An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network

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An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network Sam Dallyn Alliance Manchester Business School, University of Manchester, Booth Street East, Manchester, M15 6PB, United Kingdom

a r t i c l e

i n f o

Article history: Received 9 September 2016 Received in revised form 9 November 2016 Accepted 1 December 2016 Available online xxx Keywords: Corporate tax avoidance Politics Civil society Tax justice network

a b s t r a c t Corporate tax avoidance (CTA) has become a high profile issue despite being a complex area of accounting practice. One reason for this has been the civil society campaign opposing tax avoidance. The paper provides a case study of one key civil society actor: the Tax Justice Network (TJN). Existing accounting analysis offers little to explain how some accounting issues acquire political attention and media coverage. To address this, the concept of political salience is introduced into accounting analysis – understood as the creation of focal points in campaigns – to consider how the TJN contributed to the political profile of CTA. Crown Copyright © 2016 Published by Elsevier Ltd. All rights reserved.

1. Introduction Corporate tax avoidance (CTA) involves an extremely complex set of accounting practices that give rise to difficult political, legal and accounting issues not necessarily amenable to mainstream media coverage. Yet in recent years CTA has become probably the most prominent accounting issue in contemporary politics (Cameron, 2013; Public Accounts Committee, 2015). For example, for the last four years CTA has ranked as the issue which concerns the British public most in business conduct in the Institute of Business Ethics Survey (IBE, 2016). Yet only 10 years previously, the Oxford Centre for Business Taxation found that a collection of business respondents and HMRC representatives viewed CTA as too technical and complex for the general public to engage with (Freedman, Loomer, & Vella, 2007: 40). The problem is essentially that many large multinationals ‘are able to avoid an alarming proportion of their tax obligations through complex and contrived arrangements’ (Brock & Russell, 2015) involving secrecy and offshore locations (Palan, 2003). This paper provides a partial answer to how CTA has been transformed into a high profile issue, through a case study of one NGO that has been at the centre of the emergence of the issue: the Tax Justice Network (TJN). Civil society campaigning has been an important, and often academically overlooked, factor in the transition that CTA has made from a complex issue that was largely the preserve of tax lawyers and accountants to an issue that sparks widespread political debate and controversy (see for example Holland, Lindop, & Zainudin, 2013; Dyreng, Hoopes, & Wilde, 2014; Seabrooke & Wigan, 2015a). The TJN is an unusual advocacy NGO, based around distinctive accounting and tax expertise. The network has been situated as a ‘clear leader’ (Seabrooke & Wigan, 2015a: 6) in the tax justice campaign. While the TJN is an international NGO (INGO) type network, its origins and many of its key staff are based in the UK, and consequently the analysis is centred on the UK. The UK is a country that has adopted policies of austerity (Sikka, 2015) and has a powerful

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financial sector. In this context − which does not appear to be particularly conducive to political reform − the emergence of CTA as a high profile issue makes the UK a particularly interesting case. The key research question I address in the paper is: how has the TJN contributed to the dramatic emergence of CTA as a high profile political issue? By a political issue I am referring to a topic that generates substantial media coverage and which captures the attention of political leaders. This is a crucial question for further research because it sheds light on how complex accounting issues can acquire broader public recognition and political attention. This examination of how the TJN contributed to the politicisation of CTA is concentrated on 2010–2015, since content analysis indicates that the media profile of the issue increased dramatically over this period (see Appendix A Fig. A1). The particular focus around CTA in campaigning and media coverage has been on a particular form of avoidance, which may be legal but is seen as not in-keeping with the spirit of the law and involves reductions in tax that are not intended by lawmakers (Brock & Russell, 2015: 10–11).1 To address this research question the key contribution of the paper is to introduce the concept of political salience into accounting analysis to understand how the practice of CTA emerged as a high profile political issue. Political salience, derived from Wong’s (2012) analysis of human rights NGOs, is understood as the creation of focal points in political debate and media coverage. Political salience serves as a heuristic to illuminate how some campaigns for accounting reform, in this case the campaign against CTA, become focal points in media and policy debate (see Wong, 2012: 189). The following analysis of the TJN develops political economy accounting approaches, which have made a long-standing critique of the neglect of political antagonisms (see for example Tinker, Neimar & Lehman, 1991; Shenkin & Coulson, 2007; Sikka, 2013; Catchpowle & Smyth, 2016) and civil society (see for example Spence, 2009; Thomson, 2014; Thomson, Dey, & Russell, 2015). The political economy intervention presents an important critique of corporation centred (see Shenkin & Coulson, 2007) accounting analysis but offers little to explain how and why some accounting issues and campaigns acquire more political attention than others. Academic discussions around CTA have tended to focus on questions of reputation and the tensions it may have with the ethical (social responsibility) commitments of businesses (see for example Sikka, 2010; Sikka, 2013; Haseldine & Morris, 2013; Dowling, 2014; Ylönen & Laine, 2015). However, there has been far less academic analysis of the political campaign for reform around corporate taxation, which is addressed here through a case study of one important civil society actor, the TJN The paper is structured as follows: in Section 2, I argue that the existing academic literature on CTA tends to neglect the political campaign surrounding it; to engage with this aspect I draw on the political economy intervention to highlight the role of civil society actors. While this intervention is an important one, political economy approaches offer little to explain how some accounting issues acquire media attention and political profile. To remedy this in section 3, ‘political salience’ (Wong, 2012) is introduced as a conceptual tool to examine the increasing profile of CTA and the role of the TJN in this. In Section 4, the case study methodology is outlined, which is based on content analysis, in depth semi-structured interviews with key actors (Wengraf, 2001), direct observation, and an analysis of relevant reports and publications. Section 5 is the case study analysis of the TJN. This is presented in three subsections to draw out different aspects of how the TJN has been able to generate political salience around the issue: organization structure and actors, communication strategies, and media reception. The findings are then discussed further in section 6, where the broader context around CTA is highlighted, in the final subsection the progress of political demands for accounting reform and the obstacles to these reforms, are considered. In the concluding remarks, section 7, the implications of the case study are drawn out through an identification of the key factors behind the political salience of CTA. 2. CTA: from reputation to political economy The work on CTA in accounting and finance has focused on quantitative measures of the effects of disclosure on reputation (see for example Hanlon & Slemrod, 2009; Gallemore, Maydew, & Thronock, 2013; Dyreng et al., 2014). However, this firm level focus on reputation neglects the crucial issue that is the key focus of analysis here, which is: how has CTA developed into a critical issue for the media and in public debate, and how have civil society actors contributed to this? Critical approaches have developed a different analysis of reputation and tax avoidance, by drawing out a tension between company commitments to social responsibility on the one hand and tax avoidance arrangements on the other (see Christensen & Murphy, 2004; Sikka, 2010, 2013; Ylönen & Laine, 2015). Because of the paucity of available data on CTA (Lisowsky, 2010), critical accounting analysis has tended to focus on specific cases or examples of CTA (see for example Sikka, 2010; Ylönen & Laine, 2015). However, broader issues around political conflict and civil society mobilisation tend to be a secondary issue in the existing critical accounting literature on tax avoidance, due to the firm level focus in the analysis. In regard to ethics, Sikka (2010, 2013) discusses several case studies of CTA and situates this as an instance of ‘organized hypocrisy’. In Sikka’s analysis much evidence of tax avoidance/evasion is provided and this approach renders visible the marked inconsistency between social responsibility commitments on the one hand and tax avoidance arrangements on

1 In terms of what we mean by tax avoidance, it is important to initially distinguish it from tax evasion. Tax evasion is a criminal offence which can be contrasted with tax compliance when a company or individual seeks to comply with the law in all the countries in which they operate, makes full disclosure to relevant authorities, and seeks to pay the right amount of tax (Palan et al., 2010: 9). The grey area between full and active compliance and evasion is tax avoidance. In an oft-quoted line the former Chancellor of the Exchequer, Denis Healey, is reported to have said that the difference between tax avoidance and tax evasion is the ‘thickness of a prison wall’ (Shaxson, 2011).

