Pendulum or Progress? Tax Consultants in the Crisis of Legitimacy

Abstract

After a series of scandals, the focus is now shifting to tax professionals who have received little attention so far. The paper examines how tax professionals justify their professional activities in the legitimacy crisis of tax planning. Professions have a systemic role and combine commercial interest with social benefit. In the crisis, professionals need to re-legitimize themselves by addressing core societal values in order to secure the benefits associated with professional status. Building on problem-centered qualitative interviews with 45 tax professionals from Germany, Liechtenstein, and Austria with different business models, I show that these tax professionals justify their activities in the crisis via three ideal-typical norms: selective liberal values and counterattacks, elitist shaping, and the benefits for the business location. Most professionals hope for a pendulum movement as a rollback of regulation.

Keywords

tax professionals legitimation crisis sociology of professions tax regulation

Introduction

At the turn of the millennium, tax evasion and aggressive tax structuring were hardly an issue for the public and politicians. The view that no one likes to pay taxes and that tax evasion is a harmless crime was widespread. Tax evasion, in the portrayal of many politicians, was a consequence of globalization, against which they could do little. The view changed after publications of leaked data that revealed tax evasion and money laundering in specific cases, such as the Liechtenstein tax affair published in 2008, the Offshore Leaks (2013), Luxembourg Leaks (2014), Swiss Leaks (2015), Panama Papers (2016), Bahamas Leaks (2016), Malta Files (2017), Paradise Papers (2017), CumEx Files (2018), OpenLux (2021), and Pandora Papers (2021). Media have also reported on tax avoidance by international corporations that have pushed their tax rates so far below the usual level by exploiting technical tricks that the European Commission classified this tax avoidance as aggressive (e.g., European Commission, 2017). Previously highly respected financial actors fell into disrepute after the Lehman bankruptcy and the subsequent financial and economic crisis. At the turn of the millennium, policymakers were still fighting tax evasion in an international context with little ambition and by means of largely symbolic measures (Ötsch, 2012, 2016; Sharman, 2009, 2010). In the aftermath of the financial crisis, governments tightened regulations for more transparency and information exchange, introduced anti-abuse legislation at national level as well, took action against aggressive tax avoidance under the OECD’s BEPS initiative and agreed on a global minimum tax. While experts still see regulatory gaps and observe a shift of assets into tangible assets not covered by transparency provisions, they share the view that policymakers have made great progress in regulating tax matters in recent years (Alstadsæter, Johannesen, et al., 2022; Alstadsæter, Planterose, et al., 2022; Bomare & Le Guern Herry, 2022).

Tax advisors have hardly featured in discussions of the social role of business professionals. Before the scandals, only a few scholars had dealt with the role of tax professionals as enablers of tax evasion, money laundering, and aggressive tax structuring (Mitchell et al., 1994, 1998; Sikka, 2010; Sikka & Hampton, 2005; Sikka & Willmott, 2010; Strange, 1999). Thereby, their actions as professionals have noteworthy effects on the allocation of resources in modern states. Total tax revenue as a percentage of GDP was 33.8% on average in the OECD in 2019 (OECD, 2022). The distribution of taxes within society—the share of taxes on consumption, income, corporate profits or wealth and labor, or viewed differently on different groups—shapes societies significantly. Because of their steering function, taxes can be a means and an incentive to combat the environmental crisis. While the public initially focused on tax evaders and politicians who had failed to adequately regulate tax systems, tax professionals also came into focus in the wake of the scandals, for example in the context of parliamentary commissions of inquiry and debates (Ötsch, 2017). For decades, politicians and society had confidently relied on the self-regulation of the professions. This trust is crumbling due to repeated cases of misconduct. Carter et al. (2015, p. 1208) write: “Society needs to be written back into our understanding of professions—for too long the literature has fallen silent on the role of the state and civil society in relation to professions.” On the other hand, tax advisors feel misunderstood and complain about tax advisors generally being suspected of abuse and that excessive regulation is creating a “bureaucracy monster” (Bundessteuerberaterkammer, 2019). This crisis of legitimacy of tax consulting coincides with other crisis phenomena, such as environmental crisis, war, pandemic, etc. Change usually brings conflicts, especially with groups that are losers by the change. In this context, it is important to understand how affected social groups respond. In this paper, I examine whether and how tax professionals in Germany perceive the legitimacy crisis of tax structuring and how they react to it. In doing so, I consider the dual character of the profession, which combines a core social value with economic goals. This is relevant because in crises, if professionals fail to find societal approval, the self-governance of the profession may be restricted and rights of professionals may be limited. Therefore, I first outline findings from the sociology of professions about institutional or professional logics, their change in crises in relation to normative legitimacy. Based on the analysis of 9 expert interviews and 34 semi-structured problem-centered interviews with different types of tax professionals from Germany, Liechtenstein, and Austria, this paper investigates which core values tax professionals use to legitimize their activities in times of crisis. How do tax professionals relate to each other and to other stakeholders? How do the results relate to studies on the legitimation crisis of tax professionals in other contexts? The study finds that these tax professionals either position themselves as protectors of citizens from the state via selective liberal virtues, build bridges to higher-level social projects as value-based elitist shapers, or define themselves in terms of the value of working on a common project in global competition.

Professionals, Legitimacy Crisis, and Change

Professionals have a large influence in society due to their position as gatekeepers, their being organized and their expertise. Thus, it would be appropriate to extend the triangle of governance, consisting of NGOs/advocacy, states/policy, and firms/corporates, to include professionals who have a decisive influence in all of these areas and who mediate between these sectors, particularly in situations of change (Seabrooke & Wigan, 2015, p. 3). The sociology of professions assumes that professionals have a special status compared to occupations. According to Harald Mieg (2003, pp. 15–17), frequently mentioned characteristics of professions are (1) knowledge of action and explanation that is applied to a socially relevant problem area; (2) the reference to a core social value; (3) a largely academic education; and (4) being represented by a professional association or professional representation. Professions form a third category which shapes social coexistence between the state and the market (Durkheim, 1992; Freidson, 2002; Marshall, 1939) and professions have a “dual character” (Pfadenhauer, 2003, p. 40). On the one hand, professionals should have special skills and provide socially useful services, while on the other hand they use their skills for profit. It is crucial that the balance between the common good and self-interest is maintained (Evetts, 2003, p. 50). The sociology of professions describes a long-term tension in capitalist societies between the social benefits that professionals bring and the harm they can cause through selfish behavior. Functionalist theories have mainly emphasized the benefits that “channeling competition” can bring about quality standards and skilled services in complex societies (Carr-Saunders & Wilson, 1933; Parsons, 1939; Platt et al., 1973). Other authors see useful potential in the unifying societal role of professionals as intermediaries between business and politics (Durkheim, 1992; Münch, 1994). Power- and conflict-theoretical points of view criticize this view. They observe, on the contrary, self-interested actions: In this view, professionals exploit regulated market conditions, status and competence attributions and rights of self-administration, at the expense of society and of recipients of the services (Freidson, 1972; Johnson, 1972; Larson, 2013), connected with forms of social closure via professions or occupations (Larson, 2013; Saks, 2016; Weber, 1921). Power theory approaches are criticized for suggesting that closure can only be one possible outcome of professionalization, but not the primary goal of professional work (Halliday, 1987). A profession can be understood as the result of a process of negotiation with external stakeholders (such as the state) and internal competitors, determined by conflict and dialog (Abbott, 2009); that is, as a dynamic system affected by internal, as well as external logics. Thus, interfaces and interactions of professionals with organizations and institutions become relevant (Saks, 2016, pp. 10–12; Suddaby & Muzio, 2015). According to DiMaggio and Powel (1983) organizations and society are increasingly subject to transformation less through competition than through the shaping influence of professions and the state. Professionals exert normative (isomorphic) pressure, for instance via (university) education systems and cognitive legitimation, networks, and recruitment. In organizations, they make decisions that are not determined by competition for resources alone, but also by competition for legitimacy and political influence (DiMaggio & Powell, 1983, p. 152). Contradictions between institutions and (their justifying) logics give rise to scope for individual and organizational action (Friedland & Alford, 1991), institutional entrepreneurship, and institutional work (Seabrooke & Wigan, 2015, p. 704) and crises can lead to a reorganization of hierarchies between different orders (Boltanski & Thévenot, 1991; Ramirez, 2013).

