Building Public Trust

Tax as a strategic asset

Taxes are one of the ways in which businesses contribute to society. The positive impact of taxpayers operating in Africa should be acknowledged, put in the right context and communicated in a transparent manner.

There is value in integrating reporting on tax sustainability and economic impact. Open dialogue with stakeholders and easily accessible information about tax can demonstrate value creation for all stakeholders, improve business reputation by building trust and reinforce the licence to operate.

It is recommended that companies demonstrate how their actions meet stakeholder expectations and how these actions are consistent with brand values. Companies that are getting their tax messaging right have identified material tax-related communications and embedded these into their long-term value-creation story.

Building trust – becoming a visible part of society

CEOs in Africa recognise the opportunity to build their own brands, but as social, political and economic events hit the boardroom, they also recognise the need to step forward to make a meaningful contribution and rebuild business confidence for the long term.

For many stakeholders it’s no longer enough for organisations to view their tax position through the lens of financial reporting. Increasingly, organisations are challenged to provide more information. Governments, the public, employees, investors and the media are looking for evidence that organisations are committed to building a more sustainable and inclusive economy and are becoming a more visible part of society, with senior executives and governing bodies explaining how their organisations’ tax strategies are responsible and align with their sustainability commitments.

The PwC Building Public Trust through Tax Transparency initiative

PwC supports this initiative to encourage and promote greater voluntary transparency in tax reporting. In this way we are able to demonstrate trends that are shaping the tax transparency landscape and recognise best performing companies that are using voluntary tax disclosure to tell their story, thereby demonstrating good corporate citizenship as responsible tax payers.

There are a range of approaches to disclosure and it is important to consider the purpose of each transparency initiative and the value it will bring to the taxpayer and its stakeholders. For some companies, where the business case is insufficient, there will be little activity in this area. Others, however, have dedicated time and energy to developing voluntary disclosures and driving the debate on tax transparency.

Tax transparency reporting for the financial year ending 31 December 2018

It is against this backdrop that we give credit to companies that used voluntary tax disclosures to tell their story, thereby demonstrating corporate citizenship as responsible taxpayers.


Best company

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Best performing company with a primary listing in South Africa and a multinational presence[1]


Similar to their previous disclosures, MTN produced a comprehensive set of tax disclosures in 2018. The judges indicated that the disclosures highlight the company’s commitment towards tax transparency. MTN addressed the majority of the disclosure criteria related to ‘Tax Strategy and Risk Management’ providing a comprehensive overview of principles governing approaches to tax and the link to companywide risk management.

The company provides a good breakdown of its ‘Total Tax Contribution and Wider Impact’ per jurisdiction. The judges felt that the effectiveness of MTN’s tax transparency reporting stems from the integration of its tax disclosures with other company-related disclosures. The information is also presented in an easy to understand manner.

MTN communicates its purpose, wider societal impact and licence to operate by measuring its value distribution to stakeholders, its impact on the economies in which it operates and linking it to its total tax contribution. The company provides a description of the assurance process for disclosures relating to tax payments to governments. It also provides a detailed discussion on its lobbying efforts and manages to explain its stakeholder relationship with tax authorities in good context. MTN also provides additional overview of its tax technology transformation which is unique. The judges praised the company’s comprehensive overview of its adherence to King IV principles as they relate to tax governance

[1] A company would fall into this category if the foreign sales are more than 50% of the total sales.

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Best performing company with a primary listing in South Africa that have a predominantly national presence[2]


Similar to previous disclosures, the judges were impressed with Vodacom’s comprehensive set of tax disclosures in 2018 and felt that its ‘Public Finances report’ illustrates key tax facts and findings by utilising charts and figures that are easy-to understand. It was evident that Vodacom disclosed almost all the criteria in the tax transparency maturity framework to a certain extent.

The judges commented that Vodacom’s detailed breakdown of its direct tax borne, indirect taxes collected on behalf of the government and other non-tax payments as well as comprehensive information on certain financial indicators such as revenue, profit/loss before tax, EBITDA, number of employees and capital expenditure on a country by country basis stood out. There was a good articulation of its tax strategy and principles, lobbying and public consultations on industry tax. One judge also commented that what tipped the scale in Vodacom’s favour was the integration of the tax disclosures in the company’s Integrated Report.

[2] A company would fall into this category if foreign sales are less than 50% of total sales.

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Companies that are highly commended for their effort to provide voluntary information on tax


The judges commended ABSA for the way in which it linked its total tax contribution to the Board’s responsibilities in terms of King IV and governance of tax. In addition, they appreciated the detail provided on the company’s tax code of conduct, tax contribution breakdown per jurisdiction and per type of tax.

AngloGold Ashanti

The judges commended AngloGold Ashanti on its well-documented information regarding its tax controversy exposure, and the potential impact on stakeholders, through detailed explanations and quantification of its risk in respect of amounts due to or disputes with revenue authorities. In addition, the company was commended for its level of integration and consistency of the tax disclosures across all its public reports.


Aspen Pharamacare Holdings Limited was commended by the judges for its provision of a clear understanding of the effective tax rate drivers, year-on-year variance and value-adding additional / supporting narrative to explain line items in its tax rate reconciliations. They appreciated the graphics used in the Annual Financial Statements to demonstrate each country’s tax liability. There was good disclosure on tax risk appetite, mention of approach to low tax jurisdictions and engagement with stakeholders.