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the other (see also Ylönen & Laine, 2015). In a response to Sikka’s (2010) paper, Hasseldine and Morris (2013) make an attempt to legitimate tax avoidance by arguing that a clearer distinction needs to be made between tax avoidance (legal tax planning) and tax evasion (fraudulent tax affairs which are illegal). However, this distinction overlooks the crucial point that the line between evasion and avoidance is not definitive – since accountancy firms will often promote schemes by their own admission with only a 50% chance of being successful (PAC, 2013). This alludes to how the boundaries between avoidance and evasion are not fixed in advance in the way that Hasseldine and Morris (2013) appear to suggest but rather are a matter that is legally and politically contested. Furthermore, in urging Sikka to recognize the distinction between evasion and avoidance, Hasseldine and Morris (2013) still leave open the question of what political reforms are necessary and what government policies might effectively reduce CTA. To engage with this aspect, we need to move from an ethical to a political level of analysis, and to focus on the campaign for legislative reform. The political economy approach to accounting is helpful in foregrounding political contestation and civil society mobilisation. The political economy argument is that existing academic accounting work ignores social and political conflict and inequality in favour of an implicitly status quo oriented standpoint (Tinker et al., 1991; see also Cooper & Sherer, 1984; Shenkin & Coulson, 2007; Lee & Cassell, 2008). Following in this tradition, the work of Spence and co-authors (see Spence, 2007; Spence, 2009; Spence, Husillos & Correa-Ruiz, 2010) develops a much-needed focus on politics and civil society in accounting analysis. There is some critical accounting work that starts to take up this project by engaging with civil society from different theoretical perspectives (see for example Shenkin & Coulson, 2007; Brown & Dillard, 2013; Thomson et al., 2015). But the literature does not address the crucial question of how some campaigns for accounting reform become prominent in political debate and capture the attention of policymakers. Indeed, the TJN and the CTA case provides an important example of how in some cases accounting issues can reach broader audiences and become political issues. The TJN’s research agenda has combined the detailed analysis of company accounts with a broader political economy focus on issues of corporate state capture (see for example Sikka, 2008), secrecy (TJN, 2011a; TJN, 2011b; see also Seabrooke & Wigan, 2015a) and the role of offshore finance and tax havens in the global economy (see for example Palan, 2003; Palan, Murphy & Chavagneux, 2010; Sikka & Willmott, 2010; Christensen, Shaxson & Wigan, 2015). Yet a key question remains here which is how has this critical research agenda acquired public impact and traction, particularly given the complexity of the issues involved? (See Appendix B Fig. B1). The concept of political salience provides the theoretical basis to examine how this has occurred. 3. Political salience Political salience refers to the development of focal points in civil society campaigning (which can either be applied to organizations or issues). It serves as an important concept for qualitative research in accounting because it raises the question of how and why some accounting issues acquire substantial public attention and traction (Wong, 2012: 189). This question is a particularly important one since other issues and stories about the financial sector that have attracted media attention and concern post-crisis, such as private equity (Montgomerie, Leaver & Nilsson, 2008) or levels of executive pay (Erturk, Froud, Johal, & Williams, 2013), have rather moved off the media agenda in recent years; in contrast CTA has continued to acquire increasing levels of media attention. The focus on a key civil society actor and its role in contributing to the political salience of the issue is intended to at least begin to answer the question of how this dramatic shift in the profile of CTA has occurred in recent years. In Wong’s (2012) analysis of human rights NGOs she points to organizational structure as central to how issues acquire political salience. She stresses the value of centralised agenda setting and decentralised implementation as the most effective organizational structure for INGOs (Wong, 2012: 193). While Wong establishes the value of political salience as a useful analytical concept in the study of NGOs this gives rise to further issues: first, while NGO structure is likely to be very important in generating political attention, what other factors shape the political salience of campaigning issues? Second, in emphasising the importance of organizational structure Wong tends to downplay the role played by individuals (Wong, 2012: 62). As I suggest in the following case study analysis, this omission is problematic in the CTA case because the technical expertise of particular activists has been a particularly important resource for the TJN. Issues can also serve as focal points and Wong delinks the salience of organizations from the salience of issues (Wong, 2012: 149). While the two are often interconnected – an effective advocacy NGO is likely to help in raising the political salience of an issue they become involved in – clearly some high profile and well established NGOs pick up on issues that do not acquire political salience, and therefore the two can be separated. In the following case study analysis, there is a focus on the influence the TJN has had on the political salience of the issue of CTA. However, it must be recognized that organizations do not operate in isolation and the political salience of issues is generated through multiple actors working across networks. In operationalizing the concept of political salience, one further useful distinction that Hendrix and Wong (2014) make in their analysis of Amnesty International’s approach is between salience politics and information politics. This points to how NGOs as strategic actors make choices about which issues and cases they choose to focus on, and how they communicate with broader audiences (Hendrix & Wong, 2014: 30). As Seabrooke & Wigan (2015b: 890) note, NGOs often have a gatekeeping function in selecting issues they feel are salient. Information politics refers to in depth research papers and background reports, in contrast to press releases and blog posts which are intended for quick dissemination (Hendrix & Wong, 2014: 31) and to reach wider audiences. Advocacy NGOs may focus their attention on information politics by producing work intended principally for specialist audiences, such as policymakers and other campaigners; but they may also be able to target their Please cite this article in press as: Dallyn, S. An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network. Accounting Forum (2016), http://dx.doi.org/10.1016/j.accfor.2016.12.002

