In the wake of the OECD’s BEPS project, there has been an explosion of interest in the closely related question of how tax systems ought to deal with highly mobile individual taxpayers.  The most obvious example of such a taxpayer is a high net-worth individual (HNWI) who can move easily between jurisdictions and whose choice of jurisdiction may be affected by tax rates, reliefs and administrative arrangements, amongst other considerations.  Yet we should not lose sight of taxpayers at the other end of the spectrum such as low-paid migrant workers, who may be paying considerable amounts of tax to their host jurisdiction without the capacity to make informed tax-efficient choices, or who, conversely, might be forced into the informal sector with few realistic opportunities to comply with their formal tax obligations.    

Either way, and as illustrated by recent debates surrounding the abolition of the UK’s preferential regime for non-domiciled individuals, individual mobility creates important challenges for democracy.  Contrary to the US Revolutionary slogan “no taxation without representation”, mobility can amplify the voice of at least some HNWIs even at the expense of revenue-generation (“reduce my tax liability or I shall leave”) at the same time as denying voice to others (“refugees must pay tax but cannot vote”).  In other words, it leads to potentially serious mismatches between taxation and representation.  Nor does citizenship provide any easy answers, despite its importance in signifying membership of political communities.  Citizenship has never been identical to subjection to the tax system (children, for example, are taxable but do not enjoy the full range of citizenship benefits), but in the context of ever-increasing individual mobility it is more difficult than ever to treat it even as a rough proxy for those who ought to be subjected to tax liabilities.  Indeed, tax systems can be expected to have to cope with increasing numbers of non-citizen taxpayers as well as non-taxpaying citizens.

Whether states ought to respond to these challenges with lower expectations of “no taxation without representation”, by making citizenship easier to obtain, by widening the franchise to include a wider range of non-citizens, or in some other way, raises an eye-wateringly complex series of questions that demand attention not only from lawyers but from a myriad of other disciplines.  It is hardly surprising, then, either that there has been a significant upswing in literature dealing with these topics, or that this literature has not yet settled on any consistent recommendations.   The Fiscal Citizenship Project, whose members are represented in the present volume, is perhaps driving the most systematic attempt to build a common vocabulary between disciplines, but it remains at a relatively early stage.

The present volume does not even attempt to compete as a systematic project.  On the contrary, it is gloriously various, representing the complexity of the problems involved as well as the sheer range of insights that are emerging across different jurisdictions and academic backgrounds. This approach is backed up by tolerant editorship that allows authors to speak for themselves rather than repeating an “editorial line”, which seems particularly well-judged in a young research area where the literature is still finding its way.  It encourages, instead of restricting or channelling, the growth of ideas.  All the same, variety is not the same as incoherence, and indeed the editors do an excellent job of drawing together the different strands and ensuring that the volume provides a meaningful and useful experience, whether read from the beginning to the end or dipped into. In this connexion, it is worth noting that both Lind’s introductory chapter and Brøgger and Björklund Larsen’s closing chapter focus on boundaries.  This is hardly a coincidence: the volume is all about boundaries, be they disciplinary, geographical, membership or tax conceptual. 

This neat bracketing of the issues is complemented by the exceptional clarity with which Bamford sets out many of the most relevant political philosophical questions in Chapter 2, which will be helpful for anyone working in this area but could equally be understood by the most recalcitrant first-year undergraduate.  In the following chapters, we read about a proposal for a more sophisticated concept of tax residency that would account for a wider range of life circumstances (Shanan and Narotzki); a new way of conceptualising fiscal citizenship (Schmidt and Matthaei); a proposal for increasing the relevance of tax payments to citizenship applications (Ramos Obando); an analysis of whether distinctions between citizens and non-citizens, if used carefully, might help states to respond to the challenges of taxpayer mobility (Lindsay); a discussion of the citizenship position of corporates (Scherer); the treatment of non-citizens within automated tax risk-management systems (More and Schenke); the importance, and misuse, of taxpayer status in defining political communities (Davis); the anomalous and potentially pointed exemption of agricultural workers in the US from certain fiscal obligations (Sarkar); the different status of taxpayers in the Canadian and Chinese tax systems (Li); and the scope, design and operation of cooperative compliance programmes in Norway and Sweden (Brøgger and Björklund Larsen).

