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Purpose: This paper aims to use Stones' strong structuration theory (SST) that combines Giddens' duality and Archer's analytical dualism to deal with the paradox of embedded agency, focussing on resistance, in the budgeting literature. It also applies this framework to an illustrative case study that examines a failed attempt to implement performance-based budgeting (PBB) in the Egyptian Sales Tax Department (ESTD). Design/methodology/approach: The authors have used SST as an analytical framework. Longitudinal case study data were collected from interviews, observations, discussions and documentary analysis and from publicly available reports and other media issued by the World Bank. Findings: The SST framework identifies the circumstances in which middle managers as embedded agency have limited possibilities to change their dispositions to act and identify opportunities for emancipation in the wider social context in which they are embedded. The official explanation for the failure to implement PBB in Egypt was obstruction by middle managers. The findings of this study provide an alternative explanation to that published by the World Bank for the failure to institutionalise PBB in Egypt. It was found that the middle managers were the real supporters of PBB. Other parties and existing laws and regulations contributed to the failure of PBB. Research limitations/implications: As a practical implication of the study, the analysis presented here offers an alternative interpretation of the failure of the Egyptian project for monitoring and evaluation to that published by the World Bank. This case and similar cases may enhance the understanding of how and when monitoring and evaluation technologies should be introduced at the global level to manage conflicts of interest between agencies and beneficiaries. Originality/value: This paper contributes to the extant management accounting literature on the use of ST in addressing the paradox of embedded agency in making or resisting structural change. It uses SST to integrate Giddens' ST with critical realist theory, incorporating duality and dualism in a stronger model of structuration. The SST framework offers a means of analysing case studies that result from interactions and conjunctures between different groups of actors at different ontological levels. The paper also examines the issue of embedded agency in budgeting research using an illustrative case study from a developing country, Egypt. [ABSTRACT FROM AUTHOR]