I've been giving the recent KPMG paper on tax and CSR a more thorough read. It's made me think a lot, but as usual with KPMG publications my thoughts have flowed along two themes.

The first is what it does not say, on which there's enough to write a small book. I might just get around to writing it sometime.

The second is just how crass much of what they say is. Nowhere is this more obvious than in section 6 on 'Special features of tax in relation to CSR'. Here they make the claim that a special feature of tax and corporate social responsibility is that:

[F]or tax transactions there is normally only one counterparty in any jurisdiction. Many of the commercial decisions influenced by CSR relate to choice of supplier or of target markets. Tax, by contrast, is paid only to the state or to subdivisions of it; there is no choice as to whom the company deals with on tax matters, except insofar as decisions on location of activities and transfer pricing determine the state in which the liability arises.

In other words, as far as KPMG is concerned the only relationship of consequence in tax is between the tax payer and the state to whom they have liability. Nothing else apparently need be of concern when considering tax and CSR. As a quick response I noted the other relationships that I could immediately think of that might be of concern and came up with the follwoing list of relationships, all of which have a tax dimension that can be negotiated, that meet need to be thought about:

1. Between companies under different ownership;
2. Between companies under common ownership;
3. Between companies in the same country;
4. Between companies in different countries;
5. Between companies and tax administrations in more than one country;
6. Between companies under common ownership in different countries and tax administrations in multiple countries;
7. Between companies and their tax advisors;
8. The relationship between tax advisors in different countries advising companies under common ownership;
9. The relationship of tax advisers to companies under different ownership in one of more countries;
10. The relationship between governments (as opposed to tax administrations) and companies;
11. The relationship between governments and tax advisers, and vice versa;
12. The relationship between a company and:
a. Its customers;
b. Suppliers;
c. Staff;
d. Investors;
e. Civil Society
f. The media and others with enquiry to make of it.
13. The role of the company and advisers on legislation;
14. The duty of the adviser to other advisers;
15. The duty of a government to another government.

Now remember that this paper is produced for the "KPMG's Tax Business School ¬Ã†" (I think that registration so crass) so I have to presume it's what they're teaching their people. But that begs the question are they teaching these people or indoctrinating them? Either way, heaven help their clients who might end up paying for advice from those who have been subject to this process.

Perhaps they'd like to take a look at our Code of Conduct. It might broaden their imaginations.