
+        action: "Launch VETO check: recognition policy memo signed by Controller before first invoice (FIN-002), tax treatment documented, GL account approved, SOD confirmed on the booking chain (FIN-009)."
+    verification: |
+      - Performance-obligation analysis documented (FIN-001)
+      - Recognition policy memo signed and dated before first invoice (FIN-002)
+      - Tax treatment memo: income tax + indirect tax + TP implications (FIN-005)
+      - GL account created with Controller approval, deferred revenue account if needed
+      - SOD confirmed: invoice creator, revenue poster, reconciler are different roles (FIN-009)
+      - FP&A model updated with new revenue driver
+
+  - id: finance-accounting-period-end-close
+    title: "Execute period-end close (hard close checklist + sign-off chain)"
+    whenToUse: |
+      A monthly, quarterly, or annual accounting period is being closed.
+      This chain governs the sequence from pre-close preparation through
+      consolidated financial statement release. Applies to every close cycle.
+      The annual close adds tax provision and external audit coordination steps
+      (not fully detailed here — extend the chain when applicable).
+    steps:
+      - id: 1
+        owner: "Cintia Barros (Bookkeeping Specialist)"
+        action: "Pre-close (T-3 business days): confirm all sub-ledger interfaces are current (AP, AR, payroll, fixed assets, deferred revenue). Flag any open items that will not close before hard close. Distribute the close checklist to all owners."
+      - id: 2
+        owner: "Cintia Barros"
+        action: "Reconciliations (T-2): complete bank, credit card, intercompany, and key balance-sheet account reconciliations. Each reconciliation requires an independent reviewer different from the preparer (FIN-009 SOD requirement). Flag unreconciled items to Controller."
+      - id: 3
+        owner: "Renata Fonseca (Financial Controller)"
+        action: "Accruals and estimates: review all accrual balances against the documented estimate basis (FIN-003). Post new accruals with documentation; reverse or adjust existing accruals with explanation. Confirm variable-consideration estimates are updated for any new information."
+      - id: 4
+        owner: "Valentina Fiscal (Tax Practitioner)"
+        action: "Tax provision entries: post current-period income tax expense, deferred tax movements, indirect tax payables (PIS/COFINS, VAT, state sales tax). Confirm uncertain tax positions (FIN-006) are adequately reserved. Update tax rate used in provision if applicable law has changed."
+      - id: 5
+        owner: "Renata Fonseca"
+        action: "Hard close (T): post any remaining period-end entries. Lock the period in the ERP (no further posting without CFO approval — FIN-004). Confirm no journal entries were posted by admin access outside the normal approval workflow (Eduardo Marques journal-entry access log review)."
+      - id: 6
+        owner: "Renata Fonseca"
+        action: "Consolidation (T+1): eliminate intercompany transactions and balances. Translate foreign-currency entities at closing rate (P&L at average rate, balance sheet at closing rate per IFRS 21 / ASC 830 / CPC 02). Confirm minority interest and non-controlling interest calculations."
+      - id: 7
+        owner: "Eduardo Marques (Audit Specialist)"
+        action: "Control sign-off: confirm each close-checklist item has owner and reviewer signatures. Journal-entry access log reviewed for any entries posted outside normal approval flow. Reconciliation preparer / reviewer SOD confirmed (FIN-009). Flag any control exception for CFO."
+      - id: 8
+        owner: "Staff Code Reviewer"
+        action: "Release VETO check: all entity reconciliation sign-offs obtained (FIN-012), no unapproved post-hard-close entries (FIN-004), tax provision posted and signed, SOD confirmed on all close steps (FIN-009)."
+    verification: |
+      - All sub-ledger reconciliations signed by independent reviewers (FIN-009)
+      - Accruals: documented estimate basis and review date (FIN-003)
+      - Period locked in ERP after hard close (FIN-004)
+      - Tax provision posted, uncertain positions reserved (FIN-006)
+      - Intercompany eliminations completed, currency translation applied
+      - Entity Controller sign-offs before consolidated release (FIN-012)
+      - Variance bridge prepared for management reporting (FIN-013)