Actorhood and Authority

Taxation is understood from a range of disciplines that carry different assumptions about how actors operate, how they make claims to authority, and what level of analysis is appropriate in explaining the drivers of behaviour. As such, studies of taxation operate in an interdisciplinary arena. However, these differences confuse scholars and practitioners trying to get a hold on the literature.

For this reason, this section provides a basic framework for ordering and identi-fying studies based on assumptions about actors, authority, and scale of analysis, before giving examples of studies and approaches.

The disciplines that have a serious grasp of tax matters include economics, accountancy, law, political science, management studies, and sociology. Within these scholarlyfields, there are strong assumptions about how actorhood and what drives actors’behaviour. As such, how actors operate across scales and how they make claims to authority are important to clarify.

Figure 2.1 depicts common assumptions about actorhood that correspond to thefields noted in Figure 2.1. The most obvious starting point can be found in economics where actors are considered rational economic agents who seek to maximize their interests. Governments aim to create tax systems that optimally provide welfare provisions for the least cost (Diamond and Mirrlees 1971). Such theories of actorhood and taxation have continued to develop, increasingly with a view that taxation as a‘system of coercively collecting revenues from individuals who will tend to resist’(Slemrod 1990: 157). A similar view of actors asrational political agentscan be found in political science. Margaret Levi’s (1989, pp. 8–9) masterwork on taxation argues that‘individuals calculate the costs and benefits to themselves of various actions they are considering and then choose the alternative most consistent with their fixed preferences. I then post that rulers maximize

BOUNDED RATIONALITY

revenue to the state subject to determinant constraints on their behaviour’. The system of tax collection and willingness to pay is one of‘quasi-voluntary compli-ance’ (Levi 1989). Individuals game the system and the state is responsible for ensuring that the game has some rules.

A departure from the rational view can be found in more sociological works on taxation, which stress howactors are bound to normative environments. While the influence of cultural attributes is certainly integrated into some rationalist accounts (Lieberman 2003), the view here is that attitudes and behaviour towards tax issues are saturated with normative predispositions. Such work can be found in ethnographic studies (Björklund Larsen 2017), as well as in the ‘new fiscal sociology’that stresses not only political pacts but normative alignments in path dependencies associated with taxation (Prasad 2005; Martin et al. 2009).

Figure 2.1 also suggests a number of overlaps. We have a range of theories where characteristics of actorhood can be found. First of all, theories ofbounded rationality abound in the social sciences, stating that actors are rational within limits (March 1978; Simon 1979). Such insights have been applied to taxation, demonstrating that protest can occur over seemingly small tax increases that break with established settlements (Kato 2003). Work on domination demon-strates how dominant political actors can establish normative environments in which their claims are normalized and socially accepted, which then accentuate their power. Examples from inheritance taxes and property taxes in the United States provide good examples of this kind of research (Graetz and Shapiro 2011;

Martin 2015). Finally, the literature on satisficing places more emphasis on the psychological dimensions of choice and when actors are willing to settle (Simon 1990). Such work has informed more experiment-based work on willingness to pay taxes (Fairbrother 2019). The point here is that the overlaps provide points of debate for discussion on how actors respond to stimuli in their social structures as they deal with issues.

The same can be said for theories of authority. Figure 2.2 presents these in the same manner as Figure 2.1. First of all, assumptions about authority in economics are commonly based on the rule of law to protect and defend contractsand/or claims to dominance over practices and prices frommarket share. The obvious sources here are scholars who draw on a range of economists from those viewing contracts as the basis for market activity (such as Hayek) to those who view contracts as enmeshed in social relationships (such as Commons and Veblen). On taxation, the authority of law is assumed, with deviance from it being of interest (Slemrod 2007). The provision and defence of property rights are critical to the establishment of state capacity in tax systems (Besley and Persson 2009). Research on the international economics of tax avoidance, tax evasion, and money laundering has concentrated on how authority is enforced through law, matching legal determinations (criminality) to modelled estimations of economic activity (Walker and Unger 2009). Given the strong assumptions required for such

research, critics have asserted that it is based on ‘highly questionable high-end guesstimates based on heroic assumptions and extrapolations’ (Levi et al. 2018, p. 311). Still, the principle here is that authority is derived from the rule of law.

