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Paying Taxes
2015
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wC refers to the PwC network and/or one or more of its member firms, each of which is a separate
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legal entity. Please see www.pwc.com/structure for further details.
Contents
Foreword
Key findings from the Paying Taxes 2015 data ...............................................................................................................1
What does this publication cover? ................................................................................................................................5
Chapter 1: World Bank Group commentary .......................................................................................................9
Chapter 2: PwC commentary on the latest results ..........................................................................................23
The global results for the Paying Taxes 2015 study ................................................................................................25
Comparing the regional averages ..........................................................................................................................29
Regional average sub-indicators ...........................................................................................................................33
Explaining the changes in the Total Tax Rate ........................................................................................................43
The challenges of tax reform..................................................................................................................................55
A closer look at electronic filing and payment ........................................................................................................59
Chapter 3: PwC perceptions on how tax systems are changing ...................................................................67
Additional insights around the tax compliance burden and how tax systems are perceived ...................................69
Cooperative compliance – how can businesses and tax authorities learn to trust each other? ................................81
Commentaries on selected economies ...................................................................................................................85
Appendix 1
Methodology and example calculations for each Paying Taxes sub-indicators
including methodology changes for this year ............................................................................................................121
Appendix 2
Economy sub-indicator results by region ...................................................................................................................133
Appendix 3
The data tables ......................................................................................................................................................... 151
Foreword 3
Foreword
The Paying Taxes study remains unique. It is the This year we have also focussed more on the
only piece of research which measures the ease of compliance aspects of the information that we
paying taxes across 189 economies by assessing collect through the study. Stable tax systems
the time required for a case study company to and strong tax administrations are important
prepare, file and pay its taxes, the number of taxes for businesses, helping them to operate in
that it has to pay, the method of that payment an environment where the tax treatment
and the total tax liability as a percentage of its of transactions is predictable, and where
commercial profits. The model we use is simple governments operate transparently. There is
and does not cover all aspects and regulations little question that transparent tax systems
which are a feature of tax systems, and it does which are easy to comply with increase voluntary
not set out to do so. The intention is to provide compliance. In the publication this year we have
an objective basis for governments to benchmark included a section which draws on some of the
their tax systems on a like-for-like basis. The information that we collect in addition to the core
results illustrate both successful reforms and Paying Taxes sub-indicators. We also include a
reform challenges and provide a platform number of more in-depth country articles which
for government and business to engage in illustrate the reforms that have been implemented
constructive discussion around tax reform across in those countries and their experience of what
a broader range of issues. has worked well and what has not been so
successful.
Our experience is that the findings of our study
are respected and well used by governments, The Paying Taxes study provides an unrivalled
business, and by academics. Each year we global database which supports an ongoing
launch the findings in regional events around research programme. We welcome your
the world. We have completed 35 of these since feedback on the results both on the Paying Taxes
2006, initiating constructive dialogue with sub-indicators and the additional information
governments and interest from the media to which we collect. Suggestions for other priority
ensure engagement with the wider public. areas for research are welcomed as we develop
our focus for future studies.
In our tenth year there have been some
amendments to the methodology which is used
to derive the Paying Taxes sub-indicators and
the ranking. These changes have been made
in response to calls for the data to remain
current, to take into account the potential for
Andrew Packman Augusto Lopez-Claros
differences in the tax system across the larger
economies in the study, and to more closely
reflect the improvements that are made when
implementing reform.2
2
See “What does this publication cover?” and “Appendix 1 – Methodology” for details of these changes.
Foreword 5
Key findings from the
Paying Taxes 2015 data3
On average it takes our case study company 264 hours to The compliance sub-indicators
comply with its taxes, it makes 25.9 payments and has an continue to fall; labour taxes
average Total Tax Rate of 40.9%. and consumption taxes drive the
reduction in time.
2013
2013
-1
Number of payments
-1
2013 +0.1%
-1.3%
-2 Total Tax Rate
Profit taxes
0.1%
-3 -4
hours
Time to comply
-0.2% +/-0%
-0.1% Labour taxes
-4
-0.2%
All three sub-indicators have continued to fall following a
trend seen during the nine years of the study. -0.3%
-0.3%
The average Total Tax Rate fell by 1.3 Other taxes
percentage points. Excluding the replacement
of cascading sales taxes in Africa with VAT, the Total Tax Rate
still falls by 0.2 percentage points. This is made up of an
increase in profit taxes of 0.1 percentage points and a fall in
'other' taxes of 0.3 percentage points.
3
he data for Paying Taxes 2015 relates to the calendar year to
T
31 December 2013
43%
Reforms continue to be made in
43% of economies now have electronic filing and payment Africa, while progress is less evident
systems which are used by the majority of companies. in South America. South America now has the
highest average time to comply and Total Tax Rate.
105
379
The pace of reform accelerated
during the financial crisis, slowed in
more recent years, but improvement
continues. 379 reforms making it
easier and less costly to pay taxes Central Asia & Eastern Europe
have been recorded since 2004, is still the fastest reforming
105 of these relate to electronic region with a major focus
filing and payment. on improving administrative
systems. All three sub-indicators
have fallen with the number
of payments and time to
comply both now below the
world average.
All three sub-indicators Key findings from the Paying Taxes 2015 data 2
have continued to fall
following a trend seen
through the 10 years of
The regional picture
North America
Diverse tax systems where all sub-
indicators are below the world average
The three economies in North America 38.9 213 8.2
% hours payments
have very different systems. They all use
electronic filing and payment. Regional
improvements are marginal.
South America
Has the most time consuming
tax system
55.4 620 23.7 South America is the only region
% hours payments
to show a significant increase in
Total Tax Rate. The region continues
to have the highest average
time to comply and this average
has increased.
• According to the experience • 82% of contributors were of • Interest in the tax agenda • W hen asked to rate some
of PwC contributors, 81% the view that a key aim of from the media and by civil aspects of their economy’s
of governments publish current government policy society organisations (CSOs) tax systems, the PwC
information on the tax is to increase tax revenues, was seen as highest in North contributors felt that
revenues they receive, but but 60% think that America and EU & EFTA. dealing with the post-filing
only around two thirds of governments also have an process was most in need
these keep the data up to eye on using the tax system of improvement, followed
date including forecasts for to encourage investment. by the approach of the
the current year. tax authority.
