Treading water

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Treading water

editorial

Achieving transparency, whether as a taxpayer or tax authority, can often feel like you are treading water.

Achieving transparency, whether as a taxpayer or tax authority, can often feel like you are treading water. When it feels like you are getting closer to the shore, another wave of proposals, each with new rules and threats of controversy pushing you out into open water.

Internal procedures, data gathering, analytics, and clear policies all play a key part in achieving transparency. However, transparency initiatives are vulnerable to subjective judgements (page six).

Nevertheless, companies are often accused of pursuing the lowest effective tax rate possible. Many companies are now focused on educating tax authorities, stakeholders and the public to explain how they pay their taxes (page 74). Meanwhile, The B Team has found a framework that it believes could work for many large businesses (page 20).

Many reading this will argue that this is a problem for taxpayers as they aim to comply and protect their business reputation. However, tax authorities are dealing with the same challenges.

Country-by-country reporting (CbCR) and the automatic exchange of information (AEOI) are just two transparency initiatives where it is not entirely clear how governments are analysing and using the data. There are still deep trust issues partly because of this. Furthermore, if tax authorities are viewed as more aggressive and less trustworthy, taxpayers will be ever-more cautious about how open they are with their tax affairs.

It's a vicious circle between taxpayer and tax authorities, but what makes it tougher are tax justice networks fighting for more transparency and fairness. Despite the CbCR and AEOI initiatives being introduced, it's not enough for some non-governmental organisations (NGOs) and they continue to push the debate further (page 40). These networks, while performing an essential service, are not letting taxpayers and governments rest.

No matter what policies are put in place, it seems the water beneath our feet is always getting deeper as NGOs push the boundaries. Many will be trying to stay afloat and avoid getting lost at sea.

Anjana Haines
Managing editor, International Tax Review
anjana.haines@euromoneyplc.com

more across site & shared bottom lb ros

More from across our site

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Gift this article