Governance, tax and folk tales

Description
This paper develops a particular narratological approach to analyse a common category of
narratives: individuals’ accounts of their organization’s context and purpose. In two phases
of interview research with 45 senior UK accounting professionals (tax officials, tax advisors
to, and tax directors of, multinational companies) we focus on a pivotal period in the governance
of UK taxation. We advocate analysing what ordinarily could be called ‘real world’
narratives about this context (‘tax tales’) as if they were folk tales. This approach draws on
an influential analysis of folk tales by Propp. Our theoretical contribution is to show how
features of strong or dominant plots, of the kind that structure folk tales, also help accounting
professionals to make sense of this complex governance environment

Governance, tax and folk tales
Kevin Morrell
a,?
, Penelope Tuck
b
a
Warwick Business School, University of Warwick, United Kingdom
b
Birmingham Business School, University of Birmingham, United Kingdom
a b s t r a c t
This paper develops a particular narratological approach to analyse a common category of
narratives: individuals’ accounts of their organization’s context and purpose. In two phases
of interview research with 45 senior UK accounting professionals (tax of?cials, tax advisors
to, and tax directors of, multinational companies) we focus on a pivotal period in the gov-
ernance of UK taxation. We advocate analysing what ordinarily could be called ‘real world’
narratives about this context (‘tax tales’) as if they were folk tales. This approach draws on
an in?uential analysis of folk tales by Propp. Our theoretical contribution is to show how
features of strong or dominant plots, of the kind that structure folk tales, also help account-
ing professionals to make sense of this complex governance environment. This helps us
understand personal projects of sense making in a context that is technically, legally and
morally complex and has implications for governance, for policy, and for accounting as a
professional project.
Ó 2014 Elsevier Ltd. All rights reserved.
Introduction
We use narrative analysis to study a recent, pivotal per-
iod in the governance of taxation in the UK. Our contribu-
tion is to show how a Formalist approach to narrative
(explained in depth below) helps us understand personal
projects of sense making in a context that is technically,
legally and morally complex. In doing so, we provocatively
advocate thinking about what ordinarily could be called
‘real world’ narratives about the governance of taxation
(‘tax tales’) as folk tales. This leads to novel insights be-
cause by invoking the structure of the folktale we move be-
yond considering the content of a narrative, the ‘story’, to
re?ecting on how that content is organised, the ‘plot’ (a
distinction that can be traced as far back as Aristotle’s Poet-
ics and Rhetoric; Morrell, 2012). This approach concen-
trates attention not simply on the component parts of a
narrative, such as the events that are related, but on the
relationship of these components to one another and on
their role within the narrative as a whole.
Our theoretical contribution is to show how features of
strong or dominant plots (Czarniawska & Rhodes, 2006); of
the kind that structure folktales (Propp, 1928), also help
accounting professionals to make sense of this complex
governance environment. This has implications for how
we understand accounting as a professional project. We
extend understanding of narratives as sense making pro-
jects by detailing the role emplotment plays; where emp-
lotment is, ‘introducing structure that allows making
sense of the events reported in a narrative’ (Czarniawska,
2012a: 758). The paper begins with a brief account of the
broad theoretical context of work on narrative in organiza-
tion studies, moving to a more detailed consideration of
Propp’s Formalist framework, and introducing the idea of
emplotment (White, 1973). It then moves on to discuss
the context for the research – taxation, and the empirical
data: two phases of interview research just prior to, and
shortly after, the creation of a new body for overseeing
the governance of taxation in the UK: Her Majesty’s Reve-
nue & Customs (HMRC). In our analysis we show ways in
which interviewees resolve attendant complexities in this
context by enacting personal projects of sense making,
and we conclude by identifying some implications that fol-
low from treating ‘tax tales’ as folk tales.
0361-3682/$ - see front matter Ó 2014 Elsevier Ltd. All rights reserved.http://dx.doi.org/10.1016/j.aos.2013.12.003
?
Corresponding author.
E-mail addresses: [email protected] (K. Morrell), p.a.l.tuck@
bham.ac.uk (P. Tuck).
Accounting, Organizations and Society 39 (2014) 134–147
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Narrative and sensemaking
Narratives help us make sense of social phenomena
(Barry & Elmes, 1997; Boje, 1991; Czarniawska, 1997a,
1998; Weick, 1995). Their role has become increasingly
prominent in the study of work and work organisations
(Bartel & Garud, 2009; Benjamin & Goclaw, 2005; Chreim,
2005; Gabriel & Grif?ths, 2004; Green, 2004; Morrell,
2008). Narratives are central to how innovations are
spread and interpreted (Abrahamson & Fairchild, 1999;
Bartel & Garud, 2009). They are ways to understand the
justi?cation for power and the actions of power (Benjamin
& Goclaw, 2005; Chreim, 2005; Mueller & Carter, 2005) and
they help show how the practice of management is carried
out (Alvesson & Sveningsson, 2003; Watson, 1995). As,
‘a form of social life, and form of communication’
(Czarniawska, 2010: 59), narratives play an important part
in how people thread their way through complexity in
their day to day work. They help to reduce confusion and
ambiguity, and to make contradictions manageable, allow-
ing us to make sense of experience as well as being a
means of sharing that experience (Gray, 2010; O’Leary
and Chia, 2007).
Within Accounting, Organizations & Society (AOS), inter-
est in the role of narrative encompasses work identity
(Gendron & Spira, 2010), the culturally artefactual nature
of accounting (Arrington & Francis, 1993; Gray, 2010),
and, more speci?cally, processes such as disclosure (Aerts,
1994; Nicholls, 2010), reporting (Cho, Roberts, & Patten,
2010; Nicholls, 2010; Preston & Young, 2000), and audit
(Nicholls, 2009). ‘Narrative’ is used by AOS scholars to de-
scribe their own research strategy or empirical analysis
(Brivot & Gendron, 2011; Jørgensen & Messner, 2010;
Kornberger, Justesen, & Mouritsen, 2011; Suddaby, Cooper,
& Greenwood, 2007), as well as to review other research
(Botzem & Quack, 2009; O’Dwyer, Owen & Unerman,
2011).
Here we provocatively advocate treating ‘tax tales’ –
accounts by representatives of Multinational companies
(MNCs), tax advisors from the ‘big 4’ ?rms of accountants,
and of?cials at the UK revenue service – as a particular
kind of narrative: a folk tale. This allows us to employ a
particular method of analysing narratives, thereby sys-
tematically developing a speci?c approach to working
with narrative and sense making. This is noteworthy be-
cause, problematically, narrative is used very broadly,
‘multiple uses have caused some ambiguity to be associ-
ated with the term and have sometimes led to a lack of
clarity and precision’ (Polkinghorne, 1995: 5). Our aim is
to offer a very clear application of a speci?c body of ideas
relating to analysis of narrative, and to hone in on the no-
tion of emplotment (Czarniawska, 2010, 2012a; White,
1973). The consequent theoretical contribution is to show
how this helps us understand personal projects of sense
making in a context that is technically, legally and mor-
ally complex. This has implications for how we under-
stand accounting as a professional project, as well as
implications for the governance of taxation.
Though, as our summary review above indicates, ‘narra-
tive’ is used very widely, we can start with a simple and
broad de?nition of the term narrative as ‘representation of
events’. This de?nition has common features with the
most in?uential approaches to de?ning narrative to date
(Rudrum, 2005). Clearly, many things could potentially
summarise events: lists, tables, calendars and so on. Yet
these are not what we would ordinarily think of as narra-
tive. Narratives (following Barthes, 1977; Bruner, 1990)
are typically: (i) chronological, (ii) about a person or persons,
(iii) related by someone and (iv) have a context. It remains
dif?cult to specify exactly what would (would not) count
as narrative (Pentland, 1999), but Rudrum(2005: 197) sug-
gests we have a tacit faculty for deciding this – ‘narrative
competence’. Greater clarity about this, and about our ap-
proach here, comes from a more detailed description of
the theorist we draw on in this paper, Vladimir Propp.
