Boundaries are ubiquitous in modern social life, and the work of creating and maintaining boundaries is particularly evident within regulatory fields. Through the analysis of a recent critical incident in the tax field (Arctic Systems) with which the accounting profession is intimately associated, this paper uses a Bourdieusian lens to unravel the relational complexities of the regulation of tax avoidance at the complex and fuzzy boundary between acceptable and unacceptable tax practice. We develop an alternative, relational interpretation of tax regulation and contribute to a more nuanced understanding of regulatory practice within the tax field that also raises questions about regulatory practice more widely. We conclude by highlighting how a move towards 'relational' regulation might contribute to improved understanding of regulatory processes and practices.

This paper analyses a previously unexamined but nonetheless important facet of modern society -the nature and impact of the relationship between in-house tax professionals in large multinational organizations, and the external business, tax and regulatory environments within which they operate. Drawing on face-to-face interviews conducted with senior tax executives in US multinational enterprises (MNEs), we uncover the social reality of the world in which MNEs' tax executives operate, and find that these tax professionals are a powerful, elite group of knowledge experts who can significantly shape tax law and practices. We analyze the activities of these experts who, although working largely in the shadows of their organizations, are very much engaged in constructing and shaping the wider institutional environment. From a theoretical perspective that brings together institutional work and the endogeneity of law, we find these elite professionals engaging in subtle and diffuse exercise of power at a micro level within their organizations, a meso level between organizations within the field and at a macro level within the wider external environment. This has important implications for our broader understanding of the tax and regulatory environments which corporate actors inhabit.

Corporate tax avoidance has been a matter of considerable public attention, particularly since the 2008 global financial crisis. The nature of calls for tax reform and increased regulation, advocated most prominently by tax activists and NGOs, has revolved around transparency as a possible corrective to unacceptable tax avoidance, although there is no consensus as to what the term tax avoidance encompasses and when it becomes unacceptable. We examine two responses to calls for increased transparency about the tax affairs of multinational entities: firstly, country by country reporting that provides information to tax authorities, and secondly the UK requirement for publication of tax strategies, whereby large companies put information into the public domain. We find considerable misunderstanding about the benefits of transparency in this setting. By failing to consider the limits of transparency initiatives there is a risk of dysfunctional consequences, for example additional costs in providing and processing additional information, the prospect of increased disputes as new information generates new misinterpretations and uncertainty in determining the final tax position. There is a risk that greater disclosure will not effectively address concerns about unacceptable corporate tax avoidance.

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We present an analysis of over 400 comments about complying with tax obligations extracted from online discussion forums for freelancers. While the topics investigated by much of the literature on taxpayer behaviour are theory driven, we aimed to explore the universe of online discussions about tax in order to extract those topics that are most relevant to taxpayers. The forum discussions were subjected to a qualitative thematic analysis, and we present a model of the ‘universe’ of tax as reflected in taxpayer discussions. The model comprises several main actors (tax laws, tax authority, tax practitioners, and the taxpayer’s social network) and describes the multiple ways in which they relate to taxpayers’ behaviour. We also conduct a more focused analysis to show that the majority of taxpayers seem unconcerned with many of the variables that have been the focus of tax behaviour research (e.g. audits, penalties, etc.), and that most people are motivated to be compliant and are more concerned with how to comply than whether to comply. Moreover, we discuss how these ‘real-world’ tax discussions question common assumptions in the study of tax behaviour and how they inform our understanding of business ethics more generally.