• P wC contributors in 43% • In economies where taxes • In almost 87% of economies • 48% of economies have
of economies viewed the can be levied by three levels PwC contributors would a special tax regime
post-filing process in their of government the case expect the case study for small or medium
economy as difficult, and study company took longer company to use computer sized companies and
on average these economies to prepare and file its tax software at some point in the these economies have
also spend more time on returns, and made more process to prepare and file at a higher average time
pre-filing compliance. payments, than in those least one of the taxes covered to comply than those
economies where only one by the study. This suggests economies without such
or two levels of government a high level of computer use special regimes.
could levy taxes. around the world and a high
level of IT literacy which
tax authorities can build
on when developing online
filing and payment systems.
Over the last year, interest from external stakeholders in Paying Taxes
has remained high. Over 16,000 copies of the last publication have been
distributed, the results have been reported extensively by media around
the world, and meetings with senior officials within government have
been convened to discuss the findings. There has also been interest from
academia3, including interest in accessing and making use of the study’s
extensive databank that now covers a ten year period.
For example, Taxation Law and Policy Research Group, Addressing Tax
3
4
Commercial profit is essentially net profit before all taxes borne. It differs from the conventional profit before tax, reported in financial statements. In
computing profit before tax, many of the taxes borne by a company are deductible. Commercial profit is calculated as sales minus cost of goods sold, minus
gross salaries, minus administrative expenses, minus other expenses, minus provisions, plus capital gains (from the property sale), minus interest expense,
plus interest income and minus commercial depreciation. To compute the commercial depreciation, a straight-line depreciation method is applied, with the
following rates: 0% for the land, 5% for the building, 10% for the machinery, 33% for the computers, 20% for the office equipment, 20% for the truck and 10%
for business development expenses. Commercial profit amounts to 59.4 times GNIpc in each economy, by assumption of the case study firm.
5
Where full electronic filing and payment is used by the majority of medium-size businesses in the economy and where there is no requirement to file hard
copies of documentation following electronic submission, the number of payments is counted as one even if filings and payments are more frequent.
6
www.pwc.com/payingtaxes and www.doingbusiness.org
7
Independent Panel Review of the Doing Business report, June 2013, accessed from http://www.dbrpanel.org/sites/dbrpanel/files/doing-business-review-
panel-report.pdf
Taxes matter for the economy. They provide the sustainable funding
needed for social programmes and public investments to promote
economic growth and development and build a prosperous and orderly
society. But policy makers face a difficult challenge in formulating
good tax policies: they need to find the right balance between raising
revenue and ensuring that tax rates and the administrative burden of tax
compliance do not deter participation in the system or discourage business
activity. This balancing act is intensified during periods of crisis. In an
economic downturn some categories of public spending may automatically
rise, putting pressure on deficits. Governments may at times need to
deliver tax-based stimulus packages while also providing reassurance to
markets that deficits will be reversed and public debt contained.
8
The data in this chapter covers the period 2004 to 2012 only.
9
World Bank, World Development Indicators database.
10
OECD (Organisation for Economic Development and Co-operation). 2010. Growth-Oriented Tax Policy Reform Recommendations. Tax Policy Study 20. Paris:
OECD.
Buti, Marco, and Heinz Zourek. 2012. “Tax Reforms in EU Member States: Tax Policy Challenges for Economic Growth and Fiscal Sustainability.” Working
11
Paper 34–2012, European Commission Directorate General for Taxation and Customs Union Directorate General for Economic and Financial Affairs,
Luxembourg.
12
Buti and Zourek 2012.
13
Buti and Zourek 2012.
OECD (Organisation for Economic Development and Co-operation). 2010. “Choosing a Broad Base–Low Rate Approach to Taxation.” OECD Tax Policy
14
before tax, many of the taxes borne by a firm are deductible. In computing commercial profit, these taxes are not deductible. Commercial profit therefore
presents a clear picture of the actual profit of a business before any of the taxes it bears in the course of the fiscal year. It is computed as sales minus cost of
goods sold, minus gross salaries, minus administrative expenses, minus other expenses, minus provisions, plus capital gains (from the property sale) minus
interest expense, plus interest income and minus commercial depreciation. To compute the commercial depreciation, a straight-line depreciation method is
applied, with the following rates: 0% for the land, 5% for the building, 10% for the machinery, 33% for the computers, 20% for the office equipment, 20% for
the truck and 10% for business development expenses. Commercial profit amounts to 59.4 times income per capita.
Figure 1.1: A global trend of steady decline in the Total Tax Rate
Global average Total Tax Rate (% of commercial profit)
20
19
18
Labour taxes
17
16 Profit taxes
15
14
13
12
Other taxes
11
10
2004 2005 2006 2007 2008 2009 2010 2011 2012
Note: The data refer to the 174 economies included in DB2006 (2004). The Bahamas, Bahrain, Barbados, Brunei Darussalam, Cyprus, Kosovo, Liberia, Libya,
Luxembourg, Malta, Montenegro, Myanmar, Qatar, San Marino and South Sudan were added in subsequent years.
Source: Doing Business database.
17
This is an unweighted average across 189 economies.
The terms profit tax and corporate income tax are used interchangeably in this case study. “Other” taxes include small taxes such as vehicle taxes,
18
environmental taxes, road taxes, property taxes, property transfer fees, taxes on checks and cascading sales tax.
19
The seven economies are Burundi, the Democratic Republic of Congo, Djibouti, The Gambia, the Seychelles, Sierra Leone and the Republic of Yemen.
Figure 1.2: Among regions, Sub-Saharan Africa had the biggest reduction in the Total Tax Rate
Regional average Total Tax Rate (% of commercial profit)
80
70
60
Sub-Saharan Africa
40
South Asia
30
2004 2005 2006 2007 2008 2009 2010 2011 2012
Note: The data refer to the 174 economies included in DB2006 (2004). The Bahamas, Bahrain, Barbados, Brunei Darussalam, Cyprus, Kosovo, Liberia, Libya,
Luxembourg, Malta, Montenegro, Myanmar, Qatar, San Marino and South Sudan were added in subsequent years.
Source: Doing Business database.
20
This is the average for all Sub-Saharan African economies included in Doing Business 2013 (45 in total and does not take into account movements in 2013).