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efforts at generating broader political salience, for example by engaging with the mainstream media through television and radio appearances. As we shall see in the case of CTA, in some instances information politics assumes a wider audience and journalists are often central in translating specialist research to broader publics. The focus of organizations can also shift from the production of information politics type documents to campaigning strategies that are intended to generate higher political salience. Indeed, as Hendrix & Wong (2014: 42) note, the two can also feed off one another. This transition from information politics to political salience is arguably a particularly important one for accounting research because accounting issues are often cast as technical rather than political (see for example Hrasky & Jones, 2016). And it is only once an issue acquires some level of political salience that it can assume a place in political debate and acquire the attention of policymakers. In establishing the relevance of political salience for political economy analysis, the question arises of how best to measure the concept. For Wong (2012) political salience is a concept that operates across different dimensions, so as a heuristic it is best assessed through a compound of indicators. The measure of political salience that is adopted depends on both the research question and the need to think about political salience across more than one dimension. The key research question is how has the TJN contributed to the political salience of CTA? And this gives rise to two interconnected but also distinct issues, which corresponds to the separation between issues and organizations in terms of salience: How does one measure the political salience of CTA? And second, how do we evaluate the role of the TJN in increasing the political salience of the issue? Because the research question is focused not simply on the TJN but its relation to the political salience of CTA − this requires an independent measure of the political salience of the issue, which provides data that gives an indication of the relative importance of the TJN. For these reasons the paper employs a longitudinal content analysis of major national newspaper references to give an indication of the political salience of CTA and the TJN and to what degree these correspond. The longitudinal content analysis consists of keyword searches of central terms in the CTA debate and references to the TJN and key actors within it; across different years. While newspaper coverage may not provide an entirely accurate impression of public feeling; high profile topics in the media do tend to feed into political debate and can have a major role in framing issues amongst broader publics (see for example Montgomerieet al., 2008; Happer & Philo, 2013). The focus on newspaper coverage has an added advantage in terms of the research question then because it provides a strong indication of how the political salience of the organization corresponds to the political salience of the issue. That is, it will show us to what extent the national newspaper media was engaging with CTA as an issue before, during or after the TJN campaigned around it.2 However, because the political salience of issues operates across more than one dimension, alongside references in the national press further indicators will be factored into the analysis including critical attention that the issue has received in the UK parliament (Section 5.2), the political salience of key policy proposals developed by the TJN (Section 5.3), and efforts to reform international corporate taxation at least partly instigated by the TJN (Section 6.2). 4. Methodology The approach adopted here is principally a qualitative case study based one, because political salience is employed as a heuristic to describe how the TJN has worked to raise the political salience of CTA (Scapens, 2004; Yin, 2009). In addition to this, critical research on tax avoidance has often employed a case study and/or qualitative methodology (see for example Hasseldine, Holland, & van der Rijt, 2011; Gracia & Oats, 2012; Tuck, 2013; Ylönen & Laine, 2015). The case study approach clearly gives rise to the question of case selection since one limitation of this type of empirical investigation is that it does not offer any straightforwardly generalizable findings. Having said this, the case of the TJN has been selected because the NGO has been described as being central to the campaign (Saint-Amans, 2014; Piketty, 2015; Seabrooke & Wigan, 2015a). The TJN is also an ‘information rich’ case (Flyvbjerg, 2001; Scapens, 2004) because it has made distinctive strategic and organizational choices about how to engage with tax avoidance as an issue. Furthermore, the case has an added practical value because the TJN has close links with, and key members who are, accountants in academia. It thus presents an important example that might inform others who are seeking to popularise alternative perspectives about accounting practice. The qualitative case study approach clearly has a variety of strengths and weaknesses, but it has been chosen principally in order to provide some thick description of the strategic choices made by the TJN and how they contributed to the political emergence of the issue. This is firstly because these how and why type questions tend to require a deeper and more in depth understanding of the underlying reasons behind particular organizational choices, something which the case study method is best equipped to provide (Yin, 2009: 9). Second, and connected to this, the case study approach offers possibilities for engaging with the self-understandings of key actors in terms of their reasoning behind given campaign choices. Thirdly, because the research design is intended to be principally exploratory in raising an important and neglected question in accounting analysis: how do some accounting issues acquire political salience? This is a research angle that is best addressed

2 It is worth emphasising that newspaper references to CTA do not provide a complete picture of its political salience. Many articles may refer to the issues around CTA but refer to it in different ways, such as by using the term ‘tax dodging’ or ‘tax cheating’ depending on the article. However, it does provide a clear longitudinal impression of the differing levels of attention that the TJN and the issue received in different years in the UK media, which is a key point of comparison for the empirical analysis.

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on a case-by-case basis since a broad variety of different factors are likely to affect this, so a thick description is required to generate a fuller picture of the role of key actors, while also being sensitive to the larger context. These advantages of the case study approach are important for the research question, since the case study will provide us with a sense of how the TJN worked to raise the political salience of CTA and why particular strategies were chosen to achieve this. Despite these strengths it is also important to recognize the limitations of case study research, firstly the specificity of focus can mean that broader factors or parallel processes do not receive due attention. In the case of CTA even if the TJN has been at the centre of the civil society campaign there have been a range of other actors and processes that have been extremely important, so the danger is that too exclusive a focus on a specific case can neglect the role of other important factors. Secondly, case studies are also often critiqued for possessing low external validity (Yin, 2009: 43), essentially the problem that it is difficult to make any strong generalisations from a single case (Thomson et al., 2015: 824). One final weakness that arises from the case study research design is that it is often difficult to independently verify, that is, it can be too focused on the self-understandings of key actors and thus the findings can lack reliability (Ferguson, 2007; Yin, 2009: 45). In order to compensate as far as possible for some of the weaknesses of the case study approach in terms of low external validity and the problem of generating self-validating data, the empirical investigation was triangulated in the following ways: First, a range of content analyses were undertaken employing Factiva to identify references to central issues around CTA and their emergence in newspaper media, and the time correspondence between this and the TJN’s engagement with the issue. This content analysis was based around a longitudinal Factiva keyword search of the UK national newspaper media, which examined the frequency of references to key concepts across different years − including CTA, tax havens, and country-by-country reporting (CBCR) (an important TJN policy proposal), and references to the TJN and its founders (see Appendix). This served to provide at least some independent measure of the TJN’s media impact. Second, key actors associated with the TJN were identified, as well as Members of Parliament (MPs) – UK politicians – who have helped to raise the profile of CTA. Potential interview respondents were contacted on the basis of being founders of the TJN in 2003 or full time staff, and those with important professional roles within the organization. 19 individuals were contacted via email to request an interview, of which 10 agreed to participate (see Appendix C).3 While it must be acknowledged that this is a limited sample, many of the individuals who have been central to either the founding of, or the main operations of the TJN agreed to take part. Thus a key aspect of the methodology was elite interviews – that is, it was focused around interviewing actors who have been central to the issue under investigation in terms of role and/or expertise (Harvey, 2011). And consequently the sample is of a relatively small size. The interview sample included two of the founders of the TJN, a current Senior Advisor of the TJN, and three full-time staff. Each of these interviews was transcribed and analysed, key themes were then identified around the generation of political salience. MPs were also contacted who had been members of the Public Accounts Committee (PAC) between 2010 and 2015 and who had been critical of aspects of CTA during relevant committee hearings. The PAC is a high profile parliamentary committee that has produced a wide range of critical reports about CTA. Interviewing 3 MPs as well as TJN members provided a further assessment from outside the organization of how the political salience of CTA was generated. Third, reports and publications of the TJN were selected on the basis of media content analyses citations. These were then examined in depth to identify the central themes and critiques made in these different documents. Fourth, important newspaper articles that were referred to during the interviews were examined to explore how the issue was framed in these articles. Fifth, some supplementary direct observation was undertaken through attendance at two TJN annual research conferences, in which a wide range of discussions and papers were observed. Sixth, recent parliamentary reports, speeches and hearings about CTA were examined to provide a further indication of the political salience of the issue. The analysis of the TJN and its role in generating political salience around CTA will proceed in three steps, which were found to be key aspects of the generation of political salience. The three information questions that are intended to answer the research question (see Wengraf, 2001) correspond to the different sections as follows: First, how has the structure of the TJN affected the political salience of CTA? (Section 5.1). Here I examine the organizational structure of the TJN, but also consider the role of the main individuals involved. The second information question is what communication strategies has the NGO adopted to raise the political salience of the issue? (Section 5.2). To examine this I draw on Hendrix and Wong’s (2014) distinction between information politics and political salience to address the different communication strategies of the TJN at different times. Third, how does the political salience of the TJN correspond to the political salience of the issue in the UK media? (Section 5.3). To address this question a content analysis was undertaken of UK newspaper references to CTA, to the TJN, and to their main policy proposals.

