Based on the results of the Tax Transparency Benchmark 2019 and the expert jury meeting, bespoke recommendations for further improvement for selected stakeholders are outlined below.

To companies 

  • Ensure you keep abreast of all relevant developments regarding the transparent reporting of tax and continue to adapt your policies and practice to align with these new standards;
  • Stay engaged or start engaging in an active dialogue with internal and external stakeholders to further develop your tax communication approach and help rebuild trust in taxation;
  • Provide further narrative about tax processes to move from a “show me” stance to a “tell me” one;
  • Continue to elaborate on the tax risk management process, and include a description of the company’s tax risks, risk appetite and risk response in public information;
  • Provide country-by-country reporting data and seek to improve the quality and the remit of this data;
  • Implement and continuously improve a monitoring system for the implementation and execution of your tax strategy;
  • Consider providing assurance, ideally an in-control statement and third-party tax assurance, on your tax strategy. An in-control statement should also be provided by your Internal Audit Department (or the department responsible for governance);
  • Implement the tax strategy on paper, do not use this Tax Transparency Benchmark to merely ‘tick boxes’.

To lawmakers, regulators and tax authorities

  • Proper legislation underpins enhanced tax transparency. Assist companies to develop a clear strategic vision on tax transparency and governance, by passing appropriate laws and strict good tax governance standards that apply to all companies;
  • Actively promote the use of internationally accepted standards to provide multinational companies with comparable or common governance, reporting and audit standards to work with across borders;
  • Ensure clear guidance on rules and regulations for cooperative compliance programmes and stimulate voluntary compliance;
  • Increase the transparency of compliance management strategies and tax accountability and help rebuild trust in taxation.


  • Engage in open and constructive dialogue with companies and focus on encouraging them to change. Differentiate in how you approach high and low performers on tax transparency and good tax governance;
  • Share best practices with companies on what you consider responsible and transparent corporate tax behaviour;
  • Do not only focus your efforts on multinationals and tax advisers but also on tax administrations and investors;
  • Enter into structured dialogue with governments to promote transparency.

To tax advisory firms

  • Ensure employees have the proper tax technical, tax governance and digital tax expertise;
  • See tax in a broader societal context, i.e. not only from a legal or financial perspective;
  • Promote responsible tax behaviour and support companies’ tax transparency initiatives;
  • Dare to have a robust dialogue on this topic with all stakeholders;
  • Introduce and apply an internal code of conduct for tax advice;
  • Ensure each tax adviser is familiar with the client’s sustainability and business strategy.

To investors

  • Design and implement a tax code of conduct that applies to:
    • your own organisation;
    • how you structure your investments;
    • your investments;
    • the parties you collaborate with;
  • Integrate tax in the valuation of investee companies by including it in investment and ESG policies;
  • Be transparent on the tax strategy of your own organisation and what you expect from investments and the parties you collaborate with;
  • Enter into a dialogue with portfolio companies on responsible and transparent tax behaviour;
  • Not only test investments at the moment of investment, but also monitor adherence to your criteria or expectations during the lifecycle of the investment;
  • Support initiatives to develop common standards for tax reporting to enhance (global) comparability.

To universities

  • Introduce a modernised curriculum for tax-related courses in order to meet the market’s demand for skilled tax professionals who can drive forward tax transparency;
  • Introduce relevant tax topics in economics, business management and mathematics courses, and in the social and political sciences;
  • Better communicate with society. i.e. in less technical language.


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Eelco van der Enden

Eelco van der Enden

Partner, PwC Netherlands

Tel: +31 (0)88 792 51 38

Bob van der Made

Bob van der Made

Project Manager, Senior Adviser EU-Brussels (TAX), PwC Netherlands

Tel: +31 (0)88 792 36 96