Figure 1.3: The administrative burden of compliance has eased for all types of taxes
Global average time (hours per year) Global average payments (number)
130 18
16
120
14 Other taxes
110
Consumption taxes*
12
Labour taxes
100
10
Labour taxes
8
90
80
4
Profit taxes
70 Profit taxes
Note: The data refer to the 174 economies included in DB2006 (2004). The Bahamas, Bahrain, Barbados, Brunei Darussalam, Cyprus, Kosovo, Liberia, Libya,
Luxembourg, Malta, Montenegro, Myanmar, Qatar, San Marino and South Sudan were added in subsequent years.
Source: Doing Business database.
Rolling out new information and Electronic systems for filing and
communication technologies for paying taxes have become more
filing and paying taxes and then common worldwide. Of the 314
educating taxpayers and tax officials reforms making it easier or less costly
in their use are not easy tasks for to pay taxes that Doing Business has
any government. But electronic tax recorded since 2004, 88 included
systems, if implemented well and the introduction or enhancement of
used by most taxpayers, benefit online filing and payment systems.
both tax authorities and firms. For These and other improvements to
tax authorities, electronic filing simplify tax compliance reduced the
lightens workloads and reduces administrative burden to comply
operational costs such as for with tax obligations. By 2012, 76
processing, handling and storing tax economies had fully implemented
returns. This allows administrative electronic systems for filing and
resources to be allocated to other paying taxes as measured by
tasks such as auditing or providing Doing Business. The Organisation
customer services. for Economic Co-operation and
Development (OECD) high-
Electronic filing is also more income economies have the largest
convenient for users. It reduces the representation in this group.
time and cost required to comply with
tax obligations and eliminates the
need for taxpayers to wait in line at
the tax office.21 It also allows faster 21
olt, Eric and Bird, Richard. 2008. “Technology
Z
and Taxation in Developing Countries: From
refunds. And it can lead to a lower Hand to Mouse.” National Tax Journal 61:
rate of errors. 791-821.
Figure 1.4: An accelerating pace of tax reform during the global financial crisis
Number of changes making it easier or less costly to pay taxes as measured by Doing Business
120
East Asia
& Pacific
OECD
80 high income
Latin America
60 & Caribbean
Middle East
& North Africa
40
South Asia
20
Sub-Saharan
Africa
0
2004 2005 2006 2007 2008 2009 2010 2011 2012
Note: The data refer to the 174 economies included in DB2006 (2004). The Bahamas, Bahrain, Barbados, Brunei Darussalam, Cyprus, Kosovo, Liberia, Libya,
Luxembourg, Malta, Montenegro, Myanmar, Qatar, San Marino and South Sudan were added in subsequent years. The changes shown for each year are those
recorded from 1 June of that year to 1 June of the following year.
Source: Doing Business database.
22
These reforms include both major and minor reforms as classified by Doing Business. These include changes in statutory rates, changes in deductibility of
expenses and depreciation rules, administrative changes affecting time to comply with three major taxes (corporate income tax, labour taxes and mandatory
contributions, and VAT or sales tax) and introduction or elimination of taxes. Under the Paying Taxes methodology, the tax system assessment for calendar
year 2008 covers reforms recorded from 1 June 2008 to 1 June 2009, a period that includes the start of the financial crisis in September 2008 and the months
immediately following it.
Figure 1.5: During the crisis period many economies cut the corporate income tax rate while continuing to improve tax administration
Changes making it easier or less costly to pay taxes as measured by Doing Business, by type
70
Abolished or
merged taxes
60
Introduced or
enhanced
50 electronic
system
40
Reduced
labour taxes
30
Made changes in
tax depreciation
20 or deductibility
rules that
reduced tax cost
10 Reduced
corporate
income
tax rate
0
2004 2005 2006 2007 2008 2009 2010 2011 2012
Note: The data refer to the 174 economies included in DB2006 (2004). The Bahamas, Bahrain, Barbados, Brunei Darussalam, Cyprus, Kosovo, Liberia, Libya,
Luxembourg, Malta, Montenegro, Myanmar, Qatar, San Marino and South Sudan were added in subsequent years. The changes shown for each year are those
recorded from 1 June of that year to 1 June of the following year. The figure does not show all types of changes making it easier or less costly to pay taxes
recorded by Doing Business.
Source: Doing Business database.
Figure 1.6: Among other changes to tax systems during the crisis period, those introducing new taxes were the most common
Changes making it more complex or costly to pay taxes as measured by Doing Business, by type
18
Introduced
new tax
16
14
Increased
labour taxes
12
10
Made changes
8
in tax
depreciation
or deductibility
rules that
6 increased tax
cost
4
Increased
corporate
income tax
rate
2
0
2004 2005 2006 2007 2008 2009 2010 2011 2012
Note: The data refer to the 174 economies included in DB2006 (2004). The Bahamas, Bahrain, Barbados, Brunei Darussalam, Cyprus, Kosovo, Liberia, Libya,
Luxembourg, Malta, Montenegro, Myanmar, Qatar, San Marino and South Sudan were added in subsequent years. The changes shown for each year are those
recorded from 1 June of that year to 1 June of the following year. New taxes include environmental taxes, vehicle taxes, property taxes and road taxes. The
figure does not show all types of changes making it more complex or costly to pay taxes recorded by Doing Business.
Source: Doing Business database.
The 2008 global credit crunch and ensuing Korea also accelerated the implementation
economic recession hit Korea hard. Heavily of some tax changes already in the
dependent on manufactured exports and pipeline. It reduced the corporate income
closely integrated with other developed tax rate for taxable income below 200
markets through both trade and financial million Won ($197,972) from 13% to 11%
links, the Korean economy contracted in 2008 and to 10% starting in 2010. For
sharply in 2009 and public finances came the upper tax bracket (above 200 million
under pressure. Reflecting diminished Won) it reduced the rate from 25% to 22%
confidence in the short-term outlook, the in 2009 and to 20% in 2010 and thereafter.
value of the Korean Won fell sharply. This Korea reduced the personal income tax
helped lead to rapid consideration of a rate by 1 percentage point for the middle
package of measures aimed at putting in bracket and by 2 percentage points for the
place the conditions for a recovery. top bracket while also increasing allowable
deductions.