3 Some participants consented to being recorded but asked not to be identified by name or for certain parts of the interview to be omitted from any subsequent research, these expressed wishes have been followed in the analysis presented.

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5. Case analysis of the TJN 5.1. Organization structure and actors While there was some significant critical research on tax avoidance prior to the creation of the TJN in 2003 (see for example Picciotto, 1992; Palan, 1998; Oxfam, 2000), it has subsequently served as a central hub in knowledge based research and ‘tax justice’ campaigning across the NGO sector (Seabrooke & Wigan, 2015a). After an initial meeting in Jersey in 2002, a broader delegation on ‘tax justice’ was formed for the European Social Forum in Florence, and following this the TJN was officially launched at the House of Commons in March 2003 (see TJN, 2003, 2013). The TJN has taken an explicit expertise led approach based around knowledge production and dissemination combined with a set of clear political demands for reform.4 The distinctive expertise and professional standing of the small group of founding members has been important to how alternative critical discourses around tax avoidance have acquired broader political salience. The founding members can be situated as ‘insider rebels’ (Meinzer interview, 2015) in that they each had insider knowledge of the tax avoidance industry that they were turning against, which in turn gave credibility to the alternative narrative around taxation they were developing. In terms of the founding members: Richard Murphy previously trained with KPMG and had worked for and run different businesses; Prem Sikka was – and currently is – a professor of accounting at the University of Essex with a background in industry; and the Director John Christensen had been an economic advisor to the Jersey government, and later worked at Oxfam. In pointing to organizational structure as the key determinant of whether NGOs can acquire political salience for their causes Wong (2012) downplays the role of individuals in NGOs. She cautions against too much focus on individuals on the grounds that this is ‘putting the proverbial cart before the horse’ (Wong, 2012: 62) because many NGOs have talented individuals working for them but not all are able to generate political salience. However, in the case of CTA individuals seem to have been more central and this is because issues around corporate taxation are complex, both in regard to legislation and company accounts. Thus it requires technical expertise to generate an effective counter narrative, and ideally expertise in different fields − such as tax law, political economy and accountancy. This expertise tends to be possessed by only a handful of individuals, which has made their role as critics particularly important. Second, and connected to this, the role of the Senior Advisors who provide a circle of expertise around the core staff are a central component of the TJN’s distinctive organizational structure (Christensen interview, 2015). The Senior Advisors have a professional standing as individuals – and often researchers –, which is distinct from the organizational brand (TJN, 2015a). This is different from established INGOs like Oxfam or Christian Aid where the brand is often emphasized more than the individual authors. The current Senior Advisors of the TJN have a broad range of expertise based on independent professional standing. The advisers include barristers, lawyers, professors with established reputations, investigative reporters, accountants, and consultants for important international policy forums, including United Nations bodies such as the UN Financing for Development roundtable meetings (see TJN, 2015a). Thus while the organizational structure of the TJN is important and it has been significant to the ways in which it has worked to generate the political salience of CTA, the role of certain affiliated individuals has been at least as important. In Wong’s work (see Wong, 2012; Stroup & Wong, 2013) the organizational structure of NGOs is central to the successful generation of political salience – and she points to a combination of centralised coordination and decision-making and decentralised implementation as the most effective route to this; but the TJN’s organizational model differs from this in some important respects. The first difference is around the TJN’s focus on research expertise, which one interview respondent described as ‘semi-academic’ in producing high level advocacy work for other civil society organizations and in proposing international taxation reforms. Developing a research community requires the generation of ideas and must allow for differences of opinion. Centrally coordinating research would arguably limit its proliferation and thus the network needs to be flexible in this regard (Christensen interview, 2015). As a result the core research network has a more decentralised structure than one might expect to find in a traditional advocacy INGO. A second important difference is in terms of funding. The campaigns of larger NGOs are inevitably partly shaped by the interests of their membership and particular funders interests (Hendrix & Wong, 2014). Much of TJN’s funding comes from grants from other INGOs in related fields, such as Christian Aid and the Financial Transparency coalition (TJN, 2014). The TJN’s funding is far smaller scale than in comparison to other NGOs that campaign on the issue, like Oxfam or Christian Aid (Seabrooke & Wigan, 2015c). The small number of paid staff (around 12 at present) provides greater flexibility because it means they can respond rapidly to politically salient stories around CTA (Shaxson interview, 2015). This distinctive operational flexibility, combined with the expertise of core members, has meant that the TJN has been in a position to quickly disseminate critical comment on emerging media stories around tax avoidance (see Appendix B Fig. B1). This is quite different from other advocacy NGOs, where press releases and policy responses often require extensive internal debate and

4 It is important to emphasise that the campaign against CTA is extremely wide ranging encompassing issues around gender (Christian Aid, 2014), human rights (International Bar Association, 2013), poverty (Mosselmans, 2014), international tax law (Picciotto, 2012), money laundering (JustWorld, 2002), and others. However, the focus in the case analysis here is on one NGO type network that has been at the centre of the campaign.

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ratification. Thus in order to remain relevant to a complex and fast moving issue, the TJN has been consciously designed to enable the quick dissemination of counter narratives and responses. The network has a core research focus which was emphasised during the interviews, but as tax avoidance has expanded into a major international issue this has, in line with Wong’s (2012) analysis, led to an increasing differentiation between the research and campaigning wings of the organization (Meinzer interview, 2015). Campaigning for international taxation reform at the EU or the OECD requires a more centralised campaigning wing. The Global Alliance for Tax Justice (GATJ) was created in 2013 to address this – an umbrella organization composed of over a hundred different NGOs and campaigning groups. One further aspect of the political salience of CTA has been the role of investigative reporting and the national press. A key aim expressed in the TJN’s 2014 Directors’ Report is to widen the global discussion around tax justice (TJN, 2014: 2) and here the media plays a key role. The illicit finance journalism programme created in 2010 is intended to strengthen the growth of investigative reporting around taxation − particularly in developing countries – through a 4-day course each year (TJN, 2015b). With time the organization has developed a tripartite structure: the core research network based around knowledge production and expertise, the Global Alliance for Tax Justice to coordinate campaigning, and the illicit finance journalism programme which aims to build international investigative reporting around taxation. Thus organizationally the TJN has evolved to respond to the different media and policy climate around taxation in order to work effectively in the contemporary climate where CTA issues are high profile. The TJN model also suggests that research led advocacy is more likely to generate political salience if it is organized in a different way from other kinds of advocacy INGO, through greater decentralisation of research, combined with a small set of operational staff that are able to respond quickly to emerging news stories.