Propp’s framework
Vladimir Propp’s Morphology of the Folk Tale (Morphol-
ogy) was ?rst published in 1928. Given its cultural and
political context, the work suffered as it was not published
outside of Russia for several decades. Its rediscovery some
thirty years later led to great interest in Formalist ap-
proaches to narrative and its, ‘in?uence on structural anal-
ysis is elemental in literature research’ (Lamberg &
Pajunen, 2005: 951). It is ‘Formalist’ because Propp is not
interested in analysing the subject matter of particular folk
tales, which was the preoccupation of his contemporaries,
instead he is interested in the folk tale per se. He seeks, ‘an
examination of the forms of the tale’ (Propp, 1928: xxv).
The focus of folklore scholarship before Propp was to
analyse and compare content (a focus on the story): either
to study and compare motifs, themes or elements within
tales, or to categorise tales. To do this many folklore schol-
ars relied on a distinction made by Miller in the nineteenth
century between tales of: (i) fantasy, (ii) everyday life, and
(ii) tales involving animals; others used Wundt’s differen-
tiation between (i) mythological folk tales, (ii) pure fairy
tales, (iii) biological tales and fables, (iv) pure animal
fables, (v) genealogical tales, (vi) joke tales and (vii) moral
fables. Propp’s more recent contemporary, Volkov identi-
?ed 15 categories of fantastic tales in 1924. These include
fantasies that feature the hero–fool, or three brothers, or
deal with magical objects, or the search for a bride, or an
unfaithful wife. Similarly, the Aarne-Thompson classi?ca-
tion system identi?ed 7 categories, including: a supernatu-
ral adversary, or a supernatural spouse, or a supernatural
task and so on (see Propp, in Wagner, 1968 for a review).
Propp identi?ed that each system, though workable to a
degree, is also unstable. Miller’s categories overlook that
tales relating to animals often include elements of the fan-
tastic or everyday, or a combination. The same kinds of ac-
tions can be carried out by animals, by people and by
(magical) objects – so even though characters may differ,
the tale remains unchanged at heart. Wundt’s, Volkov
and Aarne’s frameworks are open to the same criticisms.
Some animal fables are moral ones (contra Wundt); a mag-
ical object can help deal with an unfaithful spouse (contra
Volkov); or a supernatural task can be addressed via a
supernatural helper, who is also the spouse (contra Aarne).
K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147 135
Contemporary accounting scholars may see that Propp
identi?es a quintessential problem with content analysis
of qualitative data. If we devise a coding frame, or try
to identify discrete themes, we face the impossible task
of determining categories that are simultaneously parsi-
monious, exhaustive and mutually exclusive (Robson,
1993). Propp’s solution – the key and most insightful
departure in Morphology – is to analyse these tales in
terms of functions. Functions are the actions characters
perform (or are subject to) but their signi?cance is not
simply understood in terms of the nature of the action,
nor who performs it – they are not simply themes. In-
stead, functions are understood in terms of their role in
the tale as a whole – they are component parts of a tale.
As a brief example, the action ‘transfer of money’ might
be identical in two tales, but this identical act can have
very different meanings. In one tale the money could then
be used to buy a magical object, in another it might be
the ?nal reward, signalling the end of a tale. The preoccu-
pation with function is a feature of Formalism which is
concerned with how content is organised, and underlying
structure, rather than the particular features of the con-
tent itself. Propp (1928: 18) de?nes his project as, ‘a
description of the tale according to its component parts
and the relationship of these components to each other
and to the whole’. This, in essence is to emphasise plot
rather than story, using a distinction that can be traced
back to Aristotle (links between Formalism and Aristotle
are discussed in Morrell, 2012: 94).
After exhaustive analysis, Propp identi?ed 31 functions
which feature in the paradigm Russian folk tale. He classi-
?es each according to the role they play in the tale. We list
and apply these functions in the analysis section below,
but to continue to develop the difference between (i) the-
matic content (story) and (ii) functions as component parts
of a tale (plot), it is useful to give a more detailed example
?rst. Function 15 is ‘The Hero Is Transferred, Delivered, Or
Led To The Whereabouts Of An Object Of Search’ (Propp,
1928: 50–51). Across different tales this same function is
manifest in different ways. For example (and this is listing
the same function in twenty different folk tales), the hero
could ?y, either on horseback, or on a giant bird, or a ?ying
carpet, or go on the back of a giant, or a spirit, or in the car-
riage of the devil. They could go on foot, or on the back of a
horse, or wolf. They could climb a stairway, use an under-
ground passageway, descend into the earth using leather
straps, or a cat could travel on the back of a dog, or a person
with no hands could carry someone with no legs. They
could travel on a ship, or cross a body of water on the back
of an enormous pike. They could be shown the way by a
ball of thread, or a fox could lead the hero to the princess,
or a hedgehog could point the way to a kidnapped brother,
or (a staple of horror) they could follow a set of bloody
footprints. The insight Propp’s Formalist perspective offers
us is that these richly different features of individual sto-
ries are essentially similar in terms of the function they
perform in the plot of the folk tale.
Propp’s ?nal account of functions gives us, ‘the struc-
ture of the folk tale as a whole and formulates its compo-
sitional laws’ (Pirkova-Jakobson, 1958, no page). Deaver
(1996: 180) summarises Propp’s analysis:
all folktales follow a set pattern. . . the hero undertakes
a trip and is given a prohibition. He [sic] violates this
prohibition and is branded, but he receives a magic gift
from a donor. This allows him to thwart a villain. He
then returns unrecognized and is captured. After per-
forming a dif?cult task which leads to his recognition,
he earns a reward (usually marriage), and ascends to
the throne.
Propp’s method has been developed in other structural-
ist approaches to narrative (Bal, 1985; Polkinghorne,
1995), as well as continuing to inform contemporary ap-
plied ?elds such as the study of arti?cial intelligence (Lang,
2010). In organization studies, Lamberg and Pajunen
(2005: 948) suggest, ‘Propp’s theory of the folktale struc-
ture may function not only as a morphology of folktales,
but also as a structural model of any process that includes
crisis and recovery’. Dundes makes a similarly broad argu-
ment for the continuing real-world relevance of Propp in
the introduction to the second edition of Morphology ask-
ing, ‘To what extent is the structure of the fairy tale related
to the structure of the ideal success story in a culture?’
More broadly still, folk tales, as part of collective culture,
are one of the earliest ways we have of making sense of
the world and therefore a source of strong or dominant
plots (Czarniawska & Rhodes, 2006). They supply familiar,
perhaps even culturally universal, conceptual inventories.
The way we use Propp here is to apply his approach to ana-
lysing folk tales to ‘tax tales’. In doing so, we extend under-
standing of narrative analysis by showing the role that
dominant plots play in personal projects of sense making.
Central to our analysis is a more contemporary term in
narratology: emplotment.
Emplotment is a term coined by the historian Hayden
White (1973). White was concerned with what made his-
tory more than a retelling or chronicling of events, and
with the problem of the impossibility of reproducing
events in all their complexity and detail in texts. Montrose
describes this as the inescapable, ‘textuality of history’: no
matter how sophisticated, or intricate our descriptions of
historical events are, they are always mediated by texts:
we can have no access to a full and authentic past, a
lived material existence... textual histories necessarily
but always incompletely constitute in their narrative
and rhetorical forms the ‘history’ to which they offer
access’ (in Rivkin & Ryan, 1998: 781).
The identi?cation that history is always more than sim-
ply factual chronicle resonates with debate within AOS on
gendered accounts of the profession and the nicely ex-
pressed need for an accounting ‘herstory’ (Kirkham,
1992; Lehman, 1992). For White, emplotment furnishes,
‘the ‘‘meaning’’ of a story by identifying the kind of story
that has been told’ (1973: 9). Emplotment is an act that in-
volves moving beyond mere chronicling or sequencing of
events to the telling of a story (Levisohn, 2002); ‘introduc-
ing structure that allows making sense of the events re-
ported in a narrative’ (Czarniawska, 2012a: 758; see also
Czarniawska, 2010, 2012b). In the context of our paper,
emplotment is a way to understand how narratives pro-
vide structures for sense-making. Below we show how
136 K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147
narrators of ‘tax tales’: tax of?cials; tax advisors to, and tax
directors of, multinational companies; create and impart
meaning by arranging events into familiar conceptual
inventories. We argue that in doing so they draw on the
form of a particular kind of narrative: the folk tale.