The government set priorities for tax
policy: supporting low- and middle- In addition, Korea strengthened tax
income taxpayers, facilitating job creation, compliance regulation, imposing penalties
promoting investment and sustainable on high-income earners for failure to issue
growth, rationalising the tax system cash receipts and introducing more severe
and ensuring the sustainability of public punishment for frequent and high-profile
finances.23 Measures to support low- and tax evaders. It also increased the statute of
middle-income taxpayers included changes limitation for prosecution for certain tax
in both individual and corporate taxation crimes.
(such as a special tax credit for small and
medium-size enterprises). To support the Supporters of Korea’s approach believe that
continuation of family businesses, the it enabled the country to recover faster and
government reduced the inheritance tax more strongly from the global crisis than
and allowed deductions of up to 10 billion most other OECD countries.24 Korea was
Won (about $10 million) when a small one of only a handful of OECD countries
or medium-size enterprise is inherited, that actually registered a reduction in
extending this to 50 billion Won (about public debt levels over the period 2009–
$50 million) in 2014. To help self-employed 2013. Most other advanced economies saw
individuals who were forced to close their rapid increases in public indebtedness as a
businesses in 2009, the government offered result of policy interventions to deal with
an exemption from paying delinquent the effects of the financial crisis.25
taxes until the end of 2010 for those
starting a new business or getting a new
job. The exemption was further extended
until the end of 2014. To support local
business development, it gave a corporate
income tax deduction of 100% for the
first five years and 50% for the next two
years to companies relocating to Korea 23
Korea, Ministry of Strategy and Finance 2012.
OECD (Organisation for Economic Development
24
from abroad. To support future growth, it and Co-operation). 2010. “Choosing a Broad
introduced R&D incentives for companies Base–Low Rate Approach to Taxation.” OECD
Tax Policy Studies, no. 19, OECD, Paris.
and also increased the deductibility of International Monetary Fund, World Economic
25
20
Box 3: How did Spain change its tax law to cope with the 2008–2009 crisis?
Spain, whose growth relied heavily The government took austerity Spain aimed to ensure that the
on a housing and construction boom, measures to cut the budget deficit, measures it took to reduce the fiscal
was among the countries in Europe including reducing public workers’ deficit would be growth-friendly. One
most affected by the 2008–2009 salaries by as much as 5% in 2010 approach was to increase revenue
financial crisis. Its economy shrank and freezing state pensions. It also from VAT rather than to cut productive
by 3% in the first quarter of 2009, and increased the personal income tax spending.31 The government raised
unemployment rose from 10.4% in the rate for the top bracket. In addition, the general VAT rate in July 2010 from
second half of 2008 to nearly 18% in the government took a number of 16% to 18% and the reduced rate from
early August 2009. The budget deficit steps to help the housing market.28 7% to 8%. In September 2012 it again
increased to more than 11% of GDP It encouraged growth in the raised the general VAT, to 21%, while it
in 2009.26 Boosting the economy and underdeveloped rental market by increased the reduced rate from 8% to
reducing unemployment became a offering credit lines for developers to 10%. In January 2013 Spain eliminated
priority, and the government adopted a convert unsold houses to rental. It also the tax credit for the purchase of a
tax-based stimulus package to support increased the general tax exemptions taxpayer’s main residence.32
businesses and aid the recovery. for rental income from 50% to 60% in
January 2011 and introduced a 100%
Tax law amendments adopted in exemption for individuals ages 18–35.
December 2008 introduced several
initiatives designed to lower the tax In 2010 the government introduced
cost for businesses. The amended more tax changes aimed at boosting
tax law allowed new fixed assets and investment, reducing the budget deficit
real estate acquired during 2009 and sustaining the economic recovery.
and 2010 to be fully depreciated in It extended the full depreciation option
the first year as long as the taxpayer for investments and newly acquired
maintained the same number of fixed assets to 2011 and 2012, allowing
“Spain Response to the Crisis in Detail,”
26
employees in both that year and the businesses to defer their tax liabilities International Labour Organization, http://
following one. It extended the R&D to future years.29 It raised the eligibility www.socialsecurityextension.org/gimi/
gess/ShowTheme.action;jsessionid=d
tax credit beyond activities within the threshold for tax treatment as a small e7ab1c2f97cea3595f2d113e8b658102
country to also cover activities within or medium-size enterprise from €8 fda91e9854d4c2ca10afd62d1325902.
e3aTbhuLbNmSe34MchaRah8Tchr0?th.
the European Union and European million in turnover to €10 million for themeId=1383
Economic Area. It allowed taxpayers to financial years starting on or after 1 27
Deloitte. 2009. “Tax Responses to the
apply the tax exemption to dividends January 2011. In addition, it increased Global Economic Crisis.” http://www.
deloitte.com/assets/Dcom-Russia/
from EU subsidiaries located in tax the tax brackets for the first tranche Local%20Assets/Documents/dtt_tax_
havens as long as they could prove of the tax scale for small and medium- respondingtoeconcrisis__032009(4).pdf
IMF (International Monetary Fund). 2009.
28
that the entities carried out business size enterprises from €120,000 to World Economic Outlook: Crisis and Recovery.
activities and that their location was €300,000.30 The government also Washington, DC: IMF.
driven by economic reasons.27 And it introduced a reduced corporate income Decree-law 12/2012 repealed the rule
29
22
Chapter 2: PwC commentary
on the latest results
The changes in the results since Paying Taxes 2014
Tax policy issues are becoming ever more challenging. There are pressures on tax
authorities to raise revenues, to fund social expenditures but also to ensure that their tax
system fosters business investment. The business environment is complicated and has the
potential to become even more so with complex tax legislation and onerous administrative
obligations. It is not surprising therefore that in the most recent edition of the PwC Global
CEO survey33 nearly two-thirds of CEOs around the world say the international tax system
is in urgent need of reform and 70% say the impact of tax on their company’s growth is
among their top concerns.
33
www.pwc.com/taxceosurvey
The data collected though the Paying The changes made to the methodology
Taxes study is proving to be a useful this year help to ensure that Paying
tool for stimulating debate and Taxes continues to keep pace with
discussion between business and global developments, that the data is
governments on their tax systems. robust and the study remains relevant.