The crisis concerns the relationship between the profession and the state. Following Carter et al. (2015, p. 1201) “for professions, a crisis poses a specific problem: professional jurisdiction is ultimately granted by the state and in the light of a crisis the state is likely to intervene to reform the profession.” Hazgui and Gendron (2015) describe the regulation of a profession by the regulating authority, which goes hand in hand with the professionals’ attempts to shape regulation in their own sense. The authors describe this phenomenon with the pendulum metaphor, which—as we will describe later—tax professionals frequently use in our sample. In a legitimacy crisis of tax consulting, firstly, privileges of the profession are in question and secondly the position of different types of professionals or organizations within the profession changes. According to institutional theory, new organizations emerge through legitimacy (which employs techniques to achieve the chosen form of legitimacy), shifts in institutional logics and the strategic use of persuasive language, or rhetoric that is the means by which shifts in institutional logics are secured (Suddaby & Greenwood, 2005, p. 35). New logics and institutions can be implemented through reframing (via the use of language) and are most likely to become legitimate “when they fit into the preexisting cultural beliefs, meanings, and typifications of an organizational community” (Suddaby & Greenwood, 2005, p. 39). Contradictions arise in certain situations where professionals act as instrumental or moral agents and use language to enforce shifts or the preservation of institutional logics (Suddaby & Greenwood, 2005).

The tension between “core value” and “commercial interests” internalized in professions breaks out in crises, in which professionals can act as both instrumental and moral agents (Seabrooke & Wigan, 2015). Seabrooke and Wigan (2015) argue that when new reporting standards (CBCR) were introduced, morally based ideas of the Tax Justice Network have been able to prevail over interests of commercial international financial service providers, which have had a transformative effect. They explain this with reference to Campbell (1998), according to whom expertise is composed of both cognitive and normative ideas, whereby ideas are only convincing if they have moral persuasiveness (Seabrooke & Wigan, 2015, p. 4). A crisis is a window of opportunity that augment both salience and valence (linked to emotional quality) and a situation in which morally convincing values can also prevail (Seabrooke & Wigan, 2015). A study on the interaction of financial service providers involved in regulatory processes in the French context showed that professionals perform “boundary work”—work that “consists in activities carried out by an organization to set, maintain, defend, or negotiate legitimate role boundaries. It involves experimentation . . . in which roles, activities, and practices are proposed and adopted on a tentative basis” (Hazgui & Gendron, 2015, p. 1236). Boundary work involves various tactics and phases, such as developing and spreading justifications, withholding information, downplaying the need for change, providing bodies with resources, casting doubt on competencies or shifting discourse and commitment (Hazgui & Gendron, 2015). Regulation of professionals thus has more than a symbolic character. A hybrid form of regulation is taking hold that goes beyond symbolic regulation “securing a prominent role for the professional association within regulatory space” (Hazgui & Gendron, 2015, p. 1255). This “co-regulation” connects an independent regulation and the logic of self-regulation (Hazgui & Gendron, 2015).

However, recent research (Christensen, 2021), examining the role of experts in the negotiations of the OECD’s BEPS process aimed at limiting aggressive tax avoidance shows that technical expertise is particularly highly regarded despite a crisis of legitimacy. Persons with expertise in tax law are more likely to be heard than those with a background in economics, and civil society is hardly present. Paradoxically, the highly technical regulation in response to the crisis strengthens the influence of tax professionals, as their knowledge is particularly highly weighted (Christensen, 2021). Despite the legitimacy crisis, according to a Canadian study, tax accountants and lawyers have a certain blackmail potential due to their technical expertise and complicated regulation (Radcliffe et al., 2018, p. 55).

Other more recent empirical surveys on tax professionals in the crisis of legitimacy also show that professionals themselves refer to moral values and socially recognized legitimacies, respectively they use them tactically (Addison & Mueller, 2015; Harrington, 2019; Radcliffe et al., 2018). A discourse analysis on the Public Accounts Committee inquiry in the United Kingdom. into tax avoidance schemes revealed that representatives of Big Accountancy firms mainly refer to the framing that business competition is the heart of the professional mandate (Addison & Mueller, 2015, p. 1279). Following this framing, a profession has been co-opted into the dynamics of neo-liberal capitalism and will prioritize growth and profitability above all else. Professionals here externalize responsibility and attribute the phenomena to globalization, complexity, and the liberal market economy. In addition, professionals emphasize that one must distinguish between legal tax avoidance and illegal tax evasion. The company’s internal Code of Conduct should guarantee compliance with professional ethical standards (Addison & Mueller, 2015).

In contrast to the perspective of institutional logics and theories of power, recent analyses of tax professionals also elaborate on the individual agenda of professionals, which does not necessarily have to be that of the organization or profession and can be a lever for change. It is not clear whether analyses based on power theory, criticisms of globalization, and institutional logics over- or underemphasize structures or institutions as opposed to agency. Prem Sikka and Hugh Willmott speak of institutional corruption with regard to the big accounting firms:

The big accounting firms camouflage their practices with ethical codes and glossy corporate social responsibility reports. Their claim is to be advising clients on ‘tax planning’ – a euphemism for tax avoidance and evasion. . . . schemes masquerade as forms of ‘tax avoidance’ that are deemed to legitimate until they are challenged and found to be unlawful (Sikka & Willmott, 2013, p. 431).

However, the development of tax schemes, which was strongly promoted in the 1990s, was not requested by clients, but actively promoted by professionals (Sikka & Willmott, 2013, pp. 435–436), which points to agency rather than globalization constraints. Thus, the existence of an institutional logic does not preclude the emergence of alternative logics, but often makes it more difficult to act in an alternative sense. Responsibility cannot be shifted to neoliberal capitalism, but it would be too voluntaristic to deny its appeal (Sikka & Willmott, 2013, pp. 436–437).

Ecological or relational approaches also look at different connections at the micro, meso, and macro levels to explain possibilities for change. One factor that generates change is competition and power between different segments of a profession, such as between small tax advisors versus accountancy firms (Carter et al., 2015, pp. 1204–1205). Research in this spirit concludes that tax professionals adapt their activities only moderately; the change in the profession under the pressure of the legitimacy crisis is superficial. In the case of the global introduction of trusts, advisers have played an active role in convincing local clients to use this legal form, solving specific problems, building professional ties, and cultivating informal institutional work, such as with legislators, educational partnerships and universities, thus facilitating the isomorphic adaptation of the trust model (Harrington, 2015). In a further analysis, Brooke Harrington (2019) shows that wealth managers advising ultra-wealthy individuals in an international context seek to legitimize their activities through category editing, attempting to manipulate the demarcations that structure perceptions and assessments of facts (Harrington, 2019, p. 4). Radcliffe et al. (2018) describe the reactions of Canadian tax professionals in the context of the BEPS process to newly introduced regulation as ambivalent. The professionals point to the need for a positivist interpretation of the law and shift responsibility to the state, which must close loopholes in the law (Radcliffe et al., 2018, pp. 50–51). Indoor advisers are more worried than external advisers, with tax professionals overall paying more attention to moral perspectives, regulation, and social pressures, and balancing commercial, regulatory, and moral logics (Radcliffe et al., 2018, pp. 51–52). The professionals see themselves as mediators who need to keep their organizations out of newspapers, paying more attention to public perceptions and expressions as strategic necessity rather than to a moral position per se (Radcliffe et al., 2018, p. 52). The technically complex reforms strengthen the influence of tax professionals in companies, at the same time, professionals must increasingly take into account moral considerations in tax matters. (Radcliffe et al., 2018). Our own research on tax professionals has shown that tax professionals have been able to use their expertise to accumulate capital more extensively than comparably skilled other professionals. The tax consulting industry has a wide range of business models that have so far changed little as a result of the legitimacy crisis (Ötsch, 2021). These case studies thus show that there is scope for action, but that professionals nevertheless tend to act in accordance with institutional logic. However, our study also revealed that the social conflict constellations change during the crisis. With regard to sense-making and issues of recognition, we have shown that the crisis of legitimacy has only rudimentarily translated into a crisis of sense-making among professionals. However, there has been a shift in the constellation of conflicts, which until the turn of the millennium was dominated by the motto “everyone against the tax,” while the view of the recognition and positioning of tax professionals changed significantly as a result of the crisis, leading to different constellations of recognition and conflict (Ötsch et al., 2021). Does this changed conflict constellation also lead to a normative redefinition of the profession? In the following, we focus on the normative legitimation of professionals in the crisis, in particular their reference to the central value of the profession of tax consulting, focusing on the situation in Germany and potential changes due to the crisis. So far, it has been unclear whether surveys on tax professionals from the international, especially Anglo-Saxon context can be transferred to the situation in other countries that have different economic, institutional (legal system, financial administration, political tradition), and cultural contexts. Our study also examines the German tax-consulting scene in its broadness so that we can investigate different reactions between different types of tax professionals.

