Building Public Trust

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  • Publication
  • 30 minute read
  • March 05, 2024


The tax landscape continues to evolve rapidly, with a convergence of global and local corporate reporting and sustainability disclosure standards and guidelines.

In this 8th edition of our Building Public Trust through Tax Reporting publication in South Africa, we continue to explore the value derived from being transparent on tax. We consider why tax is material to both internal and external stakeholders by going “back to basics”: tax transparency is really the tip of the iceberg. What lies beneath is a robust framework that governs tax and an understanding of how tax fits, not only into the business model, but also the operating and technology model that enables it. The mindset change is significant, but necessary. Therefore, we also have challenging conversations that are necessary to navigate the tax transparency landscape.

For Our Humanity: A call to action

A rolling series of global dislocations are creating intense new challenges for society. Now more than ever, many people expect businesses to be guided by a clear purpose and deliver value to society.

Ubuntu Bethu is an ancient African mantra meaning “Our Humanity”. We believe there is a call to action: to work together to deliver sustained outcomes for communities and society – whether they are capital markets, tax systems or the economic systems within which business and society exist.



Rethink, reinvent and remain relevant

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In the face of a relentless rise in regulatory demands, today’s tax leaders encounter an enduring imperative to reinvent their approach to tax, to rethink how tax fits into a complex operating environment and how they communicate their broader sustainable tax strategy to remain relevant.

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In the face of a relentless rise in regulatory demands, today’s tax leaders encounter an enduring imperative to reinvent their approach to tax, to rethink how tax fits into a complex operating environment and how they communicate their broader sustainable tax strategy to remain relevant.

It is important to ask whether tax is material to the business. If the answer is yes, have the difficult and important conversations, prioritise and take action.


Trust, tax and transformation

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As the measures for company performance expand beyond financial metrics, companies have an imperative to build trust and transparency among different stakeholder groups.

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As the measures for company performance expand beyond financial metrics, companies have an imperative to build trust and transparency among different stakeholder groups.

Trust has always been important to PwC. It’s part of our organisation’s purpose: ‘to build trust in society and solve important problems’.

Essential to building societal trust is comprehensive and comparable tax reporting, but if an organisation does not have a robust framework to govern tax in place, the organisation cannot craft a credible narrative for taxes and how they are managed.

Invariably, tax leaders need to be more transformative in their approach to tax, their tax operations and their tax narrative. Adopting innovative approaches to governance, risk management, process improvement, engagement and a connected, data-driven approach will help accelerate your ability to transform.




When is tax material

Sustainability teams, CFO’s and Tax Directors take note – when considering tax as a material topic, companies should consider the potential impact of the following scenarios:

  • Potential understatement of tax liability.

  • Evidence of a lack of consistency and governance impacting the company’s approach to tax.

  • Perception that the company does not pay the correct amount of tax.

  • Unresolved / open assessments and / or audits or recent settlements with revenue authorities.

  • Perception that the company uses aggressive strategies to minimise tax.

  • Limited / no public disclosures on tax.

  • Operations in various low tax jurisdictions.

  • Media attention in relation to taxes.

Taxes paid by a company represent a significant financial contribution to social initiatives and these taxes support public services, environmental objectives, educational programs, health and welfare projects. 

Tax Directors play a vital role in ensuring that tax is embedded as a key strategic influencer in fulfilling their organisation’s sustainability objectives. Making sure tax is included in materiality evaluations and brought to the attention of stakeholders is one approach to help people understand the risks, opportunities and sustainability impact of tax.

First governance then transparency, getting the basics right

The quality of an organisation’s framework to govern tax is an important element in building trust – to show governments and other stakeholders that businesses take their obligations seriously. Without it an organisation will not be able to share a creditable tax story with its stakeholders. 

A framework to govern tax requires establishing tax governance structures, a sustainable tax strategy, tax risk management and robust tax operations. Such a framework should allow for performance management and regular assurance to ensure that what was designed is implemented and is effectively operating.


A clear understanding of the structures within the organisation that govern tax.

A coherent approach that can be communicated within tax and to the wider business.

 A consistent approach to the identification and management of tax risk to support reliable and quick decision making.

A clear tax operating model ensuring consistent delivery of high-quality services to the business.

A formalised methodology to review performance and obtain assurance that the framework to govern tax is operating effectively.

What does tax transparency mean for South African companies


  • Engage with the sustainability team and the owners of the organisation’s reporting suite to understand the key governance, regulatory and reporting frameworks and align with what is on the horizon.

Identify stakeholders

  • How does the organisation engage with stakeholders?

  • Who are these stakeholders? Should additional stakeholders be included for tax purposes?

  • What is it that these stakeholders want to know?

Consider aligning with peers

  • Many companies are proactively addressing tax matters in a manner that goes above what is required by law applying various guidelines to provide effective and comparable disclosure of their tax practices.

