Every company already has a TCF!

"Each company already has a TCF by definition, otherwise it would not be able to submit any tax return. It does not have to be built from scratch, but one should start by identifying all the tax controls already in place within the organization, e.g. along the COSO criteria for internal control. This also implies that a TCF should be viewed not as a stand-alone thing, but as part of the company’s business risk management or business control model. In addition, given the overall objective just described, the approach should be top-down, not bottom-up, and should be risk-based: focus on the risks and controls that really matter."

That is why a zero measurement is a first step, do you agree?