Methods

The research project “Tax Planning as a Profession” explores how tax professionals, focusing on the German context, deal with the legitimacy crisis of tax planning. In this paper, I consider how tax professionals perceive regulation, how they react to the legitimacy crisis, especially related to core values of the profession of tax consultants. To answer the aforementioned questions, we first surveyed the field of tax structuring in Germany and the activities of professionals from an external perspective, building on documents from regulators and investigative commissions, leaks, and literature studies. We also conducted 9 preparatory interviews with 10 experts (from academia, tax consulting industry, professional policy staff, administration, and civil society). In the main phase, we conducted 34 interviews with 35 professionals working in different areas of tax advice (see list of materials for anonymized list). We selected the interviewees following a qualitative sampling according to the principle of maximum structural variation (Kleining, 1982). The contrasting characteristics of the cases were, in particular, the business model, the expertise by tax type, the specific qualification, and the career path of the person. The professionals worked in tax consulting and auditing firms, law firms, tax departments of companies and banks, and a fund. We also interviewed self-employed persons, professors with consulting activities, and individuals from the tax administration and a trade union. Forty-one individuals were mainly located in Germany, one in Austria, and three in Liechtenstein, known for its low taxes and foundations. The latter also advise clients in Germany. We contacted the interviewees directly, approached them at events, and reached a small number using the snowball principle.

The professionals were interviewed using a semi-structured problem-oriented guideline (Witzel, 2000) which contained open questions and inquired about practices, in addition to questions that were more cognitive and normative in nature. These related to the professionals’ own activities, their dealings with laws, the concept of tax design, questions about legality, and attitudes toward issues of legitimacy, perceptions of regulation, the social function of tax advisors, the concept of tax justice, and the professionals’ careers and personal backgrounds. Interviews took place between early 2019 and 2021 and generally lasted 60 to 90 minutes, some much longer.

We analyzed the qualitative interviews using the reconstructive-hermeneutic integrative basic method according to Jan Kruse (2014, pp. 472–568), which is a further elaboration of the documentary method (Bohnsack, 2021), supplemented by a text-linguistic method with a sociological target perspective and further elaborations of the method concerning ideal type formation (Bohnsack, 2021; Nohl, 2017; Wohlrab-Sahr & Przyborski, 2013). We first analyzed the transcribed interviews case by case in an analysis group. Following Nohl (2017, p. 30), we chose the interview passages analyzed in depth for this paper by first singling out passages with relevant themes (in this case, on the social function of tax planning and tax advisors, justifications). Secondly, we looked at themes on which the interviewees “expressed themselves at length, engagingly, and metaphorically” (Nohl, 2017, p. 30) and those that are appropriate for a comparative analysis between cases. In the analysis process, we first examined the cases (person-related) individually in relation to the research question. In the detailed analysis, we paid attention, among other things, to the structure of the argumentation, agency of the interviewees, positioning, self-attributions, patterns of interpretation, concepts, narratives, motifs, topoi, images and metaphors, emotional expressions, caesurae, and markers of change. In a first step, we described the perception of regulation and different reactions within the profession. In a second step, we analyzed the reference to a core societal value associated with the professional activity in order to create an ideal type based on meaning. In particular, we derived this information from the descriptions of functions and roles, as well as from justifications of taxation and comparisons with other roles that the professionals mentioned throughout the interview. In forming the types, we first compared and classified the cases, then we clustered and defined the clusters until three basic values emerged that could be distinguished from each other. In the empirical part of this article, I use selected quotations to clarify statements in the original tone. For readability, in some cases I have shortened fillers, stutters, or other slips of the tongue and replaced them with dots. Capital letters stand for strongly stressed hyphen, a dot in brackets stands for a short pause, numbers in brackets for longer pauses. Additions, which are necessary due to the comprehensibility, I have entered in square brackets. I finally compared the types with characteristics of the professionals and found a rough correlation between core value and business model. In a final step, we compared our results with those of the studies discussed above.

Results: Tax Professionals for Citizens’ Rights, Value-driven Action, and Prosperity

Here, I first present some framework data on the tax consulting industry in Germany. Based on our empirical research, I describe how the interviewed tax professionals perceive the crisis and how they react to it, describe ideal-typical core values to which tax professionals refer in this situation and ask what perspectives for change can arise.

The Field of Tax Consulting in Germany

At the beginning of 2022, there were over 88,000 tax consultants and around 11,300 tax consulting firms in Germany. Sixty-eight percent of professionals are self-employed and 32% are employed, with around 7,500 professionals employed as in-house counsel by a company (Bundessteuerberaterkammer, 2022). 37.5% of tax advisors are women, 62.5% are men (Bundessteuerberaterkammer, 2022).

The activities of German tax advisors range from advising private individuals or small self-employed persons, to services for medium-sized companies, public corporations and associations, to medium-sized and large companies and family offices of wealthy private individuals. In addition, accounting firms, especially the Big Four, are increasingly providing tax advisory services. Besides, there are highly specialized firms, which tax consultants themselves call “boutiques,” alluding to a place that offers goods for exquisite demands. According to professional rankings, boutiques and Big Four accounting firms have particularly high revenues per professional (Ötsch, 2021). Working as tax consultants in Germany requires a license granted to those who have successfully passed the tax consultant exam. Prerequisite for admission to the examination is either a degree in economics or law or having completed a commercial apprenticeship with several years of relevant professional experience, the length of which varies depending on the educational path. Civil servants in the higher service and employees in the financial administration can also be admitted, on condition that they can demonstrate their professional experience (Bundesagentur für Arbeit, 2022). The role of tax advisors is defined in the Tax Advisory Act (StBerG 2021) and in professional standards (Bundessteuerberaterkammer, 2012): Tax advisors should provide objective and independent advice. Tax advisors should support the client vis-à-vis government authorities, but also take into account the law and the general interest in the enforcement of tax law.

At the national level, German lawmakers responded to tax scandals by tightening up various laws, such as a law to combat tax evasion, controlled foreign corporation rules, withholding taxes, the introduction of an anti-abuse paragraph (§42 AO), and, at the time of the investigation, reporting obligations for tax structuring. Between 2011 and 2020, the European Union enacted 12 valid directives on tax evasion and avoidance alone, among others to implement the resolutions from the OECD’s BEPS initiative and concerning mandatory automatic exchange of information, reportable cross-border arrangements, administrative cooperation in the field of taxation, hybrid mismatches with third countries, money laundering, or terrorist financing and the treatment of vouchers.

Tax Professionals’ Reactions to the Legitimacy Crisis

The tax professionals’ view of regulation is similar in broad outlines, but varies in their assessment of the measures and responses. Interviewees consistently reported that tax laws have tightened and tax administration has become stricter. They clearly distinguish the earlier period with the current situation, with most interviewees dating the turnaround in tax policy and public perception of tax structuring roughly to the period of the financial crisis that began in 2007.

