Continuous Transaction Controls

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Robin Abbi


Filed under: mission
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Continuous Transaction Controls are a way of looping government agencies into live business transaction flows, to faclitate compliance with tax, environmental and other relevant laws and regulations.


Governments around the world are required by their citizens to conduct their operations as efficiently as possible. Additionally, governments recognize that the burden of compliance on the private sector should be as low as possible.

Whilst digital initiatives in both government and the private sector have in many cases delivered significant efficiciency gains, optimal efficiency for the government and private sector taken together has not so far been reached.

In consequence, business interactions with government can be looked at holistically to ensure total cost and efficiency are optimized for the benefit of both parties.

Whilst the above is true of national economic activity, the case for improving efficiency of international trade is even more compelling.

What are the seven CTC implementation principles?

The implementation principles are for consideration by government agencies when seeking to introduce CTCs to a new business area. 1

The seven principles of Continuous Transaction Controls are:

  1. Balance
  2. Efficiency
  3. Communication
  4. Cooperation
  5. Clarity on introduction
  6. Data security
  7. Impact and Non-discrimination

Taking each of those in turn:

1. Balance

Government agencies should aim for a balance between the legitimate interests of tax collection and economic growth.

Ideally agencies should promote the business benefits of CTCs and should consider voluntary adoption first, even if only for an initial period.

Chief among the business benefits would be automation of standard business processes.

Other business benefits might include tax incentives, and reduced periodic reporting requirements.

A key part of the principle of balance is flexibility - in practice this is interpreted to mean that government should adapt to the needs of business rather than vice versa.

Allied to this is proportionality - it is a net national loss when the costs to business of implementation exceed the benefits to government.

2. Efficiency

Government should only ask for data once and take responsibility for distribution to relevant departments, rather than requesting business to supply the same data multiple times.

Government should not use CTCs to expand the amount of information collected. Instead they should use it to replace information collected by other means.

A key component of efficiency is the concept of consistency - CTC requirements should remain stable over time and should be as similar as possible across jurisdictions.

In addition, different jurisdictions should aim for interoperability of business, legal, technical and operational aspects.

It is understood that interoperability and efficiency will be maximized where already applicable standards for data, security and transport protocols are adopted.

To further support the needs of business, all the normal IT service management practices should be observed: service level agreements, communications standards , and openness about the controls in place around the processing of data. It is also a requirement that governments maintain a level of processing capability commensurate with their national level of economic activity.

Very importantly for business - CTCs should not be implemented where a breakdown in government processing ability prevents business from continuing to trade.

3. Communication

Governments should communicate early and clearly their strategy for CTCs to create a shared understanding among all constituents.

This principle hopes to increase the coherence of tax administrators and correspondingly tax payers' technology solutions and make the realization of economic benefits more certain.

4. Cooperation

Many IT projects face unexpected difficulties. Building on principle 3, communication, principle 4, cooperation expects tax administrators and tax payers to work closely together in the initial implementation phase to iron out unforeseen challenges.

5. Clarity on Introduction

For the successful introduction of CTCs there should be clarity in the communication of specifications and timelines, with enough lead time to allow the private sector to optimize their implementations.

Guidance should be made available from a single location and during initial implemtation should not be chanded unless necessary.

6. Data security

Data should be processed in line with the appropriate then prevailing legal standards.

7. Trade Impact and non-discrimination

Governments should not discriminate between different classes of taxpayer and should not discriminate between local and non-local technology suppliers.

Bmbix as a CTC gateway

Bmbix has been designed to be easy to integrate to accounting and business systems and additionally to integrate to appropriate external regulatory and government agencies where appropriate.

In addition, Bmbix has from inception, been designed to recognize the needs of international commerce which can involve regulatory and government agencies from multiple jurisdictions.


Many countries around the world have sought to protect their tax revenues from fraud and evasion by integration into the business systems. Such systems have been found to be sufficiently successful in their deployment areas to be attractive to governments in other jurisdictions.

Whilst initial deployments are usually related to VAT and related sales taxes there is a likelihood that CTCs will gradually expand into other aspects of business and consumer commercial activity.


Accountants and bookkeepers are going to increasingly find current trends of digitalization will continue and accelarate. Transactions will be digitally enabled for all stages of their lifecycle: inception, distribution, receipt, processing and regulatory compliance (including taxation).


  1. ICC Continuous Transaction Control (CTCs) Practice Principles ↩︎


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Written by

Robin Abbi

Founder of Bmbix