Context and data
Taxation is complex not simply because of the legal
framework governing corporate activity, but also because
of: the tension between enforcement and compliance;
and the mutually constituted identities and history of gov-
ernment agencies, and those whom they seek to regulate
(for recent, relevant reviews see Blanthorne & Kaplan,
2008; Hanlon & Heitzman, 2010). In terms of the relation-
ship between tax agencies and taxpayers, Pentland and
Carlile (1996: 284), in a study of the US Internal Revenue
Service, identify that, ‘interpretation and application of
the tax code is highly contingent upon the character of
the interaction between agent and taxpayer’. Preston dem-
onstrates – an apparent paradox – that greater accounting
and tax expertise by taxpayers can actually create compli-
ance (Preston, 1989). These dynamics show taxation to be
a mutually negotiated and enacted social process with its
own institutional history and traditions (Boden, Killian,
Mulligan, & Oats, 2010; Gracia & Oats, 2012; Kaplan,
Reckers, & Roark, 1988; Lamb, 2001).
The relationship between government agencies and
multinational companies (MNCs) is especially complex
(Pentland & Carlile, 1996; Preston, 1989; Shah, 1996). Un-
like most other taxpayers, MNCs are frequently in a posi-
tion of power when dealing with national governmental
agencies. They have the capability and resources to work
across national boundaries and jurisdictions and to inno-
vate in ways that can reduce tax exposure as well as to take
advantage of ambiguities or incompleteness in legislation.
Often in taxation the law is incomplete, or open to inter-
pretation, and (inevitably) omits to foresee the tax implica-
tions of speci?c and particular circumstances associated
with ?nancial innovations, or especially complex transac-
tions. MNCs have the resources to deploy specialist exper-
tise to negotiate on these areas. Moreover, they are
powerful as signi?cant contributors to national economies,
not just through the payment of taxes, but also by provid-
ing employment which contributes to Gross Domestic
Product and provides a larger pool of taxpaying individu-
als. Many MNCs have the ability to move tax jurisdiction
(WPP, 2007). This comparable parity in power chances
(which is unlike that between HRMC and the typical citi-
zen) makes the relationship between government agencies
and MNCs interesting. As we show, this greater parity in
power chances, as well as the ongoing, processual, and at
times combative dimension to such relationships chimes
with aspects of struggle and opposition which are at the
core of folk tales.
We examine a recent, pivotal period in the gover-
nance of taxation in the UK in two phases of interview
research shortly before (2001–2004), and shortly after
(2006–2007), the forming of HMRC (in 2005). This fol-
lowed the merger of Inland Revenue (IR), which dealt
with direct taxes including income taxes and corporate
taxes, and HM Customs & Excise (HMCE) which dealt
with indirect taxes. A feature of this period was that
MNCs indicated the tone and stance of the UK tax
administration had changed, and speci?cally that HMRC
was more confrontational than its predecessors. They ar-
gued this was affecting the competiveness and attrac-
tiveness of the UK. Public pronouncements by HMRC
(Hickey, 2005), the Tax in the Boardroom agenda (KPMG,
2004), the PricewaterhouseCoopers report on Total Tax
Contribution (PWC, 2005), and speci?c legislation requir-
ing the disclosure of tax avoidance schemes introduced
by the Finance Act 2004 contributed to this sense of a
more confrontational context for tax governance. Hickley
identi?ed a trust gap in his 2005 Institute of Chartered
Accountants in England & Wales’ Annual Hardman lec-
ture. Evidence of a lack of trust between HMRC and
MNCs was implicit in two in?uential policy documents
speci?cally relating to MNCs: the Tax in the Boardroom
Agenda (HMRC, 2006a) and Working with Large Business
(HMRC, 2006b).
We draw on two distinctive features of Propp’s frame-
work: (i) characters, and (ii) functions; to analyse narra-
tives in this context. Our interviewees were senior tax
advisors to, and in, MNCs and senior representatives of
the UK Inland Revenue (IR) – later HMRC. Our empirical
data primarily comprises 45 semi-structured interviews
conducted by Penelope who has extensive, specialist
expertise in the area of tax. 33 of these were carried out
in the period 2002–2004 with senior tax of?cials, tax part-
ners of a ‘Big 4’ accountancy ?rm and a number of tax
Directors of FTSE 100 companies. These interviews offered
insight into the changing context for taxation and the
backdrop to the creation of HMRC (though we did not
know at the time that this speci?c reform was to take
place). Subsequently, a further 11 semi-structured inter-
views, again with senior informants, were carried out be-
tween June 2005 and January 2007 thereby (alongside
documentary analysis) providing a longitudinal dimension
to the research. As a ?nal stage of interview research, we
carried out several more interviews with MNC agents and
public of?cials. We draw on one of these interviews (with
a MNC agent) in September 2010. These were used to
sense-check the extent to which fundamental aspects to
the context for taxation persisted through this ten year
period. Basic detail about our interviewees is shown in
Table 1.
Table 1 shows interviewees and job titles (’Position’),
with codes for the purposes of attributing direct quotes.
This table also shows the approximate number of years
after qualifying of each interviewee at the time of inter-
view (each interviewee in both public and private sector
would have several organizational tiers below them). The
value of showing this is not simply to indicate seniority,
but also to show that we elicited narratives from individu-
als who were steeped in their respective institution’s
history and context, and who had a profound understand-
ing of a complex governance environment. Each interview
lasted for at least 60 min, with the longest being approxi-
mately 120 min. The vast majority were taped and
transcribed (approximately 330,000 words of transcript).
This was not possible on two occasions where consent to
K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147 137
being recorded was not given. In these cases, since inter-
viewees were happy nonetheless to proceed, notes were
written up immediately after the interview, to supplement
notes taken during the interview (standard protocols and
assurances relating to informed consent, anonymity, pro-
tection of data, right to withdraw, retract, speak off the re-
cord, and so on were given to all interviewees). We also
draw on relevant documentary data from HMRC (formerly
Inland Revenue), public speeches, Select Committee testi-
mony, MNCs, and commentators from the tax professional
press (HM Treasury, 2010; HMRC, 2006a, 2006b, 2010;
Houlder, 2010; Inland Revenue, 2003; KPMG, 2004; Mears,
2010; Montagu, 2002; OECD, 2008; WPP, 2007).
Our research aim was to examine the extent to which
Propp’s approach to narrative could help us to understand
this complex, combative taxation environment in ways
that other methods would miss. To do this, we examined
two core research questions (Propp, 1928: 21):
1. How does the emphasis on characters help to analyse
this context?
2. What advantages does interpretation in terms of func-
tions have over other methods?
These research questions are fairly simple and straight-
forward in the sense that they follow from our review of
Propp’s method. To address them, in analysing interview
transcripts and documentary data, we used what we call
a ‘strong’ reading of Morphology. By ‘strong’ we mean we
are not using his method simply in an analogous or meta-
phoric way, but that we are more faithfully following his
research strategy (see e.g. Lamberg & Pajunen, 2005). At
the same time, we use ‘strong’ to distinguish our research
strategy from a ‘literal’ application, which would imply
treating the ‘tax tales’ of our respondents as equivalent
to the ?ctional narratives within folk tales. A strong read-
ing allows us to see speci?cally what bene?ts a Formalist
approach can bring to the study of this context without
committing to a naive realist application of Morphology.
The advantage of research carried out over time is the
potential to explore historical context. A narrative ap-
proach is also consistent with this goal – using our adopted
de?nition of narrative as ‘representation of events’. This re-
search period is particularly interesting, and (for the same
reason) it is also ‘bounded’ to a degree in chronological
terms, because the HMRC was formed on 18 April 2005.
This setting offered a natural experiment in large scale
governance reform, and our data provided a historical as-
pect that was very suited to using Propp’s characters and
functions schema. We had the ability to analyse accounts
of the governance of taxation both before and after this
pivotal event.
