SABMiller has been singled out from a growing list of companies seeking to do business in Africa. It stands accused of dodging bullets - tax bullets - but is this fair or helpful?

A handful of African nations are set to discuss corporate tax payments and, specifically, SABMiller's tax payments. Now, I'm not going to comment directly on the allegations by UK charity ActionAid that SABMiller has engaged in active tax avoidance in Africa. Naturally, the brewer vehemently denies any wrongdoing.

What I will say, however, is that my initial response to the report was that campaigners could be barking up the wrong tree.

From what I know, SABMiller is one company working in Africa that appears to take a softer approach on tax when compared to others. A very well-placed source - and not an SABMiller source - has told me of at least one meeting of drinks companies operating in Africa where SABMiller's representatives were unwilling to play ball on an aggressive plan to reduce corporate tax payments.  

In addition to this, I have listened to SABMiller's head of sustainability, Andy Wales, argue in public that the company is willing to pay slightly more tax in Africa than it has been doing.

The point being that tax regulation in Africa is the bigger issue for anyone looking at corporate payments. Even ActionAid isn't accusing SABMiller of breaking laws, per se.

That's not to say that SABMiller isn't trying to keep its tax bill down - of course, it is. If you can show me the person who pays taxes that they could avoid, then I'll show you the way to the zoo.

In that respect, the tax argument boils down to one question: where is the divide between shirking responsibility and reasonable avoidance?

Tax is a perpetual game of cat-and-mouse between the state and the private entity, whether that entity is individual or corporate.

Globalisation has introduced a moral dimension to the game, whether it's shifting operations overseas or expanding in emerging markets. One could argue that, in emerging markets, this moral dimension extends to the relative strength of the players. For example, if governance is perceived as particularly lax in a country, is it fair for a corporation to use the full powers of its accountants on that country?

I would argue that relying on the goodwill of the other player is not a long-term solution.

What matters foremost is the rules of the game.