I greatly enjoyed reading this book and would heartily recommend it to anyone who is or who might conceivably be interested in this emerging area of research.  In common with many if not most edited collections, the volume is not entirely even, either in quality or relevance to the topic.  Without wishing to single out any particular author, I sympathised with the attempts to develop theoretical and philosophical frameworks but felt that some were more successful than others.  I also thought that some of the boundary issues, in a field of study replete with boundaries, were presented by authors in a rather over-simplified or at least stylised way; still useful, but perhaps a starting-point for further discussion rather than a destination.   Finally, there is some evidence of “shoehorning” of topics into the scope of the volume, though, in balance, one of my most valuable experiences was realising that the final chapter on cooperative compliance is not at all shoehorned but instead highlights the themes of the book in a new and (for me) unexpected way.

These minor reservations, ironically, highlight one of the things that I enjoyed most about reading this volume, which is its exploratory quality.  It provides a coherent overall experience, as would be expected from editors of this calibre, but it is not overly tidied.  It is suggestive of directions rather than attempting to close down possibilities.  This, in turn, indicates a field of enquiry that is on its way up rather than one that has been answered and is exhausted of inspiration.  This sense of excitement and newness is more than captured in the volume and is one of its real strengths.  Apart from anything, it is fun to read, full of insights and inclusive.  It invites the reader to join in, and it is to be hoped that this invitation is accepted widely.

I am honoured to be the ‘main investigator’ on an exciting, funded project that we have called Fiscal Citizenship. Our work started in March 2021, 18 months after submitting a grant application, and in this blog post I want to share with you some insights about the process of securing the funding for the project and our progress so far.

The fiscal citizenship project builds on ideas that came from experience with an earlier unsuccessful funding bid that we developed further and modified for the current project. Our current funding source is the Open Research Area (ORA), a joint initiative between the research funding councils of five countries. Applicants were invited to develop proposals in any social science area and were required to include researchers from at least three of the five countries. The UK funder, the Economic and Social Research Council (ESRC), managed the process on behalf of the other research councils. We set about developing a consortium of researchers from the UK, Canada and Germany and made some early decisions about what we would research; essentially willingness to pay taxes from an interdisciplinary perspective, with special attention to the experiences of migrants. 

The timing was a nightmare. We produced a first draft of a case for support in July 2019, with the final bid due to be submitted in mid-September 2019. Unlike most calls for funding which ask for an outline bid followed by a full proposal from shortlisted applicants only, the ORA call required both an outline and full bid to be submitted at the same time. The UK and Canadian funders set limits on the amount of funding, but not the German funder, which made the budget calculations tricky to say the least. 

The funding call specified that there must be substantive research in an integrated work programme that demonstrated the value of transnational collaboration. We were very fortunate that our chosen collaborators were enthusiastic and willing to contribute to developing the workplan, but the process was complicated due to the timing over the summer period with various people on holidays at different times. We agreed early on that the bid would be primarily based in the political science literature, but of course one of the joys of being a tax researcher is that it is easy to find research across a wide range of academic disciplines and in the end our team comprises researchers from (in no particular order) political science, law, accounting and anthropology. Agreeing a set of individual studies that in aggregate would form an integrated work programme took considerable effort and we met the submission deadline with a bid for approx. £1.3m in total spread across the three countries.

Why ‘fiscal citizenship’? We decided the term best captured what we were trying to analyse. It is a term that has been used by several authors, to whom we are grateful, but is not usually defined with any specificity^[1]. We embarked on the project with high hopes of pinning the concept down and spent a lot of time in the early months of the project debating the scope of fiscal citizenship for the purposes of our research. This was partly a process of breaking it down into the two components – fiscal (what is covered – taxes, social security payments, other forms of contribution), and citizenship (legal or other forms of belonging). I’m not sure we have yet pinned this down, but it provided an excellent starting point for the team to get to know one another and explore our respective knowledge bases and interests. 

