In considering how tax administrators should relate to tax intermediaries, one approach has been to move tax administrators from a command and control posture to a more sophisticated form of regulation, as recently endorsed by the OECD's "enhanced relationship" model. For the last decade, Australia and New Zealand have tested this initiative under the name of "responsive regulation". This article examines the experiences of Australia and New Zealand in forming an enhanced relationship between tax administrators and tax intermediaries. The article shows that forming an enhanced relationship has been problematic in both countries.