Second, research in political science typically views authority as linked to those actors that have theformal institutional mandatefor the issue in question, or those who can credibly assert their authority. Here the authority of the state is kept, more-than-less, in check by its citizens (Timmons 2005), in accordance with the

‘quasi-voluntary compliance’ basis of actorhood described above. What can be taxed is not only a matter of enabling laws but making difficult political choices over redistribution (Buchanan 1987). As such governments need‘political will’to assert their authority and reform tax systems in compliance with the world’s best practices (Tanzi and Zee 2000). Citizens expect political representation from formal authorities when they pay taxes to them, though this has not always been the case in how state capacity has been built (Boucoyannis 2015). More recently, scholars working on tax have viewed state-based authority claims as contingent on their relationship to other actors in the ecosystem, including

‘stakeholders’such as civil society and corporate groups. For example, Genschel and Zangl have noted how the state has changed from ‘virtual monopolist to manager of political authority’(Genschel and Zangl 2014).

Third, work in sociology often makes the claim that authority is constructed within a normative environment, with actors making claims to legitimacy based on a formal-rational, charismatic, or traditional basis (Weber 1978). On taxation, there is a vast literature on howfiscal systems underpin state capacity (Tilly 1975;

see Martin and Prasad 2014), including how these systems are integrating into international trade (Hobson 1998) andfinancial systems (Seabrooke 2006). Given these studies, the common view is that social groups compete and cooperate over tax issues, with national cultural differences helping to explain the outcome.

PATH DEPENDENCE

Figure 2.2 also identifies a number of overlaps. First here is the volumes of work onpath dependence,which makes the point that institutions are likely to follow the track established by pacts, agreements, laws, and formal mandates—that institutions are hard to change—is the default position of most contemporary political economy and economics (Pierson 2000). Incidentally, the concept is also central to‘new’ and historical institutionalism in sociology, where the mechan-isms of institutional change and stability are central research questions (Padgett and Powell 2012; Greve and Rao 2012). On taxation regimes, the notion of path dependence has been applied in explaining the differences between national systems (classically: Steinmo 1993), as well as for the adoption of common forms of tax, like value-added taxation, across polities (Helgason 2017).

The literature on how markets are made, market makers, points to how claims to authority take place within organizational fields, with prominent firms and actors using their position to secure normative environments in which particular laws and market share are protected (Fligstein 2002; see more generally Fligstein and Dauter 2007). On taxation, the most relevant scholarship here has concen-trated on how the Big Four global professional servicefirms in accounting and auditing have established their market share through rhetorical claims to legitim-acy and thus authority (Suddaby and Greenwood 2005; Murphy et al. 2019). The social relationships that underpin such claims, and how they lead to certain types of behaviour in the treatment of tax issues across multiple jurisdictions is also studied in the budding ‘global wealth chains’ literature (Seabrooke and Wigan 2017).

Finally, work that overlaps between organizational sociology and political science points to how actors actively seek to cultivate acommon senseto shape standards and regulations (Strange 1988). Such actors are not only from formally mandated institutions but are active in fostering networks where common sense can be transformed. This approach has been explained in more‘hegemonic’and

‘institutionalist’ forms on tax issues, with the former drawing on Gramscian critiques to locate the authoritative common sense of taxation within inequality dynamics (e.g. Pascale 2008) and the latter focuses on how professional networks encourage a common sense among policymakers in how they make claims to authority over how tax policy is scripted (Ban 2015; Kentikelenis and Seabrooke 2017; Seabrooke and Wigan 2016).

If we want to understand changes in the international tax ecosystem, there will not be agreement among scholars on the prevailing forms of actorhood and authority that dominate. Instead, it is important to provide an approach that is sensitive to claims about authority being made to support or justify changes.

What needs to be understood from an interdisciplinary perspective is how forms of actorhood and authority exist within what we can understand as an ecosystem. The emphasis then lies on identifying forms of actorhood and how claims to authority are being made. By being sensitive to this rather than

closing down permissible forms of actorhood and authority from disciplinary assumptions, we can gain insights into how the international tax ecosystem is transforming.