Our workplan includes several separate but related studies using a variety of research methods. Our original grant application promised a population survey across all three countries, ethnographic work and laboratory experiments. We are fortunate to have a brilliant group of PhD students who have embraced the overall project with great enthusiasm. The rest of us bring a range of prior research experience to the project, from early career researchers to old hands like me. 

A major complicating factor was, of course, the small matter of a global pandemic, during which the world slowed down at best and at worst ground to a halt. How does one start a multidisciplinary international collaborative research project where not all team members know each other? Looking back, we achieved a lot in a virtual world. We started having regular meetings on Teams, some with presentations from team members, some discussions with visitors and lots of lively discussion. Eventually we formed sub-groups around the different projects but continued our full team meetings when possible. The big breakthrough, from an interaction point of view, came in May 2022 when we were finally able to meet as a whole group in Würzburg, Germany. All but one of the team were able to attend for a full programme of presentations and discussions which moved each of our projects on enormously. In this regard, face to face contact was very valuable to our group, albeit with environmental costs given the international travel. 

Our progress to date has also been hampered by having to adapt to the constraints imposed on us by the pandemic, but nonetheless, we now have a number of individual projects nearing completion. Drafting the survey instrument has been more complex than originally anticipated, but it is now nearly ready for launch and is currently awaiting ethics approval. Translation of the instrument into German and French has been challenging but rewarding as it really made the team focus on the wording of questions, including the English versions. Our qualitative work is coming on apace with a series of roundtables with migrant academic colleagues in the first phase of the project helping us shape an interview schedule that was later rolled out to members of the wider public. We are also talking to tax practitioners to get their views on the challenges faced by clients who are migrants, among other things. Some theoretical work is looking at fleshing out the core concept we are dealing with, fiscal citizenship, as well as some associated concepts such as fiscal culture and fiscal belonging. Last but by no means least, empirical work includes analysis of world value survey data and experiments. 

Collectively we hope to not only produce new and exciting research findings but also to support future tax researchers. Our survey questions for example, build on previous studies but include some new questions and measures and will provide a resource that other researchers will be able to use in the future, perhaps in other countries. We are also conscious of the challenges of working across disciplines. While interdisciplinarity is supposedly encouraged by universities and research funders, the reality remains that we are all bound by the norms and expectations of the disciplines we are attached to. We will learn from this experience and share our insights.

I have often heard it said by colleagues that writing grant applications is a waste of time, either in the belief that the money is not needed, for colleagues who are not empirically driven, or on the basis that success rates are extremely low. My own experience is that both arguments can be countered. Working with new colleagues, particularly from different backgrounds to your own, is invigorating and can lead to fruitful new directions for your own research. As to success rates, yes, they can be low, but persistence pays off and you should never consign an unsuccessful application to the bin – as the Fiscal Citizenship project demonstrates. Much like the torture we put ourselves through placing our precious journal articles in the hands of not always kind referees, a grant application also must pass the grade in the hands of unknown colleagues which introduces an element of luck in terms of having sympathetic reviewers and funders. The positioning of a grant application, in our case as primarily within political science, is key here to maximise the chances of having reviewers who will appreciate what you are trying to achieve. 

It is important to remember that although it is time consuming, the process of putting together a grant application, of selling your idea to a funding body, is valuable in its own right, forcing us to clarify our thinking on research questions, significance and appropriate methods. It’s something I highly recommend.

You can meet the Fiscal Citizenship team and monitor our work as it comes to fruition here [https://fiscal-citizenship.com]. And do get in touch if you would like to know more, or even collaborate in some way. 

^[1] Notably Freund (2019), Guanao (2010)  Mehrotra (2013, 2015) Morgan & Erickson (2017) Sparow (2008). Of course, many scholars examine similar phenomena without using the term ‘fiscal citizenship’, although mainly from the US, which has a particular history of taxpaying.