A tax advisor with longer professional experience, as an advisor to a medium-sized law firm, describes that in the past, in the 1970s and 80s, it was not the custom to expand gray areas: “there are things where one says, this is perhaps not legally forbidden, but one does not do that.” That changed in the 1990s; the idea of saving taxes came from the taxpayers. At that time, the large accounting firms had founded a kind of think tank and had proactively

started to develop tax models WITHOUT having a mandate . . . and said: this model is . . . valid (1) and now we sell the model Hamburg if you like it, we will put it into practice for you . . . that started MASSIVELY in the nineties. . . . and now we have been experiencing for about . . . four, five years that the pendulum is swinging in the other direction. . . . people moralize taxes.

The tax advisor also reported about employees of the tax administration who would exaggerate their role and act like sheriffs toward taxpayers. Other consultants describe the situation before the 1990s as a time when politicians and the administration tolerated certain tax arrangements, or even tax evasion. A lawyer and tax consultant working in a medium-sized tax and accounting firm reported that it used to be common practice in craft businesses, even in family-run companies, that certain private expenses, in case of doubt the private house, were financed through the company, with tax benefits. Interviewees also spoke of the past as “the Wild West.”

Various tax advisors used the pendulum metaphor. This suggests that the pendulum should naturally move back in the other direction, that is, toward looser regulation. Similarly, interviewees use the image of a disturbed equilibrium or the scales being out of balance due to regulations. According to the tax advisor of a bank, the financial crisis made everyone see the need for regulation but “… it doesn’t swing to the middle of the scale, but completely to the other side, where you say, for God’s sake, that’s much too far-reaching.” On the other hand, a financial official asked about the pendulum metaphor describes that at the turn of the millennium politics initially had deliberately deregulated, but contradicts the suggestion of a pendulum movement: The situation had changed with the financial market crisis. As far as tax compliance issues are concerned, there has been no phase of deregulation since then, but rather a permanent increase in regulation. The issue of tax fairness would be “highly anchored in the consciousness of the population” and “if regulation is needed to serve this idea . . . then I don’t see any pendulum movement or deviating tendency.” The partner of a medium-sized consulting firm, who was also involved in tax legislation as a member of the parliament from the conservative camp, on the other hand, has already tipped the pendulum in a different direction in the interview. While, to some extent, he recognized the need for tightening regulation, he also saw overregulation:

We have now spent the last . . . eight, ten years essentially dealing with how we can combat tax abuse . . . That is why I am of the opinion that we must . . . also do other things again in order to cope internationally [in] tax competition . . . under certain circumstances . . . perhaps we will have to look later on whether we have not overreacted in some cases. I wish that the legislator would have such an after-sales service . . . that they would do an impact analysis. Whether the goals were actually achieved or whether they even overshot the mark in part because they were afraid that something would happen. In the German Parliament, you can get any law passed if you write ‘Steuermissbrauchsbekämpfungsgesetz’ [Tax Abuse Control Act] over it. . . .so. . . under the floor we pull in another floor and another floor. And in doing so, we also partially hit people who do quite normal business.

The interviewee reflects the view—frequently found among tax advisors—that politicians do not regulate taxation out of conviction or factual arguments, but driven by excessive public pressure. Moreover, he already proposes concrete measures that should initiate a pendulum movement in the direction of a reduction in regulation and justifies these with competition and the interest of small businesspeople. Various tax advisors complained about collateral damage caused by regulation, in this case the tax manager of a private bank: “Only one bank has done something and then they just shoot at a small mosquito with (.) a huge flyswatter . . . and all the others have to help implement it.” Even a tax consultant whose advised company was considered compliant complained that the profession’s reputation was being tarnished by “pillory discussions,” “. . . by all these overheated discussions and by the press, that then . . . the profession might not be seen now as squeaky clean as it used to be seen.” Concerns about reputation were widespread. Tax consultants feared both a loss of reputation among the clients they advised, the society in which they worked, and their own social stigmatization in their personal environment.

It is noteworthy that tax advisors refer to the past or the current situation either positively or negatively to varying degrees. The group that refers negatively to the past distinguishes itself from older colleagues. Tax advisors reported that children of clients are often embarrassed when, in the course of passing on the inheritance, it comes out that the older generation have arranged taxes in an illegitimate way.

By saying that tax evasion was quite normal in the past and that even ordinary people engaged in it, tax professionals put these practices into perspective and contrast them with the present, which they see as morally overloaded. According to a partner with wealthy private clients, in the 1960s and 1970s, “. . . tax avoidance via Switzerland was even politically favored, because people were looking at the cold war . . . they were watching how people were driving across the border = getting rid of their cash.” He continues: “every craftsman used to have his black money account in Switzerland, yes? That they are criminalized now is= . . ., it was never legal to evade taxes but it was a different social context back then, right?” Tax consultants with a positive view of the past often highlight problems that they now consider typical of contemporary times. The partner of a Big Four accountancy firm complained that, in the past, laws were better crafted and less morality-driven due to the involvement of associations of professionals; today, everything was fast-moving and complex, and legal uncertainty prevailed. Clients have taken more risks in the past, whereby interviewees often considered risk-taking a desired characteristic of entrepreneurial personalities. Furthermore, the partner of a high-end boutique sees advantages in the social negotiation in the past situation. He first describes the interaction between the tax advisor and the financial administration as a negotiation situation in which “subjective justice” is established by two parties agreeing on a price that is subjectively perceived as fair: “Traditionally” it was like this,

“. . . now there is a bit of a preponderance . . . in the financial administration (.) In the past, it was perhaps a bit on the other side, but that is now the function (1), that they demand a hundred and then someone comes and says: but I have ten arguments that it should only be ninety. Then you find yourself with ninety-five . . .

This statement implies, first, that financial authorities today abuse power and, second, that law is negotiable depending on time and power. According to this line of reasoning, the tax administration destroys social peace because it abandons the principle of “subjective justice” and requires compliance with the law.

Broadly speaking, our interviewees showed three typical types of reaction to the legitimacy crisis. The first type indicated being compliant by conviction. This type saw the need to fund the polity, implement infrastructure measures and, in some cases, redistribute moderately. These tax advisors generally stated that they stuck to substance criteria, had the economic purpose in mind first and did not use “artificial constructions.” In the second step only, they would consider how to structure a company for tax reasons. In Particular, self-employed tax professionals and consultants to companies held this view.

The second (larger) group also described themselves as compliant, but justified this compliance with the law with concerns about reputation or fear of discovery rather than with insight. Neither tax advisors nor clients wanted to appear in the newspapers for tax matters, reap a shitstorm, or risk jail time due to more severe penalties. Many tax advisors took the counterattack. The partner of one highly ranked boutique described his own compliance decisions as follows:

. . . there are times when you can go (1) a little MORE (1) or a step further . . . and in some times . . . you stop before the last or penultimate step. (1) all these steps that I am mentioning now are within the law. (1) but there is also to take into account, when interpreting the norm, that it happens, after all, in a social context. . . . everything that is relevant in the design or interpretation of the law lies not only in the law itself. But it is also a question of (1) how does a society perceive the term abuse? (1) . . . in some times, like today, EVERYTHING is abuse (.) that does not involve carrying money . . . to the treasury. (1) And in some times, it was understood much more broadly.

According to this account, the taxpayers do not get their rights because of their consideration for social peace. Other tax professionals, on the other hand, considered abuse as definable and had confidence in the administration and the judiciary. The group of tax professionals who, compared to others, positioned themselves more positively toward aggressive tax structuring, saw themselves confronted with a bloc of the public, politics, financial administration, and media, and in part also lobbies, who would use morality or double standards as a tool to enrich themselves at the expense of high achievers. These tax professionals also accuse their critics of ignorance and envy. They saw a national character, the “sense of justice of the German,” which led to the German economy giving away too much to foreign countries. From the point of view of the critics, the tax professionals thus reverse victim and offender.