Consider your footprint and location

  • Global tax policy changes and legislation enacted in jurisdictions in which the organisation operates may have a direct impact on public tax reporting. It is important to understand whether the organisation is impacted by these changes and whether a public reporting obligation arises.

Translating voluntary tax reporting into business reality

Many organisations consider their tax disclosures in terms of ‘for whom and what purpose they are reporting’ instead of simply following a tick-the-box exercise to meet certain requirements. It’s important to say upfront that there is no one-size-fits-all approach and, depending on geography, sector, and other factors, different businesses will come to different conclusions at different times about how much and what information should be disclosed to build trust with their stakeholders.

The PwC Tax Transparency Framework (the Framework) is intended to guide companies in developing a tax transparency strategy that is fit for purpose. In this publication, we share the results of studying the tax disclosure of the top 100 companies listed on the JSE based on their market capitalisation on 31 December 2022 in the context of the Framework. Annual reports, corporate social responsibility reports, annual financial statements, integrated reports, tax reports, sustainability reports and other relevant publicly available information for the 2022 financial year were reviewed in our assessment.

This year we assess a total of 43 broadly defined tax transparency criteria in the Framework that we consider to be the basis of good practice in voluntary tax reporting and a maximum score of 80 can be attained.

The criteria are grouped under the following four main categories:

A context
B context
C context
D context

New this year

We are fortunate to be able to provide readers with a comparison of performance reported between the data assessed for 2022 and the results reported in our previous report for 2021 as we maintained similar categories, criteria and weighting in the research conducted.

Key findings

Average overall score for total tax transparency by industry

Average overall score for total tax transparency by industry

Base: 100 JSE listed companies | Source: PwC Building Public Trust Study 2022

As in previous years, on average the telecommunication sector consistently provided the most effective transparency on taxes with a score of 40, the basic materials sector followed with 34 and the energy sector with 32. 

The best performing company is part of the financial sector. 

Out of the 20 top performing companies, 9 companies are in the basic materials sector, 5 companies are in the financial sector, 2 companies are in each of the telecommunication sector and technology sector and one from each of the energy and industrial sectors.

Average transparency score per category of the PwC Framework

Average transparency score per category of the PwC Framework

Base: 100 JSE listed companies | Source: PwC Building Public Trust Study 2022 and 2021

Average transparency score per category - per sector

We are pleased to see that in each category companies have improved their disclosure in 2022. The 6% increase in reporting total tax contribution and wider impact is especially worth noting.

Average transparency per category - per sector

Base: 100 JSE listed companies | Source: PwC Building Public Trust Study 2022

The average transparency per sector is dependent on overall tax transparency demonstrated by all companies in the sector. It is noted that in the year-on-year comparison of the average transparency per category, by sector, most industries demonstrated more transparency per category. The most significant increase is demonstrated by the technology sector in the tax strategy and risk management category.

Findings from our judging panel

Each year, our independent judging panel commends companies with a primary listing on the JSE that demonstrate the highest level of tax transparency based on the PwC Tax Transparency Framework. Below we have summarised their findings for each of the highly commended companies.

Best performing in tax reporting


The independent judging panel agreed that Nedbank provided well-articulated and comprehensive reporting in all categories and addressed most of the criteria of the Framework.

Highly commended for consistent performance in tax reporting


Old Mutual


The judging panel identified Exxaro, Old Mutual and Vodacom (in alphabetical order) as companies who are consistently providing value-added, high-quality tax disclosure based on the criteria of the Framework.

Highly commended for most significant improvement in tax reporting


The judging panel commended Discovery for its significant improvement in tax reporting year-on-year, based on the Framework.

Our judging panel

Co-CEO of FluidRock Governance Group (Pty) Ltd

Senior Lecturer University of Pretoria

Head of Taxation Department of Finance and Tax Faculty of Commerce, University of Cape Town

Head School of Accountancy, University of Witwatersrand

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We value our judging panels’ contribution and celebrate their insights by quoting extracts from their feedback

Each year we are humbled by the calibre of knowledge and experience that our judging panel brings to the Building Public Trust through Tax Transparency project, and this year is no exception. They are a part of our community of solvers and bring independence, gravitas and a wide field of expertise to the assessment of the disclosure provided by companies included in this study.

"It has become an accepted principle that tax compliance should be part of the social contract of any organisation. Put differently, being a responsible corporate citizen entails, among other things, being a responsible taxpayer in the country of operation. It is therefore pleasing to witness the global move towards greater disclosure of tax related information. Unfortunately, as with many other sustainability related topics, different frameworks make for a fragmented reporting universe. Hopefully global reporting standards will emerge over time to facilitate value adding disclosures and comparisons in the interest of greater transparency.

Food for thought when contemplating a tax report:

While lengthy and colourful reports often do contain valuable information, an approach of ‘substance over form’ and/or ‘less is more’ can result in more credible and  informative reporting.  