We saw interest in last year’s study Some of these changes have had a
from government, tax authorities significant effect on the Paying Taxes
and businesses in all of our launch sub-indicators for some economies
locations (Russia, Colombia, Canada, and these are explained on the
Nigeria, Portugal and Thailand). We following pages.
have also seen the UK government use
Paying Taxes as an important point of As well as looking at the changes in
reference for its recent review of the the Paying Taxes sub-indicators of
competitiveness of the UK tax system. Total Tax Rate, time to comply and
Although the UK review used Paying the number of payments we taken
Taxes as a starting point, the study very a look at what governments and tax
soon expanded beyond the matters authorities have been doing to make
that are covered by Paying Taxes to it easier for companies to pay tax. We
look at many other aspects of the UK have included a number of detailed
tax system. Nevertheless, Paying Taxes articles by PwC partners looking at
was essential in providing a framework the changes that have taken place in
for discussions on the UK tax system their economies and considering which
and in informing many aspects of the changes have affected the Paying
government review. Taxes sub-indicators, and which,
although they make a difference for
real companies would not apply to the
Paying Taxes case study company. We
hope that these articles will provide
governments and tax authorities with
some practical examples of how tax
systems can be changed to make it
easier to pay taxes.
Introduction 24
The global results for the
Paying Taxes 2015 study
On average around the world our case study company makes 25.9 payments, takes 264 hours (just
over six and a half weeks based on a 40 hour week) and has a tax cost of 40.9% of commercial profit.
Table 2.1
The average global result for each sub-indicator
Labour taxes
16.2 94 10.2
and contributions
Other/
8.4 99 12.6
Consumption taxes
The average global results, taking into All three of the sub-indicators continue
account all 189 economies for the year to demonstrate a wide range between
ending 31 December 2013, are shown the highest and the lowest results.
in Table 1. The results for each sub- For payments and the time to comply,
indicator are also split between the the minimum and maximum figures
three types of tax showing that while, remain the same as for last year while
on average, profit taxes account for the range of Total Tax Rates has
a similar proportion of the Total Tax narrowed with the maximum dropping
Rate to labour taxes (almost 40%) they to 216.5% from 283.2%. Last year,
take 25% less time and almost 30% less The Gambia was the economy with
time than consumption taxes. the highest Total Tax Rate (283.2%)
thanks to its cascading sales tax. The
Other taxes now account for a fifth of replacement of The Gambian sales
the Total Tax Rate, but almost a half of tax with a value added tax has left
the number of payments. Comoros as the economy with the
highest Total Tax Rate (216.5%),
again due to its cascading sales tax.
The minimum Total Tax Rate also fell
between 2012 and 2013, though by
less than one percentage point from
8.2% to 7.4%. The Former Yugoslavian
Republic of Macedonia remains the
economy with lowest Total Tax Rate
due to it only levying corporate income
tax on profits once they are distributed
as dividends, an absence of labour
taxes that are paid by the employer and
low levels of “other” taxes.
Table 2.2
Global average sub-indicators for 2013 and 201234
Labour
taxes and 16.2 16.2 16.3 94 96 96 10.2 10.5 10.4
contributions
Other/
Consumption 8.4 9.8 10.7 99 101 101 12.6 12.9 13.0
taxes
Total 40.9 42.2 43.1 264 268 268 25.9 26.8 26.7
The data in Table 2.2 include data for all 189 economies
34
Figure 2.1
Trend in the sub-indicators, 2004 to 201335
% / Number Hours
60 400
Time to comply
30 200
Number of payments
15 100
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Total Tax Rate by region At the other end of the scale, the data In addition to the reduction in the
With the exception of South America shows for the first time a Total Tax Rate Africa Total Tax Rate and the increase
and the Middle East, which have for Africa that, at 46.6%, is lower than in the South America Total Tax Rate,
Total Tax Rates of 55.4% and 24.0% that of South America at 55.4%. The Central Asia & Eastern Europe and
respectively, the regions all have African Total Tax Rate has been falling North America have also experienced
a Total Tax Rate that is within consistently since its peak of 72.2% in significant falls in their Total Tax Rate
7 percentage points of the global 2005, while the South American Total compared to last year’s published data.
average of 40.9%, as shown in Figure Tax Rate has remained fairly stable.
2.2. Reflecting the region’s reliance The South American rate gradually Only in South America do “other” taxes
on revenues other than tax revenues, fell from 56.8% in 2004 to 52.2% in account for the greatest share of the tax
the Middle East has had the lowest 2009 and since then has gradually cost. In Africa, for the first time, “other”
13.6 regional Total Tax Rate since the start increased to 55.4% this year, increasing taxes now account for the smallest
14.8 of the study and this remains the case by 1.4 percentage points in the last proportion of the Total Tax Rate due
20.7
this year with a Total Tax Rate that is year alone, compared to the 2012 to the abolition by The Gambia of its
over 40% (i.e. 17 percentage points) restated data. cascading sales tax. This more closely
24.5
below the world average. aligns the African Total Tax Rate profile
25.3
with that of the other regions.
28.8
29.1
31.0
31.5
31.7
31.8
32.7
32.8
33.3
33.3
33.5
35.1
35.5
Figure 2.2
36.5
South America 16.5 17.1 21.8 55.4
36.6
Africa 17.5 14.8 14.3 46.6
37.3
Central America
23.0 12.1 7.8 42.9
38.1 & the Caribbean
38.2 EU & EFTA 13.1 26.3 1.6 41.0
45.4
0 10 20 30 40 50 60
45.5
48.3
World average (40.9%)
48.8
49.3
Source: PwC Paying Taxes 2015 analysis
50.3
54.7
Time to comply The Middle East continues to require Compared to last year, the time to
As shown in Figure 2.3, the time the least amount of time at just 160 comply has remained static for North
required by the case study company to hours, over 100 hours less than the America and fallen by 1 or 2 hours in
comply with its tax filing obligations world average. Hence, as with the Africa, EU & EFTA and the Middle East.
on average across all 189 economies Total Tax Rate, South America and Greater reductions have taken place in
is 264 hours, a reduction of 4 hours the Middle East are the worst and best Asia Pacific (3 hours), Central America
from last year. For the last three years, regions respectively. South America & the Caribbean (6 hours) and Central
only Africa and South America have has an average of 620 hours, 2.3 times Asia & Eastern Europe (11 hours).
had an average time to comply that is the world average, largely due to the In South America however the time
greater than the world average. Before 2,600 hours required in Brazil, though to comply has increased by 2 hours,
2010, Central Asia & Eastern Europe Bolivia, República Bolivariana de despite the fact that the region already
had a time to comply that exceeded Venezuela and Ecuador all require had the largest average time to comply.