As a third response to criticism of tax practices, interviewees showed signs of cognitive dissonance. In his theory of cognitive dissonance, social psychologist Leon Festinger (2012) assumes that people strive for consistency and try to reconcile their knowledge or beliefs and their actions. When new information challenges a person’s behavior, the person may either change his or her behavior, deny the information, or reinterpret the information in a way that does not challenge his or her behavior. This happens, for example, when the person who feels dissonance invokes additional selectively chosen information that justifies his or her behavior or changes his or her opinion about the source of information. People choose the option of adjusting not the behavior but the information especially in situations where a change in behavior would mean a loss, the current behavior satisfies in the short term, or when a change in behavior is not possible due to a coercive situation (Festinger, 2012, pp. 15–42). Actors who in such a situation declare their behavior appropriate tend to relativize or devalue criticism or to justify responsibility with reference to their own lack of decision-making competence, room for maneuver, or a coercive situation (also Aronson & Mills, 1959; Festinger, 2012; for the development of the theory Irle & Möntmann, 2020). This theory, which Festinger empirically substantiates with the behavior of smokers or sect members, seems plausible to explain seemingly contradictory behavior and attitudes of tax professionals in the legitimacy crisis.

Behavior and knowledge or belief diverge in the case of tax professionals especially when there are doubts as to whether tax practices satisfy professional ethical principles and/or widespread claims to legitimacy in society. Most tax professionals were aware that societal expectations of tax ethics were more stringent than professional practices. When asked about their assessment of known legal tax cases (e.g., Amazon) deemed illegal by the public, several tax professionals indicated that they had a professional and a (divergent) private opinion about the case. These interviewees operated in environments where they or people close to them were required to engage in aggressive tax structuring, and in some cases tax evasion, and viewed certain activities of tax professionals as harmful. Although some professionals had had extremely successful careers by conventional standards, they doubted their own actions and saw their own activities as less useful than the work of entrepreneurs, engineers, doctors, or professionals in high-level public service. One interviewee said:

So with some things, you think to yourself, whether this makes any sense, you think, from an economic point of view, what am I actually doing here? On the other hand, I am of course an advisor and help my client to reduce his tax burden. And that’s perfectly legitimate, as long as it’s legal. um (1) if everyone in the industry does it and my client doesn’t, he’s at a competitive disadvantage. (1) Yes, um (1) . . . as a consultant you can ask yourself, where . . . am I involved here, but (.) yes, um (1) I don’t always have to question all my activities, so to speak, whether it really makes sense down to the very last, um, . . ..

Thus, the person questions the economic benefit of his own activity, then justifies it with a reference to interpersonal helpfulness, a positivistic legal attitude that the interviewee declares legitimate, and a coercive situation created by competition. After that, however, he again takes a critical view of his own involvement and denies meaning to his own actions. In the following interview passage, he weighs mandates that he rejected on ethical grounds against another mandate (for a producer of environmentally harmful products) that he accepted despite ecological remorse because professional ethical conventions do not allow him to reject such a mandate.

While some of the tax professionals tried to resolve dissonance, in particular by referring to positivism, others noticed contradictions in their own statements. They justified their own practices by either referring to personal and professional standpoints, attributing double standards to critics (such as politicians not closing loopholes in the law or small people cheating on their tax returns), or associating tax honesty with dumbness. Others described their own room for maneuver as minimal, delegating decision-making power to clients or shareholders, or pointing to their own lack of alternatives for action due to limited job prospects in homogeneous specialized labor markets, or the needs of their own family, to whom they had to offer certain things. Some tax professionals compensate for the perceived illegitimacy of tax planning with other acts positively perceived in society. This is the case, for example, when they promote artists they advise through tax structuring. Although everyone experiences dissonance, due to tax professionals’ activities and society’s changed view of it, some interviewees have shown particularly strong signs of dissonance.

Maneuvers to Dismiss Blame

In general, most tax professionals used certain legitimations to dismiss responsibility. The most important ones are:

(a) Positivism and division of labor. The majority of tax professionals argued in a legal positivist manner. It was the task of the legislator to close tax loopholes. Tax structuring was even a duty and the classic task of a tax advisor. One would have to respect laws and, after all, cannot decide according to your “gut judgment.” A positivist interpretation would protect against despotism. However, some professionals disagreed with this view and urged a stronger interpretation in the spirit of the law.

A professor and consultant of a boutique demarcated himself first and foremost as positivist and against morality, but in the next step passed the moral responsibility on to the client: Tax consultants have a

. . . mediating function between the state . . . and taxpayers, and their task is also to help the taxpayer. (.) but just within the framework, (.) there we are again with legal and legitimate, yes, but don’t come with morals or the like, that doesn’t exist. but . . . to take advantage of that, and if you take on THE task (1) that is already more than enough.

The tax professional also complained about a “general prejudice against tax consultants,” who are considered “evil,” but in fact have “no bad reputation among clients.” “You can’t seduce clients if they don’t want to be seduced.” Some tax professionals, especially those who do tax planning, emphasize their role in the division of labor, which makes them stand out as a counterweight to the tax authorities and leaves them little room for maneuver to do otherwise. They position themselves as clever advisors as a counterpart to smaller advisors, the “forest-and-meadow,” “BMW-tax advisers” (i.e., advisers of bakers, butchers, hosts) or the “bread-and-butter business.” From this point of view, they are only compliant due to a lack of occasion and often do not have the courage to take on the tax authorities.

(b) Pressure from global markets: Some tax consultants mentioned the pressure of market mechanisms on tax consultants: The “market looks at tax rates, donors deliberately put money in” and expect a certain return. They would compare tax rates with those of competitors. However, interview partners attributed such pressures primarily to publicly traded companies. Other tax advisors spoke of competitiveness with competitors. Many, however, seemed to have some leeway in structuring and wanted to ensure a publicly defensible tax rate because of their reputation or to avoid other problems with tax issues.

(c) Taxes are unnatural: Many interviewees saw it as an unquestionable truth that everyone would optimize taxes if he/she were able to. Taxes, on the other hand, interviewees portrayed as something artificial. “There’s no tax law in the jungle”—was the statement of the partner of a boutique. In contrast, taxes disrupt the balance of the market if they are not designed in an “investment neutral” way. Interviewees frequently used path metaphors in which they depicted tax law with a jungle, considered difficult to navigate and dangerous in the collective memory. In the words of one interviewee:

. . . one helps to find one’s way, so to speak, in this jungle, but precisely there are certain guard rails to which one is guided, things that are just not possible, (.) to then just find a way that grants the best possible result without risks, (.) or at least risks that cannot be calculated.

Another interviewee said she could choose the shortest path—the tax structuring—and she would not be forced to take the dumbest path and pay more taxes. The partner at a Big Four accounting firm compared tax planning to a vacation trip, which, after all, anyone would plan.

(d) Downplaying (game and ambition): Another justification pulls tax design down to the level of game and justifies self-executed designs with ambition. In particular, female tax consultants reported that they designed aggressive constructions when they wanted to test or demonstrate their skills.

(e) Threat: Tax professionals sometimes pointed out dramatic potential consequences that would occur if they did not structure taxes or if regulation became stricter. These included the departure of wealthy investors and the relocation of companies or the “siphoning off of data” by China or authoritarian states. For potential kidnapped and threatened rich clients, tax professionals had to set up structures so that these clients could hide their assets from the public. At the same time, however, the interviewees emphasized that some degree of basic tax funding and redistribution was necessary for the sake of social peace. In the words of one interviewee:

It . . . is ideologically right to redistribute (1), because I don’t want to lock myself up (1) . . . with my rights and so, as in America, no one climbs over a fence, but I would like to live without a fence, but that means that those who don’t want to do so much, can do so much, should do so, for whatever reason, MUST have a MINIMUM of (1) . . . economic and human security.

However, distribution must remain within the measure, since the majority must have also the continuance of the entire system in the eye. A tax professional sees economic prosperity endangered by excessive tax demands:

. . . you can’t kill the horse that pulls the cart out of the mud. yes, the tax officials know that, too, (.) uh, or the decision-makers there. yes, you also need someone to pay for everything and if you pester him too much, (.) to put it very simply, he’ll be gone at some point. Either because he’s broke or because he’s doing business somewhere else, where the conditions are more favorable. (1) that is then . . . the tax competition.