Findings and discussion: characters
Propp describes how functions are distributed among
seven characters: (1) villain, (2) hero, (3) helper (who as-
sists the hero, for instance with a journey), (4) donor
(who gives the hero powers or a magical object), (5) prin-
cess and her father (these are not separate, they represent
the typical object of a quest, and its reward for the hero,
sometimes called ‘the prize’), (6) false hero, and (7) dis-
patcher (who sends the hero on their mission). Consistent
with a strong, rather than literal reading, in our analysis we
found that the identity of characters was not ?xed and in-
stead depended on perspective. This underlines that
although we pursue a realist orientation here, we are also
inevitably presenting our own narrative, and also express-
ing or re?ecting points of view. For instance, and most sim-
ply, both HMRC and MNCs can take on the form of hero (or
villain) in different contexts. Additionally, HMRC or MNCs
could be simultaneously understood in terms of more than
one of Propp’s characters.
To illustrate this at its simplest level, from an HMRC
perspective, the MNC can be a ‘villain’ in that they under-
take tax avoidance activities which minimises, by legal
means, their exposure to UK taxation. This consequently
reduces the money being received by the Exchequer. In
extremis, some MNCs can even threaten to relocate to do
this as one FTSE Tax Director intimated:
I think that the tax environment has changed and it’s
changed quite dramatically. It’s changed for the worse
rather than for the better... in order to keep the same
competitiveness it actually should change for the better
because other factors outside of the UK tax system are
changing favourably, that means that we no longer
mean to concern ourselves if companies don’t want to,
with the UK tax system (FTSE tax director, D3, 2006).
Despite such threats, as legislation continues to empha-
sise, these large multinationals must be governed by HMRC
in such a way that they pay their fair share of taxation
(House of Commons, 2012).
Table 1
Schedule of interviews.
N Code Position Years post-qualifying Organisation Date
15 C1–C15 Financial Directors and tax managers 10–30 FTSE 100 groups February 2001–December 2003
5 A1–A5 Tax Partners 15–35 Big 4 accountancy ?rms September 2002–March 2003
13 IR1–IR13 IR of?cials SCS 1 & SCS 2 15–35 Inland Revenue February 2003–May 2004
Merger of IR & HMCE to form HMRC April 2005
2 P1–P2 Tax Partners 10–15 Big 4 Accountancy ?rms June 2005–June 2006
4 D1–D4 Tax directors 15–25 FTSE 100s June 2006–January 2007
4 HMRC1–HMRC4 Case Directors LBS of?cials SCS 1 20–30 HMRC September 2005–October 2005
1 TO Tax of?cial grade 7 10 HMRC October 2006
1 D5 Tax director 35 FTSE 100 September 2010
138 K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147
Having looked at this from an HMRC perspective, if we
imagine the perspective of the wider public, there could be
connotations of villainy to MNCs, since tax avoidance cases
can be very prominent in the media and take a long time to
resolve. For example, Vodafone was in dispute with HMRC
for 10 years over a tax avoidance scheme relating to the
purchase of Mannesmann, a German company. This case
proceeded through the Court system to the UK Court of Ap-
peal. Vodafone recently negotiated with HMRC to settle the
outstanding dispute which amounted to £800 million plus
£450 m payable over ?ve years (Houlder, 2010). Even so,
HMRC is an unlikely hero from the public’s point of view
given its role in regulating personal taxation. Finally, and
again in simple terms, we might imagine that from an
MNC perspective HMRC could be regarded as a villain if
it is seen to be unreasonable. Indeed, shortly after the cre-
ation of HMRC, MNCs argued that increasing business
taxes, and the additional inconsistency and complexity of
tax rules, was undermining the international competitive-
ness of the UK (Duncan, 2006).
In our interviewees’ ‘tax tales’, we could clearly see the
potential for the identity of HMRC to shift in a way that is
uncharacteristic of a folk tale character, but which is con-
sistent with the idea that creating personal narratives
can be a guide to sense-making.
I meet with Dave Hartnett [then Director General of
HMRC] from time to time, we speak together in confer-
ences and at various meetings and others, at a senior
level in Revenue and Customs, and the actual practical
dialogue is still in my opinion very civilised and very
appropriate and very constructive. So it’s really the tone
of these public pronouncements which seems to be
inappropriate rather than the actual conversations that
are taking place (FTSE tax director, D2, 2006).
This extract illustrates how HMRC (stereotypically
understood as villain from an MNC perspective) could also
be seen as another of Propp’s characters – the ‘helper’ and
shows how personal tales about this context may differ
from received versions of public tales, where private com-
panies and HMRC are understood as in opposition. It also
suggests there may be a politically motivated desire to sus-
tain a public narrative of hero–villain combat which may
run counter to the necessary compromises required to re-
solve disputes between a local agent (in the sense that, as a
national body, HMRC is ‘local’) and a global one (an MNC).
To negotiate successfully in the middle of such complexity,
both of?cials and representatives of organizations would
need to have in mind the structure of the whole tale, and
not focus simply on themes of the day, the inappropriate
‘public pronouncements’ referred to above. These layers
of complexity are missing in folk tales since these have
one narrator and one audience. However, the language of
hero/villain, combined with an emphasis on the tale as a
whole is informative in analysis precisely because it
throws into relief the complexity of these interrelations,
and it also shows how the component parts of the tale
need to be understood in relation to one another.
Alongside these public, oral tales we could also use
Propp’s characters to analyse the kinds of narrative related
in policy documents, where the hero could be understood
as the government of the day, with HMRC acting on their
behalf as helper:
The Government wants to make sure that everyone
pays their fair share of tax and claims their proper enti-
tlements [this] forms the foundation for stable public
?nances and world-class public services’ (HMRC,
2006b: 2).
This simple narrative is explained well in terms of three
of Propp’s characters (above): Hero (Government), Helper
(HMRC), and Princess–Father or ‘prize’ (‘world-class public
services’). As one might expect however, the HMRC of?-
cials to whom we spoke expressed a clear sense of service
and public ethos. This suggests that from their perspective,
their ultimate task (‘prize’) was to bene?t the public rather
than simply to act as helpers to government. The following
extract illustrates this:
A £300 m provision saving £100 m worth of tax, may
actually be a drop in the ocean as far as that corporate’s
concerned but it would still buy an awful lot of hospital
beds in the United Kingdom (HMRC of?cial, HMRC1,
2005).
In this brief extract, which itself encapsulates a tale, we
see the ?rst example of emplotment – where an HMRC
of?cial places themselves in a narrative about tax avoid-
ance. They make sense of their role and institution’s pur-
pose by casting themselves as heroic making reference
to, arguably, the most noble use of tax revenue – buying
hospital beds (rather than, say, improving the road net-
work or supporting refuse collection).
It is important to emphasise that in our analysis using
Propp here, from which it follows that this of?cial is cast-
ing themselves in a heroic role, we are doing more than
making a comparison with a folk tale at the level of theme
(we are not just saying that both tales can be said to have
heroes). The value of using Propp’s framework is that it
shows how the ‘hero’ character plays a role in an unfolding
narrative in relation to other characters. The extract above
is not just informative about the content of the narrative or
the ‘story’ (simple comparison between their role and a
hero ?gure). Instead we are suggesting that a ‘plot’ is at
work here, (what Czarniawska, 2004 calls a ‘strong plot’).
In other words, these events are being mapped onto a cer-
tain kind of narrative, one that is very well explained in
terms of Propp’s framework: it is a tale of combat where
the revenue of?cial casts themselves as hero, the govern-
ment is the helper, the prize is increased public revenue,
and the MNC is villain. Key to understanding this tale is a
narrative arc: an account of how these characters interact
with each other as the tale unfolds. In other words, as a
rich example of emplotment it is an example of where,
‘the ‘‘meaning’’ of a story’ is given by, ‘identifying the kind
of story that has been told’ (White, 1973: 9)’.
In what is a departure from the folk tale, there are likely
to be differences between public pronouncements – or an
of?cial tale – and individual interpretations relating to per-
sonal purpose and identity. More than this, in ‘tax tales’,
we can readily identify different narrators in the same con-
text (unlike in the folk tale where the narrator is constant).
For example, perhaps a more straightforward application
K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147 139
of Propp’s framework comes if we consider the role of
MNCs, since the MNC’s own helpers (tax directors) always
have recourse to appeal to the interests of their
shareholders.
We are not in the business of paying tax any more than
we have to, and it is often overlooked by revenue of?-
cials that the directors of these companies have ?du-
ciary duties to their shareholders... paying excessive
amounts of tax isn’t the way you discharge your ?du-
ciary duties (FTSE Tax Director, C13, 2003).