5.2. Communication strategies One further aspect of political salience is how organizations communicate with different audiences, and which audiences they target with different kinds of communication. As a research led organization, the TJN has been focused around information politics – which includes background reports and detailed research papers (see Henry, 2012; Picciotto, 2012 for two important examples). As Hendrix & Wong (2014: 31) note, different forms of advocacy have different primary audiences, and while background reports are intended principally for policymakers and issue specialists – such as advocacy NGOs and academics (see for example TJN, 2005a; TJN, 2011a) – these documents can often be accessed by anyone. If we look at the early output of the TJN it is more focused on this kind of information politics work, including detailed briefings on proposed EU legislation (TJN, 2005a; TJN, 2011b) and the development of alternative policy proposals, like CBCR (TJN, 2008). CBCR if made into a legal requirement would be based on companies making public the following: the countries in which they operate; what the companies name is in that location; its financial performance in each country including third party and intra-group trade; labour information; and how much tax it pays to government locally (Murphy, 2003, 2004, 2009, 2011). The earlier work of the TJN then seems to be targeted more at specialist audiences such as policymakers, academics, and NGOs. However, as tax avoidance became a higher profile and politically salient issue, the TJN expanded into social media. Through regular blog posts that respond to current events, monthly podcasts and ‘The Offshore Wrapper’ launched in 2014, which provides commentary on international news stories online. These instances of social media information dissemination are intended to connect to broader publics online with an interest in issues concerning international taxation. Thus the TJN has expanded its output to build directly on the political salience of CTA and its heightened media attention. While the TJN is research led and does little direct lobbying (Christensen interview, 2015; Murphy interview, 2015) the development of formal and informal networks has been important to establishing it as a focal point. For information politics – of which critical academic research is one type – to generate broader political salience it requires fostering different networks to reach wider audiences. Here Wong (2012: 72) distinguishes between informal links and formal relationships, the latter are codified and subject to formal consent – the GATJ would constitute a clear example of a formal campaigning NGO network for international taxation reform. But arguably as important, if not more so, is spreading political salience through informal links, which are not written down and come about through day-to-day operations (Wong, 2012: 17). Here the TJN has undertaken a wide range of informal networking with other NGOs and policymakers. Furthermore, John Christensen, the Director, and Alex Cobham, the current Research Director, had both worked for campaigning INGOs that have an interest in taxation and development issues; Christensen for Oxfam and Cobham for Save the Children and Christian Aid, amongst others. These links with other INGOs established partly through the professional backgrounds of key members strengthens the basis for collaboration around tax campaigning across the NGO sector through informal networks. Finding supportive MPs and legislators has also been crucial to the TJN generating political salience for CTA and this is the case both in the UK and at a European Union level. Briefings and seminars have been important in disseminating information and building formal and informal links. Although many factors contributed to this, in July 2015 the European Parliament voted strongly in favour of public access CBCR (European Parliament, 2015a). A month previously in June a seminar on public access CBCR was organized for Socialist and Social Democratic European parties, where Prem Sikka was on the panel (Socialists and Democrats in the European Parliament, 2015). Indeed two of the founders of the TJN, Sikka and Murphy, are referred to in the recorded meetings and delegations that led to the development of the resolution (see European Parliament, 2015b). So networking with European legislators has served to increase the political salience of CBCR. Please cite this article in press as: Dallyn, S. An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network. Accounting Forum (2016), http://dx.doi.org/10.1016/j.accfor.2016.12.002

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In the UK context one significant link with MPs that has been established both formally and informally, is through the Public Accounts Committee (PAC), which became a high profile critic of CTA during the 2010–2015 parliament. The Chair during the 2010-15 parliament, Margaret Hodge, and other members of the committee consistently drew attention to corporate media ‘scandals’ around tax avoidance (see for example PAC, 2014). One important MP in the PAC’s engagement with CTA was Austin Mitchell, the former Labour MP for Grimsby. Mitchell had previously written a number of papers, with Sikka (; see for example Mitchell & Sikka, 1993; Mitchell, Sikka & Willmott, 1998; Mitchell, Sikka & Willmott, 2001) one of the founders of the TJN – and later through the Association of Accountancy and Business Affairs (AABA). The AABA was created in 2002 and seeks to generate public debate and critical scrutiny of accountancy practices. It has always been closely allied to the TJN in terms of its public interest research focus and membership. Sikka is the Director of the AABA and amongst its Trustees are several other academics with critical accounting backgrounds (AABA, 2015). Mitchell also co-authored a paper on tax havens with two of the founders of the TJN published through the AABA (see Mitchell, Sikka, Christensen, Morris & Filling, 2002) and later wrote a paper on the role of the big four accountancy firms in facilitating avoidance and evasion with Sikka (Mitchell & Sikka, 2011). Once again this points to the important role of individuals in fostering links and networks to generate political salience. While it is open to debate how much direct influence his work has had on the approach later taken by the Committee during its hearings, Mitchell, amongst other MPs on the committee, was a vocal critic of accountancy firms (see PAC, 2013; PAC 2015). A number of key issues and examples are referred to in both the Mitchell & Sikka (2011) paper and the PAC hearing in 2013 involving accountancy firms, such as: Deutche Bank and Goldman Sachs use of the Cayman Islands to avoid national insurance contributions (PAC, 2013: Bacon, Q67; Mitchell & Sikka, 2011: 43); the shifting of VAT registration numbers to lower tax jurisdictions (see for example PAC, 2013: Swales, Q121; Mitchell & Sikka, 2011: 16–17); and the conflict of interest around accountancy firms helping to devise tax avoidance schemes and then providing auditing services to the same companies (PAC, 2013: Mitchell, Q41; Mitchell & Sikka, 2011: 58). Thus one can see strong parallels between the two documents, which suggests that Mitchell & Sikka’s work had some role in shaping the tone of the PAC hearings involving accountancy firms, and that this contributed to the political attention CTA received in PAC reports and hearings during the 2010–2015 UK parliament. 5.3. Media reception Fig. A1 in Appendix A illustrates that CTA received minimal attention in national newspapers until after the financial crisis in 2009, but coverage of the issue increased markedly from 2012 to 2013 from 85 direct references to CTA to 249. This indicates that 2013 was something of a breakthrough year in the attention paid to CTA in the national press. While the TJN – and its main founders – received their highest number of citations in 2015 (Fig. B1 in Appendix B), the content analysis illustrates that the network has been campaigning around tax avoidance issues for much longer, while receiving substantially less media attention at least until after the financial crisis in 2007. In the majority of these articles the TJN, and often TJN members, are quoted to provide comment on tax avoidance news stories in a way that positions them as a source of critical expertise (for some important examples of this see Drucker, 2010; Bergin, 2012; Griffiths, 2012). While the content analysis indicates that the TJN and the issue of CTA received a high number of newspaper references in corresponding years, particularly 2013 and 2015 (see Figs. A1 and B1 in Appendix A and B), this does not ultimately prove that the TJN was responsible for the increasing media profile of CTA. As Wong (2012) notes, many forces affect the political salience of issues, although NGOs can be central to this. But it does highlight that the TJN and its founders became something of a go to source due to their expertise when CTA was becoming a politically salient issue. A shift in the media’s issue focus is also evident from the content analyses. Tax havens emerged as a politically salient topic in the media soon after the crisis in 2009 (Fig. A2 in Appendix A). And the analysis of tax havens was a key research area in the information politics approach of the TJN in its early years (see for example Hampton & Christensen, 2002; Hampton & Sikka, 2005). This highlights the importance of timing and context in regard to the generation of political salience, the global financial crisis offered opportunities for the TJN to raise the profile of tax avoidance issues, initially by focusing on tax havens. But CTA emerged as an object of media attention somewhat later, particularly 2013 onwards (Fig. A1 in Appendix A) through scandal based news stories, centred on recognized brands, such as Google and Starbucks amongst others. CTA also became prescient as a campaigning issue in the broader context of austerity and constraints on fiscal resources during the 2010–2015 parliament. NGOs as strategic actors make ‘difficult choices regarding the issues and cases to which they can devote limited resources’ (Hendrix & Wong, 2014: 30). Some interview respondents suggested that CTA was targeted by the TJN specifically because of the political salience it could generate – in terms of both media attention and policy debate. Even though a higher proportion of taxation is lost through tax evasion, CTA was more likely to generate headlines, particularly in the context of austerity. As Murphy (interview, 2015) describes it, ‘If we now look at the US tax scam, which I think is still around £120 billion a year. Multinational tax avoidance? £5 or £6 billion. Total offshore impact? £5 billion? 10% of the total tax scam is what we’ve focused on’ (Murphy interview, 2015). The content analysis of references to the TJN and its founders probably significantly underestimates the network’s indirect influence on the wider debate around tax avoidance. This is because it does not operate quite in the manner of a typical Please cite this article in press as: Dallyn, S. An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network. Accounting Forum (2016), http://dx.doi.org/10.1016/j.accfor.2016.12.002