Like many other consultants, she contrasts the entrepreneur with the state, which cannot handle money and wastes it. Moreover, she says, the majority has lost interest in entrepreneurial activity. It is primarily concerned with security when it comes to taxes and other issues. Some interviewees, especially those defending aggressive tax planning, used Nazi analogies to invalidate criticisms of tax design.

In general, it was noticeable that interview partners frequently responded by defending and counter-attacking even to neutrally posed questions. For example, various professionals responded with chains of over ten justifying arguments to the question about the definition of tax structuring. This indicates an awareness of the legitimation problem.

Tax Advisors’ Reference to Societal Benefits and Core Values: Ideal-Typical Core Values

As shown under 2), professions owe their special status to the reference to socially recognized core values. Tracing the interviews back to central recognized basic values resulted in the three ideal types: Type 1) The liberal; type 2) The elitist-value-based shaper; type 3) Benefits for the business location.

Type 1: The Liberal

Strictly speaking, the main feature of this central value is to strengthen an order with as much freedom as possible. Only one of the interviewees represented this goal in a rudimentarily consistent manner: The interviewee stated that he represented his clients in court and vis-à-vis the tax office even in critical cases and wanted to limit interventions in assets above a certain proportion. At the same time, he was in favor of greater redistribution and criticized a two-tier tax system that favors people with access to legal advice. The interviewee was particularly concerned about the erosion of democracy with the help of private legal tools:

. . .What I find quite problematic from a legal-theoretical point of view is this tendency to make one’s own laws, which is of course connected with a lot of money and large corporations. And that’s not only the tendency to make one’s own tax laws in the past, but also to try to do so now, and to find it legitimate . . ., that has spread from there to other areas as well, spread to other areas. So, I also have the feeling that basically . . . this arsenal of weapons that has been . . . developed . . . within management consulting is also being applied to other areas.

This applies, for example, to Amazon’s general terms and conditions, which are “completely self-created law.” This could lead to a conflict, for example because of forgotten tax payments on an e-book publication in a third country, being settled before an arbitration court in Delaware according to the law of the state of Washington, to the exclusion of all other courts. The interviewee sums up:

as if you don’t belong to the democratic society at all. Those are the others, they vote, the stupid idiots, we just do it for ourselves. And they can do it. . . . Of course, a few deputies can’t stop something like that. . . . but I find it downright creepy how people like that rise up to some super race, eh, and do their own thing.

The interviewee was one of the few tax professionals who criticized his own profession for stretching the law via legal positivist interpretation. He also saw a connection between parliament’s right to budget and democratic representation; there was a “very clear connection between being a citizen and paying taxes.” This interviewee, owner of a small law firm, however, interpreted the liberal much more broadly than others. Most professionals who identified themselves with the liberal lived it out selectively.

The selective-liberal viewpoint positions itself primarily against the state as an intrusive entity that endangers freedom. However, freedom stops where practices of tax professionals are challenged. Selective-liberals do not perceive phenomena of unequal access to resources, and thus indirectly also to justice, as an encroachment on freedom. Tax professionals who argued in selective-liberal terms were partners in boutiques, accounting firms, a fund, and advisors to a bank. The partner of a high-end boutique described his understanding of the liberal as follows: He had been educated in such a way

. . . that legal protection differs from dictatorship in that . . . in a constitutional state even Adolf Hitler is entitled to a just and fair trial. . . . and there is no compromise there either. . . . and that is with these easy prejudices and with the justification, whom one may represent today and whom not, what is ethically right, what is ethically not right . . ..” In tax law, “the opponent is always the state. (1) or the community” which is why one “easily gets the . . . smell that one does things that would actually be unethical.

Furthermore, he states that helping clients to pay the lowest tax burden is perfectly legitimate, while he compares criticism of this activity to a contrived demand that lawyers should not represent Jews or Gypsies in court. In the sense of positivism, the only thing that matters is what is legal. The liberal here, then, consists in representing the interests of a client in the positivist understanding of law, even if this contradicts widespread ethical ideas or the spirit of the law. In the view of the interviewee, a person who takes the legal profession seriously is systematically at risk of coming into conflict with the community.

Another selective-liberal position places a stronger emphasis on market order enforcement, perceived as a natural system, and on self-government in the sense of private use of funds or elements of direct democracy. One interviewee, who is against “everything being regulated by the state” and is “more in favor of individual self-responsibility,” moved to Switzerland for self-tax reasons. He singled out the country as a role model: In the tax system, cantons and municipalities would act “like a small company”; they could also manage for themselves. Municipalities are very transparent in financial matters and send citizens a detailed balance sheet of their budget planning, which ensures that taxes also have an extremely high level of acceptance there. The partner of a boutique found the taxes far too high and the expenditures too little transparent. He asked,

. . . wouldn’t it be more reasonable that you leave it to the people [the tax money] and the people will spend it somehow, . . . that you trust the population more, that they know what they can do with the money. Yes, why . . . you automatically assume that the government is a better owner of the money than the person who earned the money.

Beyond this, however, the interviewees seemed to have little engagement with forms of representative and direct democracy or self-organization, citing entrepreneurs as role models who stand precisely for hierarchical contexts. Here, they also use the value “liberal” selectively.

A third frequently encountered argumentation of selective-liberal tax professionals invokes market efficiency, linking it to the complexity of tax systems. Representatives of this school of thought argue that the legal system is distorted and that the German tax system is far too complex because politicians overload tax law with their political projects that they cannot implement otherwise. Interviewees explained this hypothesis in many interviews with a topoi, the tax benefit of nurses’ night and vacation allowance. The partner of a Big Four accounting firm said:

. . . the payment is not adequate or not fair, so we try to . . . because we say that working at night is a special burden, which should then also be subsidized with certain allowances. In principle, this is an intervention in the market mechanism. . . . A simple fair debate would be to say that we will do everything the same way. There are no allowances. . . . then of course they would lose these control mechanisms . . . [if] . . . we’d say we’re doing away with all the allowances, there’s no more nighttime allowances, then the garbage cans would be burning outside.

According to a widespread concept, tax systems distorted in this way are not “investment-neutral,” so that the bottom line is a worse economic result. Lawyers emphasize that complexity creates tax loopholes, which tax avoiders then exploit. A flat-tax model with a maximum tax rate of 25% developed by Paul Kirchhof, a controversial tax law professor among tax professionals, should provide a remedy. In political discourse and in the 2005 election campaign, the Christian Democratic Party (CDU) and liberals touted the model as a beer coaster tax that would make life easier for citizens. The CDU’s election defeat, in which the beer coaster tax branded as unfair by the opposition played a major role, is seen by the proponents interviewed as an indication that the implementation of a systematic tax system is not possible in the German political system. The tax professional continues:

. . . in the present time, we have constantly anyway some elections, some regional elections, where something . . . everything is influenced, . . . because naturally then many come immediately also with particular interests naturally . . . so that’s why I think that was more in the sense of a reality check. is that really [not] realistic . . . the beer coaster tax.

Thus, in this sense, elections and related political decisions are seen as impeding the implementation of a system that professionals perceive as optimal to radically implement legal systematics and market efficiency. Here, selective liberal thinking ultimately points in the direction of expertocracy.

Type 2: THE Elitist Value-Based Design of Society

A second core value that professionals used to justify their activities was an elite value-based activity for the good of society that went beyond the narrow function of the profession. Among interviewees, this type occurred among a few tax professionals who advised wealthy individuals and artists. In professional activity, these professionals weigh different values, where good deeds of clients can compensate for tax structuring, or tax optimization is allegedly not relevant for this group. Representatives of this group, in contrast to the utilitarian third type (see below), also refer to non-business ideals such as environmental protection, equality or political freedom, or to universal values. For this clientele, tax optimization is less of a concern. The partner of an accounting firm explains:

Among the younger customers, the sustainability issue is coming up massively, so what we see from Fridays For Future is for me a very broad movement that is now taking to the streets, but there are definitely asset holders, I say mid-twenties to late thirties, who . . . are thinking about how they can use their assets wisely. So, achieving financial returns, some of whom have very high assets, [is] not the first goal . . . rather, it is to do something meaningful, sustainable, in quotation marks, with the assets, most of which have been inherited.