This is another instance of emplotment, and tells a com-
pletely contrasting tale, but it uses the same basic story
structure – the difference here being that the individual
casts themselves in the role of helper rather than hero.
The role of the hero (MNC), assisted by the helper (Tax
Director), is to seek the Prize (shareholder return), in a
struggle with the villain (HMRC). Together, Propp’s basic
analytical framework, and the concept of emplotment, help
us understand how completely contrasting ‘tax tales’ (each
from a particular perspective) can be interpreted as narra-
tives with their own structure and logic that support
sense-making.
Findings and discussion: functions
Morphology details a strict and particular sequence of
31 functions. Again consistent with a strong rather than lit-
eral reading of Propp, we did not ?nd exact matches for all
of the same functions in this case study. However, we did
?nd quite striking parallels and the implications of this
are intriguing. Contemporary accounts of the context for
governance of the UK tax system (perhaps by extension
any ‘governance tale’) do seem to mirror certain de?ning
characteristics of the folk tale. An obvious question here
is whether we in our analysis are revealing, or imposing
such parallels, but – in either case – one implication is that
there may be deeper, underlying structures for sense-mak-
ing that inform both how we construct and recall simple
folk tales, and how we explain complex environments. It
may be that stories we learn at a very early age establish
conceptual inventories that we unconsciously apply to
make sense of more complex terrains in later life. This does
not necessarily imply any determinism or deep structure,
instead these ‘strong plots’, ‘are strong because they
have been institutionalised, repeated through the
centuries, and well-rehearsed with different audiences’
(Czarniawska, 2004: viii).
Below, in Table 2 (in the ?rst column) we outline the 31
functions and summarily describe them. This paraphrases
Propp’s more detailed descriptions, but each description
is suf?cient to give the essence of each function. The result-
ing schema is an original analysis of this case and context
that an approach focused on content would not be able to
generate. It suggests ways in which narratives about taxa-
tion can be structured so as to make sense of complexity
through emplotment. This account of Propp’s functions
supplements the two examples above based on his charac-
ters (from the perspectives of an HMRC of?cial, and a FTSE
Tax Director). Combined with column 2, which illustrates
where these functions have parallels in our ‘tax tales’, the
table embodies a (Formalist) narrative analysis of our qual-
itative data: where themes interlock to reveal that a kind of
tale is at work here. It summarises the corpus of ‘tax tales’
(stories) from both phases of the interview research, and
documentary data, in a way that offers a sequenced, con-
text-sensitive interpretation that relates the component
parts of the tale to the tale as a whole (plot).
In a folk tale, the hero and the villain remain the same
characters (though they may not be recognised as a hero
or villain until the end of the tale). This constancy was a
feature of individual ‘tax tales’ but of course attributions
of role depend on the narrator’s perspective (as we showed
above with contrasting tales of HMRC as hero/helper and
FTSE Tax Director as helper). To show this, our table
(though only outlining one perspective) underlines that
there can be changes in attributions – such as hero/villain
– because it speci?cally represents a point of view: a per-
spective with the MNC as villain. This integrative account
allows us to summarise a great deal of content-rich data
because Formalist analysis shows how to move from many
stories to the general form of a kind of narrative.
For concision, the functions and a translation into this
context are only outlined in Table 2. This is by no means
a detailed narrative, it simply shows the skeleton of one
and the scope for further development of Propp’s approach.
To apply this in greater detail, we now focus on the basic
narrative arc that Propp identi?ed as a feature of all the
folk tales he studied. This arc involves three functions:
interdiction > violation > prize and takes us from the
beginning to the end of the tale. Offering more detail on
this adds some ?esh to the skeleton account of functions
shown in Table 2. It also supplements the analysis of emp-
lotment based on characters above.
Drawing on our interviewand documentary data, below
we offer illustrative extracts which show how the three
functions in Propp’s folk tale were closely paralleled in
our ‘tax tales’. Initially, we offer examples of each stage,
we then conclude with some extracts that we think show
how our interviewees linked all three stages in ways that
helped them make sense of the complexities in taxation.
These are acts of emplotment – where interviewees resolve
complexities in this context, in personal projects of sense
making.
Interdiction – warnings not to do something (or instructions
to do something)
Propp identi?ed that folktales typically have a com-
mand near the beginning (don’t go into the forest, don’t
speak to anyone on your journey, and so on). In this con-
text, the ultimate source for interdictions is legislation
and the categorical differences between tax evasion and
tax avoidance: tax evasion is an illegal activity (Blanthorne
& Kaplan, 2008; Kaplan et al., 1988); tax avoidance is law-
fully trying to minimise or avoid paying tax, with further
distinctions being made between unacceptable (‘aggres-
sive’) or acceptable forms of avoidance. De?nitions of
aggressive tax planning are open to debate and often con-
tentious (Freedman, Loomer, & Vella, 2009; OECD, 2008).
In the UK, prior to the establishment of HMRC, and since,
this distinction has arguably become even less clear owing
140 K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147
to: the cumulative effects of a series of judicial decisions
starting in 1980 with W.T. Ramsay v Inland Revenue Com-
missioners; and the result of any number of ?nancial inno-
vations. Tax avoidance is not limited to arranging
transactions in the most tax ef?cient structure (Shah,
1996); it can also be linked to the process of complying
including the manipulation of transfer prices (Sikka &
Willmott, 2010). The Institute of Fiscal Studies’ (IFS) Report
on Tax Avoidance, in an attempt to impose clarity, de?ned
tax avoidance in broad terms as, ‘action taken to reduce
or defer tax liabilities in a way Parliament plainly did not
intend or could not have intended had the matter been
put to it’ (Institute for Fiscal Studies Tax Law Review
Committee, 1997: paragraph 7).
Among interviewees there was clarity about the core
interdictions: do not evade, or aggressively avoid, paying
tax; but as our interviewees acknowledged, the de?nition
of tax avoidance is not clear. Speaking in 2003, an IR em-
Table 2
A narratology of the tax tale – from the perspective of MNC as villain.
1. Family member leaves home / hero introduced Crea?on of HMRC / Introduc?on of new leadership/government
2. Interdic?on to hero.
3. Interdic?on violated (or command ful?lled).
Legisla?on, mandate and authorising environment
4. Villain reconnaissance.
5. Villain gains informa?on about vic?m
6. Villain tries to deceive vic?m/capture vic?m or their belongings
Complexi?es rela?ng to dis?nc?on between Acceptable / Unacceptable
Avoidance, strategies for avoidance by MNCs and ?nancial service
providers
7. Vic?m taken in by decep?on Successful (from MNC perspec?ve) avoidance
8. Villain harms family member Lost revenue, cost to public purse
9. Misfortune is made known Corporate scandals; representa?on in the media (Vodafone)
10. Hero decides upon counter-ac?on
Regula?on change (poten?ally with Government as hero and HRMC as
‘helper’) or move to a disclosure regime
11. Hero begins search.
12. Hero is tested paving way for donor.
13. Hero reacts to donor
14. Hero acquires magical agent
Implementa?on of innova?ons/legisla?on to increase revenue (e.g.
introduc?on of ‘Spend to Save scheme); more broadly, introduc?on of
powers (‘magical agent’) to enhance tax collec?on and applica?on of
those powers (with Government as ‘donor’)
15. Hero transferred (this func?on is described in detail above).
16. Hero and villain in combat
Di?erent interpreta?ons of legisla?on lead to nego?ated agreement
17. Hero is branded Portrayal of HMRC in media; public image of HMRC
18. Villain is defeated.
19. Ini?al misfortune or lack is resolved
Revenue recovered
20. Hero returns.
21. Hero is pursued.
22. Hero is rescued from pursuit
Mutually cons?tuted iden??es / history of enforcement agencies, and
those they seek to regulate (departure from Propp in that there is no
‘end’ to this tale)
23. Hero unrecognized, arrives home or in another country Portrayal of HMRC in media; public image of HMRC
24. False hero presents unfounded claims
Poten?ally, poli?cal spin placed on revenue regime by an administra?on
(with the Government as false hero)
25. Di?cult task proposed to hero.
26. Task resolved
Successful, itera?ve carrying out of mandate
27. Hero is recognized.
28. False hero or villain is exposed
Poten?ally, through exposure and corporate scandal, public reappraise
HMRC; more aware of corporate avoidance
29. Hero is given new appearance Change to structure / branding (shi? from IR to HMRC)
30. Villain is punished Prosecu?ons, puni?ve measures
31. Hero is rewarded HMRC protects budget and resources
K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147 141
ployee acknowledged it was dif?cult to de?ne, but
suggested there was a de?nitive and shared, core sense
to what unacceptable meant in the relevant legislation:
I mean I don’t think we can de?ne it absolutely, but
most people know when they’ve been [unacceptably
avoiding tax]. They go out of their way to do something
for a tax reason. And some of these things involve you
know twenty or thirty different steps. And you know
that’s tax avoidance (Tax of?cial, IR12, 2003).