Africa’s, but on a like-for-like basis more than 650 hours a year to comply
Central Asia & Eastern Europe’s time with their tax filing obligations. For Between 2012 and 2013, seven
requirement has fallen every year since Africa, there are still seven economies economies each improved their time
its peak of 488 hours in 2005 and it fell where the time to comply is over by more than 50 hours, and only in
again between 2012 and 2013 to reach 600 hours, but the average is lowered Georgia did the time increase by more
246 hours. Africa’s time to comply on by six economies where the time to than 50 hours. The time to comply did
the other hand peaked at 343 hours in comply is under 150 hours. not change in 147 economies between
2005, but since then has fallen by only 2012 and 2013.
31 hours to 312 hours today, again, on The time to comply with consumption
a like-for-like basis. taxes is particularly high for South
America compared to the other
regions, and this drives the global
average so that consumption taxes take
the longest to comply with on average
around the world at 99 hours compared
to 94 hours for labour taxes.
Figure 2.3
Time to comply by region (hours)
Central America
41 96 74 211
& the Caribbean
EU & EFTA 37 84 55 176
Figure 2.4
Number of payments by region
Central America
4.7 13.0 16.1 33.8
& the Caribbean
World average 3.1 10.2 12.6 25.9
Central Asia
3.3 6.2 13.8 23.3
& Eastern Europe
Middle East 1.0 10.4 5.4 16.8
0 10 20 30 40
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 46.6 50.6 52.9
Time to
comply (hours) 317 319 320
Number of
payments 36.2 36.0 36.1
As shown in Table 2.3, the average As explained on pages 43 and 44 this The Democratic Republic of Congo
Total Tax Rate across African large decline is primarily due to The reduced its time to comply by 32 hours
economies has dropped by 6.3 Gambia, where the Total Tax Rate fell through simplifying its corporate
percentage points of which 2.3 by over 220 percentage points and the income tax returns and removing the
percentage points can largely be Democratic Republic of Congo, with a requirement to calculate provisional
attributed to the changes in the Paying reduction of over 60 percentage points. tax each month. These decreases
Taxes methodology and the remainder As we explain on pages 45 and 46, the were partially countered by the
to changes in African tax systems change in the result for The Gambia is introduction of a new health insurance
that took effect in 2013. Africa now largely attributable to the replacement in Mauritania which increased its time
has the second highest tax cost of the of a cascading sales tax by a value to comply by 38 hours.
regions with South America having added tax, whereas for the Democratic
the highest average rate. The average Republic of Congo the change is largely The 0.1 percentage point increase
Total Tax Rate for Africa is affected by attributable to the increase in GNIpc in the number of payments can be
the cascading sales tax in Comoros. from 2005 to 2012 values. These attributed to increases in Mauritania
Without Comoros, the Africa Total Tax significant reductions have affected only (12 payments due to the new health
Rate would be over 3 percentage points “other” taxes with the result that “other” insurance scheme) and the Democratic
lower at 43.4%. South America on the taxes moved from being the largest Republic of Congo (18 payments due
other hand has no economies with a constituent of the Total Tax Rate in 2012 partly to a new labour tax), partially
cascading sales tax that would inflate to the smallest constituent in 2013. offset by decreases of 11 payments
its Total Tax Rate in a similar way. in each of Kenya (due to the use of
Along with changes in the Total Tax online filing and payment for VAT)
Rate, Africa has also shown a slight and Namibia (due to online filing and
decrease in time to comply, with the payment of property tax).
most significant movement being a
decrease for Kenya of 106 hours thanks
to changes in the VAT system. Having
been introduced in 2009, it was only
in 2013 that the majority of companies
began to use electronic filing and
payment for VAT. This allows VAT to
be calculated and the records to be
stored electronically and it is now easier
to collect the information needed to
make payments.
The following economies are included in our analysis of Africa: Algeria; Angola; Benin; Botswana; Burkina Faso; Burundi; Cameroon; Cape Verde; Central
36
African Republic; Chad; Comoros; Congo, Dem. Rep.; Congo, Rep.; Côte d’Ivoire; Djibouti; Egypt, Arab Rep.; Equatorial Guinea; Eritrea; Ethiopia; Gabon;
Gambia, The; Ghana; Guinea; Guinea-Bissau; Kenya; Lesotho; Liberia; Libya; Madagascar; Malawi; Mali; Mauritania; Mauritius; Morocco; Mozambique;
Namibia; Niger; Nigeria; Rwanda; São Tomé and Principe; Senegal; Seychelles; Sierra Leone; South Africa; South Sudan; Sudan; Swaziland; Tanzania; Togo;
Tunisia; Uganda; Zambia; Zimbabwe
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 36.3 36.4 36.4
Time to
comply (hours) 229 232 232
Number of
payments 25.4 25.7 25.4
As can be seen from Table 2.4, the and the profit taxes Total Tax Rate The average number of payments has
average Total Tax Rate for Asia Pacific increasing by 0.7 percentage points as remained flat across the two years,
is largely unchanged though this is shown in Figure 2.5 below. although the methodology changes
the net result of the Total Tax Rate and some data revisions caused a slight
reducing in some economies such as The average time to comply for the increase in the restated 2012 figure.
Solomon Islands and Vietnam and region has fallen by three hours
increasing in other economies such following reductions in China
as Singapore. These changes are not (57 hours), Mongolia (44 hours)
due to changes in the underlying tax and Sri Lanka (43 hours) thanks to
systems in these economies, but are improvements to electronic systems
instead mainly due to the change for filing and paying taxes. The time to
in methodology. While the overall comply has increased in Pakistan and
change in the Total Tax Rate is only Tonga by 17 and 18 hours respectively
0.1 percentage point, the change in due to the introduction of a new
the mix of tax types is more significant provincial VAT scheme in Pakistan
with the “other” taxes Total Tax Rate and a new retirements benefit scheme
reducing by 0.6 percentage points in Tonga.
