ACCOUNTING-TAX HARMONIZATION IN MULTINATIONALS WITH OPERATIONS IN BRAZIL AND THE UNITED STATES: A THREE-DIMENSIONAL GOVERNANCE AND TECHNOLOGY FRAMEWORK FOR TAX COMPLIANCE

Abstract

This article examines how multinational enterprises operating in Brazil and the United States can coordinate accounting and tax rules, data, processes, and controls without seeking to standardize IFRS, US GAAP, or the countries’ tax systems. The study is qualitative, exploratory, bibliographic, and documentary, updated on October 2, 2026, and draws on academic literature and primary Brazilian, United States, and international sources. The analysis supports the proposal of a three-dimensional conceptual framework comprising normative, factual, and axiological dimensions, integrated through governance and enabled by information technology. The proposal differs from the OECD Tax Control Framework and general internal-control frameworks by bringing together, within a single structure, accounting recognition and presentation differences, cross-border tax obligations, operational capacity, and the values of integrity, transparency, tax fairness, and legal certainty. Its theoretical application to transfer pricing, GloBE/Pillar Two rules, and the 2026 CBS/IBS transition shows how the framework can guide decisions, system configurations, reconciliations, and audit trails. Information technology improves reliability and traceability but does not replace legal interpretation, data governance, or human oversight. The framework remains conceptual and requires operationalization and empirical validation.