However, a Tax Director whom we later interviewed
about this same legislative context suggested that the
establishment of the HMRC had led to a situation that,
‘simply bunched together avoidance and evasion’. They
said it confused matters when the then Director General
of HMRC, ‘spoke at the London branch [of the Chartered
Institute of Taxation] I think a year ago, when he started
talking about morality and avoidance and all sorts of
things.’ (FTSE tax director, D2, 2006).
Violation of interdiction – warnings/instructions are ignored
Inevitably interdictions are violated (strangers are spo-
ken to, siblings are left alone and lost, forbidden fruits are
tasted). In this context, while core interdictions are clear,
because (as the quote above shows) the de?nition of unac-
ceptable avoidance is not, violation is more nebulous.
What is considered by the government to be tax avoidance,
and therefore subject to closer scrutiny, may be regarded
as effective and legitimate tax planning by a taxpayer.
Tax law cannot foresee every eventuality and is de-
signed for existing transactions and scenarios so –
although it contains basic tax principles – it cannot predict
the tax treatment of new types of transactions. Applying
existing legislation becomes more dif?cult as the transac-
tion concerned becomes more complex or unusual and a
matter of interpretation. The taxpayer (MNC) is likely to
interpret legislation in their favour, whereas the agency
may interpret it in such a way as to increase the tax take.
Differences in interpretation, and hence the tax impact
of the transaction, will be a matter of negotiation between
the two parties. If they fail to reach agreement, ultimately
the Courts act as arbiters of violation of interdiction and
determine (in terms of Propp’s framework) the prize. But,
as we noted earlier, unlike the vast majority of individual
taxpayers, MNCs are in a comparative position of power.
This means their relationship with government agencies
is closer to the hero–villain encounter in a folk tale, and
more likely to result in protracted struggle. The following
extract illustrates the complexities of violation in this set-
ting – where there is greater parity in power between gov-
ernment agencies and MNCs than there would be with
other taxpayers. A Tax Director was commenting on the
context in which HMRC was formed:
they were on a lose-lose situation with some companies
who realised that the Revenue would do a deal rather
than proceed to litigation [as a result, MNCs] would
have an opening position that was perhaps certainly
more aggressive... certain transactions that were
entered into, in the knowledge that (by the companies
that were entering into them) that they had a 50/50
chance and that perhaps they wouldn’t get the full
amount but they would probably end up being able to
do a deal... that encouraged companies I think to do
things that they might otherwise have not done had
they felt that the thing was going to go court and it
was an all or nothing (FTSE tax director, D4, 2007).
This is still the case judging from one of our more re-
cent, sense-checking interviews, where a group Tax Direc-
tor of a multinational commented (D5) in September 2010,
‘Some multinationals might, for instance do 15 tax plan-
ning schemes, then budget for 5 to be stopped. HMRC is
happy they have stopped 5 schemes but there is a positive
outcome for shareholders as 10 schemes have been
successful’.
Drawing on Propp’s schema, and emplotment, we
would anticipate revenue of?cials and MNC agents to act
in ways that interpreted relations in terms of an overarch-
ing narrative of struggle or combat, within which were
individual, smaller scale skirmishes. We did ?nd evidence
of this, for example from an MNC perspective, in the fol-
lowing interview with a FTSE Tax Director who described
one instance of working with a particular tax of?cial:
he didn’t understand our business and because he had
no relationship with us, we – you know he asked ques-
tions that maybe we thought were unnecessary. So in
the end we spoke to the director of the LBO [Large Busi-
ness Of?ce] again, saying we’re not very happy with
this. This approach that he’s taking with us. And he then
sort of stepped in, in his ringmaster role to bring it all
back on course so that this other chap wouldn’t upset
this taxpayer (Tax manager, C14, 2003).
This appeal to a higher authority, and the ringmaster
metaphor shows how an overarching narrative transcends
individual transactions. It is appropriate to see it as strug-
gle since this very brief description of an extraordinarily
complicated and intricate transaction, is replete with emo-
tionally laden terms, ‘didn’t understand’, ‘no relationship’,
‘unnecessary’, ‘not very happy’, ‘upset’.
We found evidence of this perspective – of an overarch-
ing relationship of struggle – in relation to revenue of?cials
too. For example one tax of?cial (LB5, 2003) identi?ed the
value of a close, ongoing understanding of individual MNC
representatives in terms of attributing responsibility, ‘you
do get close to the tax managers, and it’s very dif?cult
for them to be lying to you straight, you know face to face’.
Prize: The task is resolved, the villain is punished and the hero
rewarded
Having looked at the very beginning of our tale, we now
turn to the end. One problem in following Propp’s analysis
too closely is that folk tales always have an ending (and,
typically, a happy one). However, in the governance of tax-
ation, the narrative is perpetually unfolding because gov-
ernments and legislation change, ?nancial service ?rms
innovate, and the identities and history of the two parties
(HRMC and MNCs) are mutually constituted. Hypotheti-
cally, the ultimate happy ending from the perspective of
142 K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147
a political administration could be re-election. For minis-
tries (such as HMRC) it could be to enjoy the con?dence
of their government, to retain their budgets and gover-
nance structure, win greater autonomy, and earn the con-
?dence of the public. Tax revenues fund the public purse
and pay for public services: hospitals, schools, law and or-
der and so on (Montagu, 2002); in that sense, for of?cials,
the prize can be ongoing bene?t to other public services.
For MNCs and their representatives, continually increasing
the return to their shareholders, and also enjoying an
unblemished corporate reputation could be the prize.
Given the lack of a de?nitive ending, and an environ-
ment characterised by change and complexity, the pursuit
of these different prizes may lead to narrators of ‘tax tales’
reframing the character of other tax actors. In Propp’s
terms, changes in the legislative context prior to the crea-
tion of HMRC seemed to mean that the identity of the rev-
enue (IR/HMRC) shifted from helper to villain. In 2005,
MNC tax advisors felt that HMRC was changing in tone
and stance in their relationships with MNCs. This was
partly owing to changes in legislation but also the changes
and uncertainty brought about by such fundamental
reform.
I think it’s making them gear up to have the resources to
deal with more intrusive enquiries, making them deal
with more confrontation. I think in certain circum-
stances, it’s beginning to have an effect of being so irri-
tating in certain areas, that actually it is making certain
corporates consider whether this is the right place to do
business (Tax advisor, P2, 2006).
During the period of our research, a number of schemes
were introduced to counteract tax avoidance. Notably, and
prior to the creation of the HMRC these included the
‘Spend to Save’ scheme introduced in the 2003 Budget
(Inland Revenue, 2003). An extra £66 million was allocated
to focus on tax avoidance which was anticipated to yield
more than £1.6 billion of additional revenue. As a conse-
quence of this scheme, relations between HMRC and MNCs
became more confrontational. The threat of relocation
(above) again underlines the comparative parity in power
chances between some MNCs and government agencies.