Figure 2.5
Trend in Total Tax Rate by type of tax for the Asia Pacific region
8.4% 7.8%
Other taxes Other taxes
17.3% 18.0%
Profit taxes Profit taxes
10.7% 10.5%
Labour taxes Labour taxes
The following economies are included in our analysis of Asia Pacific: Afghanistan; Australia; Bangladesh; Bhutan; Brunei Darussalam; Cambodia; China;
37
Fiji; Hong Kong SAR, China; India; Indonesia; Japan; Kiribati; Korea, Rep.; Lao PDR; Malaysia; Maldives; Marshall Islands; Micronesia, Fed. Sts.; Mongolia;
Myanmar; Nepal; New Zealand; Pakistan; Palau; Papua New Guinea; Philippines; Samoa; Singapore; Solomon Islands; Sri Lanka; Taiwan, China; Thailand;
Timor-Leste; Tonga; Vanuatu; Vietnam
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 42.9 42.7 42.8
Time to
comply (hours) 211 217 217
Number of
payments 33.8 33.7 33.7
The most significant change in the Puerto Rico’s Total Tax Rate increased
Paying Taxes sub-indicators for Central by 15.3 percentage points following
America & the Caribbean is in the changes to the surtax bands and
time to comply, which has decreased thresholds and is the main reason for
by six hours to 211, as shown in Table the region’s marginal tax cost increase.
2.5; the regional average is still the While there were a number of other
third lowest across the regions. This increases and decreases in the Total
decrease is largely due to Guatemala Tax Rates for economies in the region,
and Costa Rica where the time the next largest was a decrease of
was reduced by 70 and 63 hours 6.2 percentage points in Barbados as a
respectively. Only St. Lucia recorded result of the methodology changes.
an increase in time, of 14 hours.
The average number of payments
increased marginally following the
introduction of a capital gains tax in
Guatemala.
The following economies are included in our analysis of Central America & the Caribbean: Antigua and Barbuda; Bahamas, The; Barbados; Belize; Costa
38
Rica; Dominica; Dominican Republic; El Salvador; Grenada; Guatemala; Haiti; Honduras; Jamaica; Nicaragua; Panama; Puerto Rico; St. Kitts and Nevis; St.
Lucia; St. Vincent and the Grenadines; Trinidad and Tobago
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 34.7 37.9 39.5
Time to
comply (hours) 245 256 256
Number of
payments 23.3 29.8 29.5
All sub-indicators in Central Asia The reduction in the time to comply Nine economies in the region show a
& Eastern Europe have fallen is by far the greatest of any region reduction in the number of payments
significantly between 2012 and 2013, and results from decreases in time in between 2012 and 2013 with Tajikistan
as shown in Table 2.6; and it is thus eight of the nineteen economies in more than halving its payments from
the most improved region in terms of the region. The greatest reduction is 69 to 31 due to the introduction of
the ease of paying taxes, continuing a 136 hours in Belarus which accounts online payment and filing for corporate
trend that has been exhibited over the for almost two thirds of the overall income tax and VAT; a reduction in the
nine years of the study. fall across the region. The changes in frequency of filing and payment for
Belarus stem largely from increased corporate income tax and real estate
The reduction in the Total Tax Rate use and enhancement of electronic tax; the merging of land tax and real
due to the methodology change is filing systems including keeping estate tax payments and the abolition
the result of small reductions in the records online, automatic updates and of the retail sales tax. Ukraine reduced
Total Tax Rates for almost all the data collection, improved training its payments from 28 to just 5, due to
economies in the region. The reduction on the use of the systems and a the increased use of electronic filing
in the Total Tax Rate between the reduced requirement for supporting and payment and Macedonia FYR and
restated 2012 data and the 2013 data documentation. Significant reductions Azerbaijan reduced their payments
can be attributed almost entirely to were also exhibited by Armenia to just 7 from 29 and 18 respectively.
a 51.6 percentage point reduction in (59 hours) following the unification The reduction in Macedonia FYR is
the Total Tax Rate of Uzbekistan and of social security and income tax due to a mandatory electronic system
a 15.5 percentage point reduction for and Ukraine (40 hours) thanks to for VAT filing and payment and
Armenia. The change in Uzbekistan increased use of online systems. On the increased use of electronic systems for
is the result of small companies other hand, Georgia’s time to comply corporate income tax. Electronic filing
being made exempt from certain increased by 82 hours following the and payment also accounts for the
contributions from salary, while in introduction of a new corporate income reduction in Azerbaijan.
Armenia social security contributions tax return that requires more detailed
were combined with income tax and information and breakdown of costs.
are now borne by employees rather
than by employers.
The following economies are included in our analysis of Central Asia & Eastern Europe: Albania; Armenia; Azerbaijan; Belarus; Bosnia and Herzegovina;
39
Georgia; Israel; Kazakhstan; Kosovo; Kyrgyz Republic; Macedonia, FYR; Moldova; Montenegro; Russian Federation; Serbia; Tajikistan; Turkey; Ukraine;
Uzbekistan
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 41.0 41.0 41.1
Time to
comply (hours) 176 178 179
Number of
payments 12.3 13.2 13.1
From last year, EU & EFTA has The 3 hour drop in time to comply
improved marginally across all three from the 2012 published data is largely
sub-indicators, most notably in its explained by Latvia’s 71 hour reduction
average number of payments as shown coupled with a 41 hour reduction for
in Table 2.7. Romania. For Latvia, much of the
reduction can be attributed to changes
For the Total Tax Rate, all but two in the VAT system so that the VAT
of the 32 economies in the region return is now a single document.
have exhibited some change since
last year, but these are all small and Romania accounts for the vast majority
any decreases are cancelled out on of the drop in the number of payments
average by the increases. There were thanks to the majority of companies
however a number of reforms in 2013 now paying their taxes online. This
that are expected to affect the Paying has resulted in a drop of 25 payments
Taxes sub-indicators next year. The from 39 to 14. Romania now has no tax
largest movement from last year is that counts for more than 2 payments
a 5.9 percentage point increase in a year, but as there are ten taxes for
Greece following an increase in the which payments are included, the
statutory rate of corporate income tax average number of payments remains
from 20% to 26% and a change in tax relatively high for the region.
depreciation rates.