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advocacy INGO, in that it is perhaps not as concerned with getting its name associated with different causes to the degree a more traditional professionalised INGO might be. Individual subscription funding tends to be more important to professional advocacy INGOs that have a widely recognized name and brand. The TJN’s focus has been more on developing alternative narratives and policy proposals, working as a kind of research hub of like-minded actors. As the current Research Director explained, ‘TJN hasn’t always been very good or very interested in claiming the credit. . . there isn’t this imperative to label them (campaign issues) ours’ (Cobham interview, 2015). TJN members often suggested they were more interested in helping to create wider political salience around tax avoidance, and in developing policy proposals around taxation that are taken seriously. The Factiva content analysis of references to the TJN and its founders provides some useful indications of the profile of the TJN but tells us less about the concrete impact of the TJN’s activities. To consider influence we can also focus on a specific issue and think about how particular policy ideas that members have worked on have acquired traction and wider circulation. One policy proposal that has been a key demand of the TJN since its inception in 2003 is public access CBCR (see Murphy, 2003; Seabrooke & Wigan, 2015a). As Fig. B2 in Appendix B illustrates – and here international media is included in the Factiva search because CBCR has been debated by international organizations – the political salience of CBCR in policy debate goes far beyond the reach of the TJN. CBCR has now become a proposal that is being adopted in some form, planned, or at least discussed, in a variety of important national and international forums. The increasing political salience of CBCR then, particularly during 2015, highlights how the TJN has raised the salience of corporate taxation issues by advancing proposals for reform which at their most effective pick up broader momentum beyond the organization. 6. Discussion and analysis The claim advanced here is that political salience serves as a useful heuristic tool for accounting analysis because it helps to shed light on when, and how, complex accounting issues can acquire a high political profile, and the role of civil society actors in this. While existing political economy accounting analyses have broadened the analytical focus to address the wider social and political context (see for example Lee & Cassell, 2008; Catchpowle & Smythe, 2016). Political salience is intended to address a crucial but neglected follow up issue, which is: why do some accounting issues acquire high levels of media attention and generate policy debate? Because CTA can be situated as a widespread practice within financial globalisation (Palan et al., 2010; Sikka & Willmott, 2010; Action Aid, 2011), the political salience it has acquired in recent years and the role of the TJN in contributing to this gives rise to some important points for discussion and reflection, which I will address in turn: First, why did CTA emerge in the media at a particular point in time and what was the TJN’s connection to this? And second, what has the generation of political salience around CTA led to in terms of accounting reform, and what are the barriers to this occurring? 6.1. The co-construction of political salience While the analysis has been focused around a case study of one civil society network, it must be noted that the political salience of CTA has been co-constructed by multiple actors and the development of networks across different fields. In the case of CTA this has included NGOs, politicians, journalists, and grassroots demonstrations. When assessing the impact of the TJN, Wong’s (2012) distinction between the political salience of issues and organizations is crucial. The TJN was created in 2003 and thus it predates the emergence of CTA as a high profile political issue, so a range of other factors worked in conjunction with the TJN in generating the political salience of CTA. TJN researchers and campaigners were examining the role of tax avoidance and financial secrecy within the global economy prior to the mainstream media’s engagement with the topic (see for example TJN, 2005b), particularly through their focus on tax havens.5 The emergence of CTA in the national media at a particular point in time highlights the centrality of the broader social and political context in helping to establish the political salience of the issue. While the global financial crisis brought to the fore questions about the financial system and problems around tax havens in the global economy. The content analysis points to a spike in national media coverage of tax havens in 2009 (Fig. A2 in Appendix A) and a significant increase in references to the TJN in the same year (Fig. B1 in Appendix B). But it is the broader political context of austerity in the UK, particularly from 2010 onwards, and constraints on fiscal expenditure that created a supportive issue environment for the political salience of CTA. One part of this change in political context, which enabled the TJN to capitalise on and work with investigative reporters was generated by UK Uncut – a decentralised activist collective that have demonstrated outside different high street shops in the UK that have undertaken tax avoidance, including Vodafone and Starbucks. These protests began with Vodafone in 2010. As Murphy (interview, 2015) noted, the Google story actually attracted little public attention when it was first covered in 2009 but when covered again in 2010 by Bloomberg the story acquired unprecedented political salience, which has had a significant role in framing debates around CTA in subsequent years. This difference between 2009 and 2010 points to a significant shift in the broader socio-political context, which provided a supportive issue environment

5 Also reflecting this focus on tax havens, at least in the early years of the campaign, the first item to appear on the AABA website was a leak of the Edwards Report – a critical government report on financial regulation in the Crown Dependencies (Jersey, Guernsey and the Isle of Man). The report was commissioned in 1998 and published in 2003, a few weeks after the leak through the AABA.

Please cite this article in press as: Dallyn, S. An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network. Accounting Forum (2016), http://dx.doi.org/10.1016/j.accfor.2016.12.002