The narrative arc: interdiction, violation, prize
We conclude our analysis with examples of the narra-
tive arc (interdiction, violation, prize) in practice, showing
how it underpins projects of sensemaking and the con-
struction of professional selves. Drawing on the concept
of emplotment (Czarniawska, 2010, 2012a, 2012b; White,
1973), we propose that the overarching structure in the
folk tale that Propp identi?es (interdiction > viola-
tion > prize) can be seen as a ‘strong plot’ (Czarniawska,
2004), that has particular resonance in taxation. Even in
the midst of such complexity and ambiguity, there remain
clear imperatives and goals, and even where technical and
legal considerations are so prominent, actors understand
their work in terms of an overarching narrative of hero–vil-
lain struggle. This ?rst example illustrates the importance
of a core, anchoring imperative – a prize – in making sense
of oppositional struggle, interdiction and violation:
the pot does get stirred from time to time and, again, I
accept that but there is a loss of, a loss of time and it
takes you time to gain knowledge etc. and then you
graft all the new um, working methods and information
systems on top of that. The time spent doing the core
job that I mentioned has, has dropped a lot, you know,
and it’s brought inevitable pressures because that’s
the job. I think that’s, that’s the job I see myself as being
paid to do and I think, you know, most other tax special-
ists will say the same, you know, that we’re here to
bring the money in, in the end. We can do that by hav-
ing a, a reasonably good working relationship with the
group and, and that’s something we always try and
achieve because it makes life better for people on both
sides but in the end, we are an arm of the government
which aims to recover yield. That’s how, that’s how
we justify our existence really (Tax of?cial, TO, 2006).
Here there is evidence of contextual sources of change
and reform, ‘time to gain knowledge... new working
methods and information systems... brought inevitable
pressures’; as well as reference to how ‘the pot does get
stirred’, which refers in part to the policy of rotating tax
of?cials to improve audit and prevent overly familiar rela-
tionships from developing. Alongside these complexities
are very de?nite and marked anchor points that support
sense-making. As the narrator of their own ‘tax tale’, this
of?cial makes sense of their purpose and identity through
the concept of prize, ‘to recover yield’, and this is tied to
fundamentals in terms of their professional self, ‘that’s
how we justify our existence really’. Underpinning this
professional identity is a sense that interdiction and viola-
tion are inescapably part of the fabric of the work. This is
what lies behind the expression of a basically combative
relationship between HMRC and companies. Though care-
fully expressed it is clear in the above extract, in the nicely
quali?ed aspiration – to have, ‘a reasonably good working
relationship’, which is one that ‘we always try and achieve’
(emphases added); and the description of ‘people on both
sides’. More forcefully this sense of a combative relation-
ship underpins their description of how, ‘in the end’, ‘we
are an arm of the government’.
A second, shorter, example also links the concepts of
violation, interdiction and prize. Interestingly, it invokes,
but at the same time undercuts, a stereotype about the
professional character of the tax accountant (Friedman &
Lyne, 2001):
I must admit I’ve had trainees and said (a) don’t get per-
sonally involved, (b) treat it as a bit like an intellectual
game, I don’t know what it is, it’s your intellectual argu-
ment against somebody else’s, like a game of chess,
you’ll win ermyou’ll lose a few [laughs] and you’ll prob-
ably draw an awful lot but in the end it is an intellectual
exercise (Tax of?cial, HMRC 3, 2005)
A number of things are interesting about this way of
framing the relations between interdiction, violation and
prize, ‘like a game of chess’. There is again a clear sense
of combat and opposition consistent with the themes of
interdiction and violation (so it is in this sense similar to
the extract above). Alongside this (again as in the extract
K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147 143
above), there is a desired, though not always realised, goal
to ‘win’, consistent with prize. Also though, and intrigu-
ingly, the advice to consider chess stems from a very basic
and unspoken recognition that the governance of taxation
is not an intellectual exercise. Drawing on Jakobson’s dis-
tinction (see Czarniawska, 1997b), the way that the exam-
ple of chess is used here is not based on a logic of
association (it is not syntagmatic, or metonymic). Instead
it is based on a logic of substitution (it is paradigmatic,
or metaphoric). The emphasis on cold reason, consistent
with stereotypical portrayals of accounting as practice, is
necessary precisely because this is not a game of chess.
This is what informs the caution, ‘don’t get personally in-
volved’. This advice is about creating a safe distance for
those many occasions (which we have described as skir-
mishes within an overarching narrative) when the prize
is not realised. As cautionary advice, there is almost a par-
adox here: this senior tax of?cial’s encouragement to new
recruits to see this as a game or intellectual exercise is only
needed precisely because for HMRC of?cials it is not a
game or intellectual exercise. Whilst invoking chess is
intended to offer some kind of protection, distance, and
insulation, it actually reinforces that the strong plot of
the folk tale (a combative struggle with moral dimensions
and with themes of interdiction, violation and prize) is at
work here.
Below we offer two more, related examples that illus-
trate how interdiction, violation and prize are relied on,
again in a context that is complex and murky, to frame pro-
gression through a professional career in taxation. First is
an example of an of?cial describing the reasons why some-
one may not have been promoted to a higher grade:
the reason for the more lowly grade is that they haven’t
really had the ability to negotiate, its been black and
white. I mean, obviously with any system of negotiation
you’re making work at the edges, but this, in fact has
been quite a bit sort of issue, the negotiation and the
fact that we have settlements about major issues (Tax
of?cial, HMRC 4, 2005).
This of?cial was relating how entrants to HMRC begin
their professional careers with clear categories for what
is acceptable, a view of ‘black and white’ re?ecting Propp’s
functions of interdiction and violation. Complexity is
inherent in the work and the legislation, meaning more se-
nior of?cials ‘work at the edges’ and so career development
is partly based on being able to see beyond ‘black and
white’, which is necessary to ‘the ability to negotiate’.
Interdiction and violation remain fundamental, but profes-
sional identity is predicated on success in attaining the
prize, ‘settlements’.
A parallel quote from an MNC perspective, again using a
black and white trope, is given below:
there’s a distance between where the inspector is and
where the tax payer agent is... if you got really close
to the black then you’re doing really well. If you got
there – a bit too close to the grey... I would do a deal.
Because that’s what they were after at the end of the
day to get a deal done (Tax manager, P1, 2005).
Interdiction is to keep things lawful, or in ‘the black’,
and violation is ‘too close to the grey’, with the prize being
‘at the end of the day’, ‘a deal’. The same basic ‘strong plot’
(Czarniawska, 2004): interdiction > violation > prize helps
both public and private sector accounting professionals
make sense of their work as an ongoing accomplishment
in this complex context.
Implications
Our analysis demonstrates how complex events are
emplotted: ?tted or mapped onto kinds of story
(Czarniawska, 2012a; White, 1973). Emplotment helps
structure interpretation and – for the same reason – famil-
iar plots like the rudimentary arc: interdiction > viola-
tion > prize; can mislead and obscure complexity. It
follows that we can identify more widely the role familiar
plots play in governance, and see where these plots are
helpful or unhelpful (by helpful, we mean succinctly to re-
fer to the public good). Where they are helpful our ap-
proach offers a guide to strengthen them. Where they are
unhelpful we can devise new conceptual categories that
re-package rather than pre-package. If we know the kind
of story events are being ?tted into, we can identify limita-
tions in consequent prescriptions or interventions. A num-
ber of implications follow from this. We begin this section
with an implication for theory and develop two policy
implications from this. We conclude this section with con-
siderations about implications for the profession.
Governance requires players understand the ‘rules of the
game’ (Picciotto, 2007). The governance of taxation is an
informative context in which to consider this, because the
key issue of avoidance or evasion indicates that despite a
black and white interdiction, in practice things are grey. As
extracts from our ‘tax tales’ show, these rules are complex:
negotiated, learned, enacted and renegotiated. But, there is
a missing aspect to this which emplotment can illuminate.
This is to identify the original source of rules: the common
ground that is necessary before one can even begin to nego-
tiate. Sometimes this is described in terms of a common
macro-social contract (Donaldson & Dunfee, 1995); or
shared hypernorms (Calton & Lad, 1995). Emplotment pro-
vides an alternative, additional way of understanding the
wellspring of such common ground: it originates in kinds
of story. This source for the ‘rules of the game’ can take us
closer to devising prescriptions for policy since whilst we
cannot change a macro-social contract, or hypernorms in
society, we can change how we use stories.
