Paper short abstract:

This paper focusses on tax authorities’ regulation of large corporations. By looking at a case in Denmark and Finland, we analyze relations between corporations showing transparency into their tax matters and authorities providing predictability. Based on this we discuss fairness and favoring.

Paper long abstract:

This paper discusses challenges of fairness versus favoring when large corporate taxpayers are regulated by tax authorities. It reports a case study of how large corporate taxpayers are being regulated within the so-called Cooperative Compliance program in Denmark and Finland. This internationally renowned regulatory program has been scrutinized through in-depth qualitative studies in both countries. The program forms a regulatory relation based on collaboration and has a specific set of ‘parts and aims’—reflected in its similarity in Denmark and Finland. Based on this shared ground, we show that in both cases when the program is brought into operation by the tax authorities, this brings about a number of challenges related to how transparency and predictability are negotiated and enacted in the relations. We will present how respectively tax officials, tax directors and tax advisers understand these processes of providing transparency and predictability. The challenges imbued in this regulatory craft lead to a discussion about how this particular form of regulation is fair or whether there is some kind of favoring of certain actors. This discussion links to the panel on “Tax matters” as it precisely shows “the making of” tax compliance and questions how and which kind of “justice” this creates for the actors.