Sheralee Morland

Sheralee Morland is the immediate past president of the Institute of Risk Management of South Africa (IRMSA) and served on its executive committee for nine years. She is a member of the Finance and Remuneration (REMCO) Committees and a Director of the Cruywagen-IRMSA Foundation. Ms Morland is an active volunteer in the activities of the SA Integrated Reporting Committee (IRC) and has been appointed to the Working Group from 2020.

She served as Executive Head of Enterprise-wide Risk Management at Nedbank for 12 years. Other professional roles include Old Mutual (Insurance/Asset and Investment Management/Pension Funds and Medical Aids), Standard Bank, EY and Anglo American (for the implementation of the UK Turnbull Guidance on Risk Management following Anglo’s listing on the London Stock Exchange).

She has experience in governance roles of auditing, internal audit and risk management in banking, insurance, asset and investment management, pension funds, medical aids and mining. Her passion for effective integrated reporting has instilled in her the belief that such reports must provide a comprehensive ‘one-stop shop’ for all the necessary information, ideally packaged meticulously in one document. She believes such reports must also serve as a brand and reputation enhancing creation. She currently plays her role in the capacity of CEO through Joshero (Pty) Ltd – for integrated reporting and Candid Assure (Pty) Ltd – for risk management.

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Loshni Naidoo

Loshni Naidoo is the integrated reporting project director at the South African Institute of Chartered Accountants. Her focus is to support members, the broader finance community and society, with information and tools to progress the conversation on sustainability, integrated thinking and integrated reporting.

Ms Naidoo began her career as a chemical engineer and worked for several years in the production and project environments, mainly in mining and chemicals manufacturing. Later, she moved into the accounting and finance fields, where her focus was on providing integrated reporting and sustainability advisory and assurance solutions to a diverse array of organisations.

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Parmi Natesan

Parmi Natesan is the Chief Executive Officer of the Institute of Directors in Southern Africa (IoDSA). She has been with the IoDSA for eight years, first as senior governance specialist and then as an executive at the centre for corporate governance, overseeing governance thought leadership, director training and certifications.

She is a leading corporate governance specialist in South Africa and has authored numerous articles and papers, and spoken at various conferences and events. She has served as an executive director on the IoDSA board for four years. She also serves on the boards of PPS Holdings Trust and Alviva Holdings as a non-executive director.

Ms Natesan represents the IoDSA on a number of forums and committees, including the King Committee of South Africa, the Integrated Reporting Committee of South Africa, the Anti-intimidation and Ethical Practices Forum, the 30% Club (which advocates for gender diversity on boards) and the Global Network of Director Institutes. The career accolades she has received over the years include the Rising Star alumni award from Nelson Mandela Metropolitan University as well as being named one of Destiny magazine’s top 40 African women under the age of 40.

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Prof. Madeleine Stiglingh

Prof Madeleine Stiglingh is head of the department of accounting at the University of Pretoria. Under her visionary leadership, accounting and finance at the university has excelled, which has led to her being considered one of the leaders in this field in the world.

In the 2019 QS Subject Field Ranking, accounting and finance at the University of Pretoria was ranked in the 201-250 band and in the 151-200 band in the 2019 Academic Ranking of World Universities (ARWU). Prof Stiglingh is also editor of one of the leading taxation reference works used nationally by both practitioners and students, ‘Silke on South African Income Tax’.

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Our methodology

The PwC Tax Transparency Framework (the Framework) is intended to guide companies in developing a transparency strategy that is fit for purpose. The Framework does not necessarily lead to more disclosure on tax matters but is intended to help companies make an informed decision on ‘transparency to whom and for what purpose’.

The Framework includes 57 broadly defined tax transparency criteria that we consider to be the basis of good practice in voluntary tax reporting. We use it to carry out an annual review of voluntary tax reporting and transparency of the top 100 companies listed on the Johannesburg Stock Exchange. The sample companies evaluated were selected based on their market capitalisation on 31 December 2018.

Annual reports, corporate social responsibility reports, annual financial statements, integrated reports and relevant website information were reviewed to conclude on our findings.

Our aim is to guide companies from the potential complexity of tax transparency to practical execution. With this in mind, we closely monitor developments regarding voluntary transparent tax reporting. In this context, we reconsider the criteria included in the Framework frequently to ensure that it aligns with global frameworks. This year it resulted in additional criteria being included compared to the previous year, which implies that a like-for-like comparison with the average transparency rating of the companies in scope in last year’s assessment cannot be made.

This year we also went one step further in our assessment methodology. In addition to assessing whether the companies in scope included a criterion in their voluntary tax transparency reporting, we also evaluated the Framework criteria on a five-point Likert scale to distinguish between different levels of quality of disclosure.

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How can we help:

If you are interested in a further discussion on your company’s tax transparency strategy or would like to participate in a tax transparency maturity assessment, please contact us here.


Contact us

Gert  Meiring

Gert Meiring

Tax Reporting and Strategy Southern Africa Lead

Tel: +27 (0) 11 797 5506

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