Often tax reports contain very similar statements relating to the commitment to being law-abiding, responsible corporate citizens and/or taxpayers. Experience to date has however confirmed that such statements cannot always be taken on face value and need to be judged against the DNA, culture, ethos and/or values of the organisation. Thus, while being recognised for transparency is to be commended, it is ultimately the behaviour of leadership at all levels in the organisation that ‘speaks the loudest’.

A valuable insight into the effectiveness of the tax management and risk element, is a high-level overview of the profiles of members of the tax leadership team in the organisation as well as the specific areas of responsibility of the tax function.

While difficult to substantiate, the general ‘spirit’ of a tax report can be tangible if it provides the reader with a sense of credibility and authenticity. This is in comparison with some Reports that seem to contain more theoretical and/or abstract statements than ‘at the coalface’ detail and information.  

Although extensive information on tax can be set out in various reports with use of cross-referencing to guide the reader, it is useful to include a high-level summary of such information in the tax transparency report. Additionally, adding substance to information provided in respect of the topics of sustainability and value creation for the business and its stakeholders from a tax perspective is recommended.

While the substantial tax contributions being made by reporting entities are commendable and they are not directly accountable for how the taxes are used, there is a need for business to work with governments and civil society in addressing the many social challenges – a number of which are as a result of the ineffective use or misappropriation of taxes. While it can probably be understood why companies may be hesitant to report and elaborate on such initiatives, it is hoped that this will indeed form part of the approach to being a responsible corporate citizen for all."

Annamarie van der Merwe | Co-CEO of FluidRock  Governance Group (Pty) Ltd

“Transparent tax reporting serves to mitigate tax-related reputational costs which might be imposed on a company by the public. It provides context to an arbitrary indicator such as the effective tax rate, which could easily be misinterpreted. It also serves to inform policy makers on the important economic contribution of large companies to the fiscal revenues of governments.”

Lizette Kotze | Senior Lecturer University of Pretoria

“One of the most critical assets to a MNE is trust. When stakeholders consider that an MNE’s actions or its underlying motivations fail to meet their expectations of reasonable corporate tax approaches, this may put long-term profitability and sustainability at risk.

The complexities and uncertainties in the application of tax law, move corporate tax payments, or the perceived lack thereof, into the realm of corporate social responsibility. Considering the context of complexity and uncertainty in the application of tax law, the most tax responsible thing to do is to be aggressively transparent in relation to the questions that concern stakeholders. Some of the key questions include: 

Is the board accountable for the tax policy? How? 

What is the tax strategy of the group and how is it implemented?  

What is the tax policy of the group and were the trade-offs made between stakeholders in developing the tax policy articulated? 

Where are the various entities owned by the Group tax resident?

Where do they do business? What do they do? 

What is the effective tax rate of the Group and how much cash tax does it pay in each of the jurisdictions in which it does business? 

These and other key questions will be answered by those companies who adopt a robust framework to tax transparency, considering the Integrated Reporting Framework, King IV, the B Team Responsible Tax Principles, the GRI 207, among others.

However, complying with the above frameworks will not be enough if the way in which these frameworks are approached is as a tick box exercise. Rather, the spirit of transparency must permeate the tax disclosure.”

Tracy Johnson | Head of Taxation Department of Finance and Tax Faculty of Commerce, University of Cape Town

“Tax is being incorporated into certain wider sustainability reporting frameworks. Companies should consider demonstrating how their tax strategy and practices align with their sustainability strategy and goals. The impact of tax is seen on not only the Financial Capital of a company but also its Social and Relationship Capital. There are a number of instances where the reputation of a company has been severely impacted because of its relationship to tax authorities and the manner in which it has conducted its tax affairs. Tax is therefore an integral part of the operations of a company and part of its creation or destruction of value. As with other aspects of reporting, companies must consider what they consider to be material from a reporting perspective and then report accordingly. For many entities, tax may be one of those areas that companies consider important to report upon in the interest of transparency and providing a more informed view to their stakeholders.”

Zubair Wadee | Head School of Accountancy, University of Witwatersrand

How can we help

The tax transparency landscape is evolving rapidly and becoming more complex. Keeping up to date with how your peers are responding and understanding what information your stakeholders are looking for is increasingly important, but also increasingly challenging. Our benchmarking report can show you how you compare to your peers and offer insights into areas for potential development to meet stakeholder expectations. We are well placed to support you in designing your tax transparency strategy, and provide you with valuable tax reporting, governance and risk management strategies and recommendations, along with insights leveraging our market intelligence and global reach. 

Please contact us should you wish to discuss any of the topics explored in the report further.

Contact us

Kyle Mandy

Kyle Mandy

Africa Tax Technical and Tax Policy Leader, South Market Area Tax Sustainability Leader, PwC South Africa

Tel: +27 (0) 11 797 4977

Carla Perry

Carla Perry

Senior Manager | Tax Reporting and Governance Specialist, PwC South Africa

Tel: +27 (0) 78 735 9393

Kerneesha Naidoo

Kerneesha Naidoo

Manager | Tax Reporting and Strategy Manager, PwC South Africa

Tel: +27 (0) 83 627 3956

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