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 2025

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

AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed
Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said
Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
Gift this article