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for the political salience of CTA. The policy climate of austerity became central to UK political discourse around 2010, which helped to generate a political environment in which stories of CTA could gain traction, in part due to the disparity between the taxes paid by citizens and large corporations (MP interviews, 2015). The TJN and its founders receive their highest number of newspaper references in 2015 and this is also the year in which CTA receives its second highest number of newspaper citations (Figs. A1 and B1 in Appendix A and B). This suggests that CTA was co-constructed as a politically salient issue with investigative journalists, and both actors built off one another – with particular journalists providing stories of corporate scandal, which TJN members were then in a position to provide expert critical commentary on. Here the TJN and the political salience of CTA resonate strongly with Hendrix and Wong’s (2014) finding that ‘media coverage and background reporting are jointly determined’; information politics can drive media attention and vice versa. The newspaper media’s engagement with CTA also shows the importance of corporate scandal in establishing political salience. Developing a narrative frame around scandal centred on particular brands has certainly helped to increase the political salience of the issue, like Amazon and Starbucks (see Griffiths, 2012; Bergin, 2015). And while investigative reporters have had a central role in framing this as a public issue, the TJN has often been a go to source in providing a swift critical response to the counter moves of multinationals. The stories of corporate scandal around recognized brands like Apple and Google has been central to establishing political salience even if this is not where the largest proportion of tax is lost (Murphy interview, 2015); this points to how accounting issues are far more likely to make a transition from the technical to the political if they tap into popular media frames (Neu, Cooper, & Everett, 2001). One further aspect of the TJN’s approach that has been important to the emergence of CTA as a political issue is the development of clear proposals for reform that are supported by appropriate expertise. Stories of scandal and the resulting political anger need to be channelled into concrete reform proposals to have impact (Murphy interview, 2015). To gain traction proposals for reform need to acquire political salience independently of the organization, and this occurs as they become more widely discussed by policymakers who are attempting to respond to high profile media stories. 6.2. Prospects for reform Concrete legislative reforms provide a further and perhaps more direct indication of political salience – since it is relatively easy to establish whether particular reforms have been enacted. As Wong (2012: 31) notes ‘it provides an indication of the issues states choose to formalize because of their importance’. However, two caveats are in order here: First, international taxation reform is an extremely long and complex process, and there can be a long delay between a policy proposal being discussed in international forums and this leading to concrete policy outcomes. Second, one must also recognize that the barriers to reform are more substantial for some campaigning issues than others. Too reductive a focus on assessing political salience through international reform neglects the differing barriers and challenges particular campaigns face, which is why it serves here as a secondary indicator. In the case of CTA these barriers are resource based as well as ideological. Ideological in the sense that CTA reflects certain pervasive aspects of neoliberalism around tax competition and a perceived ‘need’ to cut public expenditure (see Sikka, 2008, 2015). The political environment in which neoliberalism is entrenched in policymaking presents major obstacles to concrete reform, even if the campaign has been successful in changing the terms of the debate. It is also a key reason why a number of campaigners that were interviewed were somewhat sceptical about how much had actually been achieved in terms of reform despite a range of announcements that UK political leaders have made about tackling CTA. The point concerning ideology connects to one important area of reform in regard to national policy, which is increasing the resources of HMRC. In terms of how much money the revenue recoups for each pound spent the figures are striking – the law firm Pinsent Masons suggests that the Large Business Service responsible for pursuing corporate tax cases generates £97 for each £1 spent (Bullock, 2015). While these figures may be questionable, even a two-to-one return on investment would demonstrate a positive case for more funding (MP interview, 2015). While the HMRC – the non-ministerial UK department responsible for tax collection – has been subject to considerable criticism for having too close a relationship with multinationals (see for example PAC, 2015) one potential way of better monitoring the organization would be to have an independent office for tax responsibility to oversee its work, as Richard Murphy (2014) proposes and which a number of MPs have endorsed. National Audit Office (NAO) figures highlight that only 10% of cases pursued by HMRC address sums over £1 million, while 68% of cases pursued are small scale and account for 0.95% of total revenue (NAO, 2015: 35). This provides significant evidence that HMRC concentrates less on large-scale tax evaders and avoiders (such as corporations) and tends to focus on cases where less revenue is at stake. Cuts to HMRC’s budget clearly do not help the organization to pursue potential corporate tax evasion cases (Lavery, 2013), which requires considerable resources and expertise. The Director of the TJN argued that it was difficult to understand the case for not investing more in HMRC given these returns − and that the lack of funding is likely to be the product of an embedded neoliberal perspective in policymaking. In terms of the agenda for reforming HMRC, the Labour Party commissioned a review that has since been published and which was cited by the current Shadow Chancellor, John McDonell, in his 2016 Labour party conference speech in September (McDonnell, 2016). The investigative team for the report included Prem Sikka and John Christensen (both founders of the TJN) and a range of academics with critical accounting or critical business studies backgrounds. Four of the investigative team are also trustees of the AABA (which as noted is closely aligned with the campaigning and research agenda of the TJN) – Prof. Please cite this article in press as: Dallyn, S. An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network. Accounting Forum (2016), http://dx.doi.org/10.1016/j.accfor.2016.12.002

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Prem Sikka (Essex University), Prof. Christine Cooper (Strathclyde University), Prof. Colin Haslam (Queen Mary, University of London), and Prof. Hugh Willmott (City University). While the report was not produced by the TJN − which states explicitly in the statement on its homepage that it is not aligned to any political party (TJN, 2016). The report does advance many of the proposals for reforming HMRC that have been made by members of the TJN including increasing resources for an organization that has continually had its funding and staff numbers cut in the last 10 years (Sikka et al., 2016: 13), and giving HMRC complete independence from business interests (Sikka et al., 2016: 35) to ensure that it is not compromised in its efforts to legally challenge cases of large scale corporate tax evasion. Similar to Murphy’s (2014) proposal for an independent office for tax responsibility, the review suggests that HMRC should have an independent Supervisory Board to watch over its practices and increase public accountability (Sikka et al., 2016: 29). While this document is intended to feed into Labour Party policy formation it will be interesting to see to what extent these proposals are taken up by the Labour Party and how this filters through into wider political debate. If these proposals later become manifesto commitments, this will be another significant example of working with sympathetic politicians to give the tax justice agenda broader political salience. From its inception a clear intention of the TJN has been to push for international reform of the tax system in order to deal with the growing misalignment between the location of economic activity and the declared tax on profits of multinationals (Cobham interview, 2015; see also Cobham & Loretz, 2014). In regard to the key multinational authority now tasked with developing a framework to combat CTA by the G8 and the G20, the OECD base erosion and profit shifting (BEPS) initiative has been working on a range of action points to reform the international tax system (see for example OECD, 2011, 2012). Christensen (interview, 2015) noted that a large number of well funded corporate lobbyists have been active in trying to shape the proposals behind the scenes, while the TJN’s BEPS monitoring team has no independent funding. Ideological and resource based barriers then present significant obstacles to political campaigns for accounting reform. TJN members also expressed major concerns that the BEPS process has not adequately considered the interests of developing countries (see also Global Alliance for Tax Justice, 2013; Quantrill, Haslam, & Picciotto, 2014). Through research and advocacy the TJN has often stressed that a key problem in the international taxation system is the established arms ‘length principle’ in which the different components of a multinational are essentially treated as separate entities in different national jurisdictions − rather than unitary transnational entities, which of course they are in practice (see Picciotto, 2007, 2012; Ylönen & Teivainen, 2015). Thus members of the TJN stressed the case for a system of unitary taxation and formulary apportionment according to the ‘full range of actual business operations in each jurisdiction’ (Corporate Reform Collective, 2014: 113; see also Picciotto, 2012; Sikka & Murphy, 2015). However, this has been taken off the agenda of the OECD partly due to pressure from the US and a perception that it would be too ‘politically complicated’ (Christensen interview, 2015), which again points to the difficulty of achieving political salience in terms of concrete reform around long-term policy proposals. However, public access CBCR is acquiring increasing political salience, and it has been debated at both the OECD and the EU (see Fig. B2 in Appendix B). While the OECD has not proposed public CBCR, it has developed a confidential CBCR template to be submitted to tax administrations (see OECD, 2015). Momentum for public CBCR is developing at a European level, the European Parliament voted overwhelmingly in favour of public CBCR in July 2015 (European Parliament, 2015a). The European Commission has since adopted a modified version of these proposals,6 and national governments are working on adopting the OECD’s CBCR template. In a significant further development an amendment to the UK’s Finance Bill proposed by opposition MPs was accepted in September 2016, which states that ‘the Treasury may by regulations require the group tax strategy to include a country-bycountry report’ (Hansard, 2016). Although the wording is ambiguous − note that the treasury may require rather than must require, and the precise form this legislation will take and when it will be implemented has not yet been fixed7 – this does move the UK further in the direction of public CBCR, since companies are required to publish group tax strategies and the Treasury can make it a requirement that the OECD version of CBCR is also made public. So in this instance public CBCR has made further significant progress at a national level, which indicates that public CBCR could actually be nationally adopted by states acting independently, as some interview respondents argued (for example Cobham interview, 2015). Furthermore, at a European level, the proposal for a European Common Consolidated Tax Base was developed in 2011, which presents a framework to develop unitary taxation at a regional level. While this has stalled politically (Cobham interview, 2015), the European Commission opened a consultation on its re-launch in 2015 and there are plans to present a new proposal in 2016 (European Commission, 2015) and this process could significantly raise the political salience of unitary taxation as a framework for international taxation reform. Examining the progress of international tax reform provides another useful measure of the political salience of the TJN in terms of its political demands. Here the picture is complex and the barriers to substantial reform are considerable, however major reform is at least being discussed in key international policymaking bodies and some significant progress has been made. The case for public CBCR is likely to strengthen, particularly given the support for the idea amongst MEPs reflected in the European Parliament 2015 vote. Thus establishing the political salience of different demands has been approached by the TJN strategically, public access CBCR has acquired increased traction in the context of high profile cor-

