If companies provide the information required under the draft text of the IFRS replacing IAS 12 the tax authorities would be able to avail themselves of declaratory statements providing cumulative liabilities based on the estimates of tax litigation outcomes. National law may allow tax authorities to demand an itemized breakdown of disclosed, accumulated tax liabilities. This could – for instance – result in revealing an estimated 70% chance of having to pay up which might be taken into consideration by the courts when it comes to assessing whether a taxpayer acted bona fide or whether he willingly tried his luck in an attempt to defraud the tax authorities. In the end, it would obviously still be a matter of national law how to deal with taxpayers taking a tax position with a 30% chance of success and whether this would meet the standards of a criminal act.