This clientele also invests heavily in social impact bonds, he said.

An important reference of this, but also of other interviewees, were families and family businesses, which, compared to politics or listed companies, have longer planning horizons and were less influenced by voters or shareholders. The tax professional explained that a principal or family is

interested in the well-being of the business over the longer term, after all, and in some circumstances, the family. So that’s a bit more long-term thinking and they have a different risk profile, yes, so today many board members or managing directors are aiming to be (.) . . . compliant and don’t take any risks at all, whereas an entrepreneur or a private person who owns assets thinks about the risk and up to what point . . . am I prepared to bear this risk under certain circumstances.

According to this statement, family entrepreneurs engage more in aggressive tax planning than listed companies. A longer-term corporate policy may compensate for more aggressive tax payments. An ethic of their own also seemed to be above the law to some extent for this and other elite-value-based arguers, even if on the other hand they identified with the democratic system. The interviewee had an ambivalent attitude toward the state, flirting at the same time with his efforts to help shape the national economy in terms of economic development at the highest level, as well as with anarchism:

. . . and I’ll be frank, I have an anarchist vein, and what do we tax consultants do? We deprive the state . . . of the money it is entitled to, so I said somewhat flippantly that I would like to become one of the best-paid anarchists someday, yes?

The interviewee illustrated his attitude to rules with his behavior on the road. He himself complies with rules only if they fulfill their purpose, he also drives faster or slower than permitted if the situation requires it, while “. . . Germans are very obedient to authority” and believe every sign that is erected somewhere. This must be questioned “already sometimes and interpreted to a certain extent. So, this is my form of anarchism, so very mild; <<laughs>> not so much to do with throwing stones. . ..” The interviewee, who elsewhere invokes legal positivism, ironically argues here for interpretation in the spirit of the law. Positivism is effective in this example when it comes to the professional activity and interests of clients, while in other cases the interviewee devalues legal positivist road users for understandable reasons.

In addition, this and other tax advisors use ethical or their own criteria when selecting clients. Exclusion criteria mentioned by interviewees were behavior perceived as unethical from an interpersonal point of view, such as the use of legal instruments designed to cause harm in a dispute between spouses, right-wing extremist activity, the operation of nuclear power plants, pornography, or financial products judged illegal, such as CumEx-transactions. Analogous to the selectivity of liberals, tax professionals seem to make a selective ethical-elitist reference to core values here, especially when these justify their own activities.

Type 3: Benefits for the Business Location

The third central value of tax professionals, who I call “utilitarians” here, is to provide a benefit to the competitiveness of the location. Unlike liberals, they are not concerned with following market rules or tax law dogma. Rather, location policy, the appropriate level of taxes, state structural policy and a moderate distribution policy are what count. In contrast to egalitarian, leftwing or radical left-liberal concepts, utilitarians are not primarily concerned with equitable distribution in the sense of equality of opportunity or equality. Utilitarians accept injustices and inequalities if this promotes the location in global competition and if the majority benefits from this situation. Utilitarians, however, also distanced themselves from the rich who did nothing for the benefit of the location and only inherited, for example. The group of tax professionals belonging to this category was particularly large. In particular, this included corporate tax advisors and advisors from medium-sized accounting and tax consulting firms and banks, but also partners in boutiques.

Utilitarians are in favor of taxes that are beneficial to an economy and guarantee location advantages in the long term in the sense of a high road strategy. The tax advisor of a bank described the basic attitude directed at the economic benefit as follows:

You have to look at it from both sides, so to speak, that is, on the one hand, how much tax can you levy at all in international competition without those who can leave then going somewhere else and paying less tax, and on the other hand: . . . how do we actually want to live here, (.) what—in quotation marks—prosperity or luxury, what welfare state, do we afford, what infrastructure?

Due to the tax surpluses of recent years, the question arises: “either we do something great with the money or we give part of it back by cutting certain taxes. . . . One could think of corporate income tax, to use it to stimulate the economy.” In the following, he suggested the relief of the middle. One could promote “certain industries or invest a lot in education . . . the people, that is what makes Germany, engineers, academics . . ..” In addition, the small incomes should be relieved, “. . . there you would have to set incentives to make work more attractive in general . . . perhaps also to make it clear that . . . this gainful employment, that it is worth it, or that it is also interesting from a tax point of view, so as not to punish the wrong people.” Thus, the professional does not first ask what is necessary (e.g., investment in environmental policy) or what is just, but chooses tools that primarily promise economic prosperity.

Utilitarians typically advocate a high-road strategy that takes location competition seriously while responding with policy coordination. The partner of a boutique says:

. . . it is unfortunately a fact that states compete with each other for tax bases. And they do so brutally. So . . . you don’t have to have any illusions . . . Now we are relatively far above . . . the large companies are virtually pushed abroad, so if you describe it that way, . . . it would make sense that within the framework (.) of the EU we agree on a minimum tax rate . . ..

Therefore, politics should stop tax competition in an internationally coordinated manner. At the same time, the interviewee considers the economic effects of German tax policy from the perspective of international location policy.

He criticizes that, in Germany, people without inheritance hardly manage to save start-up capital for a business start-up, because taxes on small incomes are relatively high. He continues:

. . . if you look at who has become a billionaire here, there are not so many. Everything is (.) . . . highly concentrated . . . Most of them inherited it. << knocks on the table >> and in the USA we actually have entrepreneurship, where people manage in their own generation to. . . To get to the top like that. . . . Capitalism lives from this possibility, this dish-washing story, so to speak, and we’re not very good at that in Germany either. . . . we are not a particularly permeable society. . . . and tax law plays its part in that.

The tax professional fears that “our dynamism in society” is declining and worries, as do other interviewees, that there were more founders in previous generations than there are today.

Most utilitarian tax professionals also agreed that family entrepreneurs who think in the long term should be exempt from wealth taxes, even if this is actually unfair in terms of distribution policy. The consultant of a medium-sized consulting firm put it as follows:

. . .when I always hear the discussion, yes . . . Mrs. Klatten gets three-digit millions every year as dividends from . . . BMW, and (..) . . . Kühnert [a Social Democratic politician] . . . he was ranting and raving. (..) The BMW works council (..) really got in his face and said: we’re glad that we (..) . . . have investors like Mrs. Klatten. We’re glad that we have investors like Mrs. Klatten, because (.) when we talk to her (.) she understands, first of all, (1) that employees are paid reasonably here in Germany. She also has no problem saying that the dividend will be much lower because of this or that investment, . . . because this is not a pension fund that immediately wants to take a hit, . . . there is pressure (.) for . . . a regular and preferably increasing dividend, and they do not have that with investors like the Quandt family. . . . and << knocks on the table >> . . . we can go and tax as we want. . . . or almost tax as we want. then she moves to Kitzbühl [Austria] << knocks on the table >> that’s a few kilometers over the border and, . . . then . . . there is no inheritance tax, then there is no property tax, then you have nothing at all.

The tax professional thus points out the structural advantages of the legal form of family businesses compared with listed companies, and emphasizes the benefits of the corporatist system for many stakeholders. He also opposes measures that, driven by claims of fairness, would destroy these benefits.

Further interviewees criticized administration and the complex tax law, which would waste resources. Tax consultants had the impression that they do not do any productive work themselves. A person said she was “sometimes extremely tired” of having to waste her time and expertise “sometimes on crap like this, where I say there’s nothing in it for the national economy.” This is particularly critical when the state wastes taxpayers’ money, she said. In addition to many other tax professionals, however, she is critical of the tax relief for family assets of large inheritances in terms of incentives to work. The extensive tax exemption of corporate assets leads to large fortunes simply accumulating and passing to generations “that have actually done nothing,” while craftsmen are highly taxed: “there you almost become a social democrat.”