6 In April 2016 the European Commission proposed a version of public CBCR although limited to companies with revenue over D 750 million and only including the public disclosure of multinational subsidiaries within Europe (and not presently subsidiaries outside) (European Commission, 2016). While there are limitations to this version of public CBCR it does clearly illustrate that the proposal is making significant progress at an EU level. 7 I thank reviewer 1 for raising this point.

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porate scandals around tax avoidance. While the political salience of unitary taxation is some way further off, achieving full public access CBCR was seen by some TJN members as the key interim step to further the political salience of the unitary taxation proposal, because public CBCR would highlight cases of misalignment between corporate economic activity and profits.

7. Concluding remarks This paper has focused on an important contemporary politicisation of corporate accounting practice, one that has acquired an unprecedented degree of media attention and generated political debate across many developed economies. While the case study analysis presented has focused on one civil society network, and the political salience of CTA has involved a multitude of actors in different fields; the TJN is a particularly interesting case for academics working in finance and accountancy because many of the key members of the network are academics and researchers. Political salience has been introduced as the key theoretical contribution, since it serves as a heuristic device with which to explore how and why some accounting issues become public issues that generate media attention, which is arguably a neglected topic in accounting analysis. The concept of political salience has been introduced to shed light on how some accounting issues acquire political attention and the role of civil society actors in driving this. In the case of CTA, an investigation into the dynamics behind the generation of political salience takes us beyond debates around the ethics of CTA (see for example Sikka, 2010; Haseldine & Morris, 2013) onto questions of political reform and legislation. What points can we take then from the political salience of CTA and the TJN case study? The first is the role of the newspaper media in the UK, which has been crucial to how a complex and difficult area of accounting practice has been translated into a broader public issue. This has centred on particular stories of scandal involving recognized brands (see also Hanlon & Slemrod, 2009). Second, and more broadly, the TJN approach has highlighted the value of civil society actors being able to speak different languages to different audiences. Key members of the TJN have been involved in writing stories to provide wider journalistic exposure of tax avoidance (see for example Shaxson, 2011), and others have advised politicians about international policy proposals (see for example European Parliament, 2015b). These different communication strategies have helped to generate political salience at different levels. Third, it was also notable how the earlier information and research based focus of the TJN translated into broader political salience through external factors and a supportive issue environment, centred on post-crisis austerity, combined with sympathetic MPs, and investigative journalists. Thus clearly no single actor working in isolation can manufacture political salience for an issue, since this requires a broad and interlocking process across different fields and a supportive issue environment. The fourth aspect of the generation of political salience has been the distinctive organizational structure and approach of the TJN. What the case has shown is that political economy accounting research and the development of alternative narratives around accounting are important, and that research must be decentralised to help broaden the network. Yet for political salience to be generated, some degree of centralisation and coordination is necessary both in terms of campaigning and to provide at least some level of operational coordination to keep the network running. The TJN does this through a small number of core staff who can respond rapidly to emerging stories. Although there is a question of balance here, since if operational coordination is too centralised this limits diversity and thus the capacity to expand the network more widely. The need for a degree of centralisation in some areas clearly supports Wong’s (2012) analysis, although it is less applicable to research where networking and opportunities for expansion are maximised when the organization is looser and more decentralised. While this analysis has been focused around an academic analysis of one NGO, and this limits the generalizability of the findings, the hope is that this case has shed some light on the strategies and the distinctive approach of an important civil society actor in raising the political salience of CTA. Furthermore, if certain civil society actors have been central to policy discussions about tax reform – of which public CBCR is a very clear case – their strategies should be the focus of greater recognition and analytical attention within academic accounting analysis. The proposal developed in this paper is that Wong’s conception of political salience (Wong, 2012; see also Stroup & Wong, 2013; Hendrix & Wong, 2014) offers a fresh analytical focus for political economy accounting analysis, one that gives us the means to undertake further investigation into the strategies of civil society actors and the role of the media in shaping debates around accounting practice. The conception of political salience developed here offers some important areas for further research. First, from an empirical perspective, the newspaper media has been identified as central to the generation of political salience in the case of CTA. But the engagement of investigative reporters with the issue across the national press, particularly from 2010 onwards, and the receptivity of editorial boards to these stories, warrants further investigation around how this change occurred. Second, the concept of political salience has foregrounded the role of civil society actors and it thus presents opportunities for further research on the different strategies of civil society groups involved in campaigns for accounting reform, and an examination of what kinds of organizational form and communication strategy have been effective in generating political salience in different cases.

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Acknowledgements My thanks to all of the interview responses who participated in the research for their detailed responses to questions. I would also like to thank the anonymous reviewers, and Adam Leaver and Julie Froud for helpful comments provided on earlier drafts of the paper. Appendix A.

Fig. A1. References to ‘corporate tax avoidance’ in top UK newspapers 2003–2015.

Fig. A2. References to ‘tax havens’ in top UK newspapers 2003–2015.

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Appendix B.

Fig. B1. References to Tax Justice Network or TJN or John Christensen or Richard Murphy or Prem Sikka in top UK newspapers 2003–2015.

Fig. B2. References to ‘country-by-country reporting’. General Factiva search – including international media, national and international policy making bodies. 2015 citations most frequently referenced with OECD (436), European Union (272) and European Parliament (229), 2003–2015.

Appendix C. Bacon, R. (Minister of Parliament and Vice Chair Public Accounts Committee, 2010–2015), interview 25/3/2015. Christensen, J. (TJN executive director and TJN co-founder), interview 9/3/2015. Cobham, A. (TJN Research Director), interview 23/4/2015. Meinzer, M. (TJN Senior Researcher), interview 5/5/2015. MP and Public Accounts Committee member (anonymous), interview 17/3/2015. MP and Public Accounts Committee member (anonymous), interview 24/3/2015. Murphy, R. (Director of Tax Research and TJN co-founder), interview 19/2/2015. Researcher on the TJN and academic (anonymous), interview 22/4/2015. Shaxson, N. (TJN writer and researcher), interview 5/3/2015. Quentin, D. (TJN Senior Advisor), interview 12/10/2016.

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