A policy implication follows from this implication for
theory. We can consider an instance where a story could
be said to be failing us. In folk tales, ‘baddies’, transgress,
are discovered, face judgement, and are punished. This
simple logic features in media portrayals of public inqui-
ries into complex ?nancial questions. For example, com-
mentators on the UK Treasury Select Committee’s (TSC)
hearings describe witnesses representing MNCs as ‘vil-
lains’, ‘hauled’ before the TSC where they ‘come under
?re’ from ‘salvos’ as ‘?ngers are pointed’ (e.g. Christodou-
lou, 2010; Davies, 2013; Kollewe, 2012). The theatre
144 K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147
attendant to such hearings may appeal because it ?ts
expectations about what should happen to ‘villains’ in
‘the end’. We have a governance mechanism (public in-
quiry) that satis?es the logic of a story-structure but it
also may not be effective. Whilst they may be repre-
sented as such, MNCs are manifestly not ‘villains’ and
taxation raises complex issues which are not publicly
accessible. Such issues do not ‘end’: Chief Executives
move, new instruments are devised, MNCs relocate, the
law changes, the next ?nancial year begins, witnesses
‘stonewall’ (Elliott & Treanor, 2012), and so on. One sug-
gestion that follows from our focus on emplotment is to
consider how to rewrite the role of the public in such a
story. An implication from our analysis is that simple plot
arcs underpin our understanding of taxation governance.
Inquiries place the public as spectators to a story of trial
and punishment. Less frequently perhaps, they invite a
view of the public as a passive, remote or abstract
mandate for the actions of politicians. Either picture is mis-
guided since the public are consumers, shareholders,
employees and customers engaged in long term relation-
ships with MNCs. More effective sanctions for corporations
could come about if the public were understood as active
participants in an ongoing story of shared responsibility.
Relatedly, another implication is to consider instances
where this familiar plot arc, and aspects of sense-giving
associated with it, may help with more effective gover-
nance of taxation. An additional strategy by public bodies
charged with increasing revenue could be to craft
announcements, rulings, and procedures that utilise the lo-
gic of this story structure. This goes beyond the simple
attribution of a label such as villain. For public bodies
who perceive a company to be defaulting on their social
responsibility by avoiding tax, it is not enough to paint
the company as villain. Instead, as we emphasise here,
such labels need to be understood as part of a mix of inter-
locking characters and actions that make a story. For in-
stance MPs may be uniquely placed to give a CEO a
‘grilling’ or ‘salvo’, but the actions of the public are poten-
tially far more in?uential on corporate strategy. The public
are capable of buying products from other retailers, using
other companies’ services, investing in other companies,
lobbying, complaining through social media, and so on. Fi-
nally, for policymakers and government agencies such as
HMRC, our emphasis on the role of strong plots
(Czarniawska & Rhodes, 2006), suggests alternative ways
in which to scrutinise the accounts and representations
of events of multinational companies, not simply through
direct analysis, but by mobilising different constituencies
and the wider public. We need not be wedded to a
simplistic, essentialist or structuralist account here: plots
can be made strong through conventions and routines
(Czarniawska, 2004). In challenging the governance of
multinational companies over their tax affairs, public
bodies could also seek to expose simplistic assumptions
in the accounts given by representatives of these compa-
nies and recover complexity where there is a rudimentary
implied narrative with shareholder return as the ultimate
prize. This may take on particular resonance in times of
austerity since simplistic narratives of shareholder return
may become less convincing where public services are
undergoing cuts and redundancies are threatened. Turning
‘tax tales’ into folk tales opens up new ways of thinking
about countering aggressive avoidance.
Seeing‘taxtales’ as folktales alsooffers freshscope tocon-
sider accounting as a professional project. It is well under-
stood Friedman and Lyne’s (2001) ‘beancounter’ stereotype
is out of step with studies that understand accounting as a
set of historically contingent social practices that do not just
re?ect economy but constitute it (Carnegie & Napier, 2010;
Napier, 2006). Nonetheless it features over time in literature
on accountants’ image (Beard, 1994; Bougen, 1994; Cory,
1992; DeCoster & Rhode, 1971; Dimnik & Felton, 2006). The
stereotype lags behind the transformation of accounting as
apractice, andattempts bytheprofessionitself toinstitution-
alise alternative images of accountants as business profes-
sionals (Carnegie & Napier, 2010). Reduction to a stereotype
is also overly simplistic, not just because these often involve
minglingdifferent, context sensitiveimages andassociations,
but because monolithic accounts of profession overlook
broader historical factors (Chua & Poullaos, 1998). As
practice, accounting can only offer a ‘mirage’ of objectivity.
1
As a specialism, given the complexity of taxation, the image
we have of tax accounting is arguably an ampli?ed version of
such traits. What we show in relation to this here is rather
intriguing though. Aspects of this stereotype do play a role
within taxation, but it is precisely because accountants do
not conform to the stereotype. The advice given to new en-
trants to tax at HMRC (above): ‘‘don’t get personally involved’’
andtreat it ‘‘likeagameof chess’’ is onlynecessarybecauserev-
enue of?cials do get personally involved, and because this
work has combative and moral dimensions which they make
sense of in terms of public goals. The role this stereotype plays
here is as self-preservatory myth. Myths in a sociological or
anthropological sense are not necessarilyfalse (theyoftenhave
notruthvalue), but theyarelogics that support action(Bradley,
Erickson, Stephenson, &Williams, 2000). The ‘mirage’ can per-
haps be a relieving distraction when remaining objective and
impartial seems far away.
Conclusion
Folk tales are part of sense-making and can be vehicles
for inference that ‘pre-package the world’ (Abbott, 2008:
40). They are also sense-giving because they furnish us with
frameworks that are both descriptive and constitutive. To
study narrative through the lens of the folk tale, in combi-
nation with Propp’s framework, makes some of the dif?cul-
ties involved in making sense of this context very clear.
Public narratives about the role of HMRC, or the mission
of a MNC seem to ?t this framework very well. Private nar-
ratives about individual identity and purpose – the ‘tax
tales’ we concentrate on here – are more complicated yet
they can still be described in terms of Propp’s characters
and the narrative arc: interdiction > violation > prize.
Something that thematic or content analyses of our ‘tax
tales’ would be less able to re?ect is that the identity of
characters changes. HMRC and MNCs have shifting identi-
ties as heroes, false heroes, helpers and villains that change
1
We are grateful to Wai Fong Chua for this phrase.
K. Morrell, P. Tuck / Accounting, Organizations and Society 39 (2014) 134–147 145
through context and history, and also in terms of who is
acting as narrator, or who the intended audience is.
The idea of a de?nitive ending may be illuminating if
we consider the ultimate purposes of political administra-
tions, ministries, and MNCs, but it is also simplistic. These
actors have prizes that they strive for and that are often
speci?cally time-bound: re-election, defence of their bud-
get, protection of shareholder interest, ?nancial targets.
But it is also often unrealistic to think in terms of endings
given that this context changes and evolves through
unfolding relations between multiple actors (who them-
selves change and evolve). At the same time, speci?c cases
of tax avoidance attract such media attention and public
disapproval that the attraction of the concept of prize re-
mains, and for analytical purposes this makes invoking
the rudimentary narrative arc interdiction > viola-
tion > prize appealing too. In a number of ways, the limita-
tions we encounter while thinking ‘through’ folk tales can
assist our attempts to understand this more complicated
setting. We also need to acknowledge, if only brie?y, that
this paper is itself a narrative, it is related, sequenced, con-
text speci?c and re?ects our point of view (Barthes, 1977);
although ultimately it is not perhaps for us to identify what
kind of narrative, ‘science... epic... quixotic fantasy... conspir-
acy theory [or] divertissement’ (Morrell, 2008: 628).
The transferability of Propp’s research strategy and the
obvious resonance his functions and characters have in this
context raise intriguing questions. We argue that the scope
to apply his work – a crystallisation of the folk tale – re-
?ects deeper structures of sense-making that are common
to different kinds of narrative, including accounts of gover-
nance and taxation. For us, in this context, we ?nd enough
evidence to suggest that part of what governs tales about
tax – in the media, by public of?cials, and by senior
accountants in both public and private sectors – is com-
mon to the logic of the folk tale. As adults, we may remain
constrained, enchanted, and enlightened, by the recipes we
learned for making sense of the world as young children.
Acknowledgments
We would like to thank Wai Fong Chua, and three anon-
ymous reviewers for their very helpful comments. Thanks
also to Graeme Currie and Mark White for their comments
on an earlier version of the manuscript.
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