Summing Up: Shifting Values

Tax professionals clearly perceive the legitimacy crisis of tax structuring and largely date it to the period after the turn of the millennium or after the financial crisis that began in 2007. As a rule, they now pay more attention to not getting into conflict with the law or with authorities and to complying with requirements. However, most of them do not make this certain turn toward more compliance out of conviction, but out of fear for their reputation or of punishment. While some welcomed substance criteria for tax designs and generally saw the need to generate taxes for a community or society, some tax professionals also seemed to pine for the good old days when they had a free hand and when hardly anyone confronted them with morality claims.

Tax professionals justified themselves conspicuously extensively, invoking positivism and division of labor, the pressures of global markets, a tax avoidance instinct inherent in human nature, trivializing aggressive tax avoidance, or imagining terrible potential consequences of not structuring taxes. A correlation between business model and core value is appearing. Tax professionals from contexts to which creative and aggressive tax structuring are attributed are found in the camp of selective-liberal core values, those with access to very wealthy clients or artists represent elitist-shaping values, and those from business consulting tend to have utilitarian core values. In the current crisis of legitimacy, we were able to identify three types of core societal values that tax professionals associated with their activities. While representatives of the (1) selective-liberal core value are largely critical of development, the (2) elitist-value-based shaper and (3) economic benefit types attempt to bridge the gap to criticism that legitimizes tax design. While selective-liberals seem to resist change and rhetorically mobilize against it, the other types seem to be looking for a better fit with societal values.

Conclusions: From Value Avoidance to Framework Setting

Compared to studies on tax advisors in a crisis of legitimacy from the Anglo-Saxon world, we surveyed the tax advisory industry in Germany on a broader scale. This revealed that tax consulting encompasses a broad range of activities and different groups of tax professionals have different views on compliance and practices in dealing with gray areas of the law. In the studied case, commercial, regulatory and moral logics (Radcliffe et al., 2018, pp. 51–52) balance in a specific way that has both similarities to and differences from the Anglo-Saxon and French situations of tax professionals in the legitimacy crisis that we studied. All tax advisors use moral arguments and refer to core societal values that they associate with the goal of their professional activity. These core values are either (a) selective-liberal values, through which civil rights and market institutions are to be enforced against the state; (b) elitist value-based shaping, which draws cross-references to other crises (e.g., the environmental crisis); or (c) the national economic benefit as a community project.

In the case of tax advisors focusing on the German case, the crisis of legitimacy has led to a stronger regulation of the profession, whereby the professionals at the time of the interviews seem more driven than formative and use various justification tactics. Interestingly, in our case, we find similar debates about positivism (Radcliffe et al., 2018) and the complexity of tax systems and tax systematics as in the U.S., with the goal of introducing a flat tax and justify aggressive tax structuring (Ventry, 2002). Thereby, many studied tax advisors regard the complexity of the tax system as a genuinely German fate. Regulations seem to work and influence the work of tax professionals to an appreciable extent. In the examined context, tax professionals juxtapose expertise and morality, they take the moral discussion seriously and fear moral-driven regulation. To a certain extent, this indicates the effectiveness of moral arguments. On the other hand, we also observed strategies of framing or reframing (Suddaby & Greenwood, 2005, p. 39), although the frames of the German and other contexts varied slightly. Common to all contexts, however, is a tension between the commercial and value-based contexts of the profession, with professionals preferring to reframe in such a way that values justify activities with a commercial goal perspective. However, commercial interests may go hand in hand with compliance, presupposing that business models and policy frameworks allow for it. Tax professionals have scope of actions and may chose compliant business models. Although some tax professionals have credibly asserted that they have accepted disadvantages for compliance, it usually seems easier to selectively access core values that are in line with the business model and to creatively shape these values. Cynicism, aggressiveness, and a variety of violent metaphors that selectively liberal-minded tax professionals have used suggest that this direction now has little social support for its practices. Thus, tough regulations and competing frames can plunge old justifications into a crisis of legitimacy, so that their appeal fades. Not even a professional redistribution project disguised as a coaster tax prevailed. However, strengthening the business location as a common project, but going beyond market and competition-based arguments of the UK context (Addison & Mueller, 2015, p. 1279), seems to connect to values that are still legitimate. Equating the benefit of the company with the benefit of society is widespread, and the benefit of the national economy is often set as a legitimate goal. As this paper has shown, the dynamics of tax professional’s behavior and values, and thus their impact on society, is complex and driven by different interests, self-justifications, and core values. Understanding the consequences for successfully regulating the profession and improving the tax system and the regulatory framework of the profession in order to reach socially beneficial goals, or to put it simply: progress, cannot ignore these if it wants to be more than just a “pendulum” swinging between less and more regulation.

Footnotes

Acknowledgements

I would like to thank my interview partners for the valuable insights they provided, Simone Polillo, André Vereta Nahoum, Richard Hule, and the anonymous reviewers for their further suggestions and critical comments and to my student assistants Stephanie Buchholz and Fabian Lochner for their contributions on the project.

Declaration of Conflicting Interests

The author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This paper is part of the project “Tax Design as a Profession” (project number 418216288) funded by the German Research Foundation (DFG).

Directory of materials: List of interview partners

Preliminary interviews with experts:

E1a and E1b: Staff members of members of parliament (Left Party, Christian Democrats, Finance Committee)

E2: Former employee of the BMF, advises auditing company

E3: Representative of a civil society organization, former employee of an auditing company

E4: Professor of business administration, focus on corporate taxation

E5: Representative of civil society (ethics in finance), formerly working in the banking sector

E6: Professor of business administration, tax law

E7: Professor of tax law

E8: Professor of finance

E9: representative of a think tank (business ethics), former professor

Professionals:

P1: Partner in an accounting firm, business administration, upscale private clients.

P2: Self-employed tax consultant, advises private individuals and small self-employed persons

P3: Fund manager

P4: Tax consultant of an accounting firm (apprenticeship, studies)

P5: Tax director of a group, previously auditing company, business studies

P6: Tax consultant of an auditing and consulting company, lawyer, advises mainly medium-sized businesses

P7: Tax consultant, self-employed, advises auditing company, business administration, previously auditing company, advises mainly medium-sized businesses and upscale private clients

P8: Professorship for business administration and tax law and work for a tax consulting firm, previously auditing firm

P9: Partner in an auditing firm, focus on corporate taxation

P10: Partner of a renowned tax consulting firm, honorary professor, focus on corporate taxation

P11: Tax consultant and head of department of a large medium-sized company

P12: Partner of a business and tax consulting firm, lawyer, also US tax law

P13a (double interview): deputy head of the tax department of a bank, tax consultant and lawyer

P13b (double interview): Head of the tax department of a bank

P14: Division manager of a bank

P15: Self-employed tax consultant, small business and private clients, business studies

P16: Tax consultant, private bank, lawyer

P17: Head of tax department, DAX company, tax consultant, previously auditing company

P18: Head of a tax office

P19: Partner in a medium-sized tax consulting and auditing firm, professor, chamber official, business administration

P20: Tax consultant, partner, lawyer of a tax consulting firm, also US tax law, previously auditing firm and ‘Magic Circle’

P21: Lawyer, previously financial administration

P22: Partner of a renowned law firm, lawyer for tax law, honorary professor

P23: Tax judge, financial economist, lawyer

P24: Partner in an auditing and tax consulting firm, Member of the Bundestag

P25: Professor of tax law, financial economist, lawyer

P26: Senior manager of an auditing company, previously court of law

P27: Trade union representative, tax policy area

P28: Representative of the tax administration

P29: Lawyer, specializing in inheritances, foundations

P30: Partner of an accounting firm, tax advisor, lawyer, previously court

P31: Lawyer, judge of the Federal Constitutional Court, Federal Fiscal Court, honorary professor

P32: Self-employed tax consultant, business administration, advises mainly artists

P33: Partner in a business law firm (“magic circle”)

P34: Lawyer, represents whistleblowers

Author Biography

Silke Ötsch is a researcher at the Sociological Research Institute (SOFI) at Göttingen University and visiting professor of sociology at the University of Hamburg.

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