European Union & European Free Trade Association (EU & EFTA). The following economies are included in our analysis of EU & EFTA: Austria; Belgium;
40
Bulgaria; Croatia; Cyprus; Czech Republic; Denmark; Estonia; Finland; France; Germany; Greece; Hungary; Iceland; Ireland; Italy; Latvia; Lithuania;
Luxembourg; Malta; Netherlands; Norway; Poland; Portugal; Romania; San Marino; Slovak Republic; Slovenia; Spain; Sweden; Switzerland; United Kingdom
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 24.0 24.0 23.7
Time to
comply (hours) 160 161 159
Number of
payments 16.8 17.6 17.6
The following economies are included in our analysis of the Middle East: Bahrain; Iran, Islamic Rep.; Iraq; Jordan; Kuwait; Lebanon; Oman; Qatar; Saudi
41
Arabia; Syrian Arab Republic; United Arab Emirates; West Bank and Gaza; Yemen, Rep.
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 38.9 38.4 41.4
Time to
comply (hours) 213 213 213
Number of
payments 8.2 8.2 8.3
The Total Tax Rate for the North The differences between the two
America region has decreased notably locations include municipal and state
by 2.5 percentage points compared to property taxes and property transfer
the 2012 published data as shown in taxes, which are higher in New York
Table 2.9. This is due to the fall in the than in Los Angeles, and the New
US Total Tax Rate, largely driven by York City corporate income tax which
the inclusion this year of Los Angeles poses a greater cost for the case
and the Total Tax Rate for Los Angeles study company than the Los Angeles
being lower than that of New York City. business tax.
42
The following economies are included in our analysis of North America: Canada; Mexico; United States
2012 2012
2013 (restated) (published)
Total
Tax Rate (%) 55.4 54.0 52.7
Time to
comply (hours) 620 618 618
Number of
payments 23.7 24.3 24.2
South America is the only region to Despite being by some way the region South America’s ease of paying taxes
show a significant increase in its Total with the greatest time to comply, the is heavily influenced by other taxes
Tax Rate, as shown in Table 2.10. This time requirement in South America which account for a significantly larger
is due almost entirely to changes to the increased by another 2 hours due proportion of all of the sub-indicators
data for Argentina where the increase largely to Colombia’s time increasing than for the other regions. Figure 2.6
in the GNIpc resulted in the case study from 203 to 239 hours as a result below illustrates the fact that these
company being subject to sales tax at of introducing a new “fairness” tax taxes have been the most important
4% rather than 3% for 2012. The rate on profits. across each sub-indicator over the past
at which the turnover tax was levied two years, though this profile has been
was also increased from 4% to 5% The average number of payments in the exhibited throughout the nine years
for 2013. region did however fall, owing largely of the study. In particular the time to
to Paraguay introducing compulsory comply is almost one hundred hours
online payment and filing for corporate greater for consumption taxes than for
income tax and VAT, reducing its labour taxes.
payments by 28 to 20.
Figure 2.6
Allocation of the Paying Taxes sub-indicators for South America across the tax types
2012
Total Tax
Rate (%) 2013
2012
Time to comply
(hours) 2013
2012
Number of
payments 2013
The following economies are included in our analysis of South America: Argentina; Bolivia; Brazil; Chile; Colombia; Ecuador; Guyana; Paraguay; Peru; Suriname;
43
As discussed in the previous sections, the movements in the average Total Tax Rate for the world and the separate
geographic regions between the data published in Paying Taxes 2014 for 2012 and the Paying Taxes 2015 data for 2013 have
been driven by significant changes in a handful of economies. Although all but nine economies exhibited some movement in
their Total Tax Rate between the 2012 published data and the 2013 data, only seven decreased their Total Tax Rate by more
than ten percentage points and only three increased theirs by more than ten percentage points. The relative effects of these
movements on the global average Total Tax Rate is shown in Figure 2.7 below.
Figure 2.7
Movement in the global average Total Tax Rate 2012 (published) – 2013
%
44
43
2012
(published)
43.1%
42
The Gambia
-1.16%
Democratic
Republic of
the Congo Uzbekistan
41 -0.34% -0.30% Guinea
-0.12% Armenia 2013
Central
-0.10% African Chad
Argentina 40.9%
Republic -0.05% Ghana Puerto Rico
+0.16%
-0.08% +0.05% +0.08%
40 110 60
Economies Economies
with Total with Total
Tax Rate Tax Rate
reduction increase
<0.05% <0.05%
-0.85% +0.58%
39
The Gambia exhibits the most There were some other smaller
significant Total Tax Rate reduction reductions in the Total Tax Rate largely
of all economies and is responsible as a consequence of the increase in
for over half of the net reduction in GNIpc. Several relatively small fixed
the global Total Tax Rate between taxes are levied in The Gambia and as
the 2012 published data and the 2013 the rates of these have not changed, but
data. It also accounts for nearly two the commercial profits have increased
thirds of the reduction of the African with the update of the GNIpc, there
Total Tax Rate. As shown in Figure was a consequent reduction in the Total
2.8 the decrease is predominantly Tax Rate by 7.7 percentage points.
due to the abolition of its cascading
sales tax, which has been replaced by
a VAT of 15%. The previous cascading
sales tax was levied at a rate of 15%
on the case study company’s cost of
goods sold. VAT however is levied
only on value added by a company
(i.e. the tax is suffered only on the
difference between turnover and cost
of sales) and is ultimately paid by
the end consumer. VAT is therefore Figure 2.8: The Gambia
not included in the Total Tax Rate, Movement in the Total Tax Rate 2012-2013
while the cascading sales tax was
%
included. This reform alone reduced
300
The Gambia’s Total Tax Rate by
221 percentage points.
2012
(published)
In The Gambia companies are required 250 283.2%
to pay the higher of corporate income
tax on profits or a tax on turnover. The
case study company pays the minimum 200
turnover tax the rate of which
increased from 1.5% to 2.0% for 2013
and this resulted in an increase in the 150
Total Tax Rate of 8.8 percentage points.
100
45 Paying Taxes 2015. PwC commentary Source: PwC Paying Taxes 2015 analysis
Democratic Republic of Congo
– increase in the case study company’s
commercial profits reduces the proportion
of commercial profits paid in tax by
63.4 percentage points.
As shown in Figure 2.9, the Democratic The statutory rate of corporate income There were some other changes to the
Republic of Congo has shown a tax fell to 35% in 2013 from 40% Total Tax Rate resulting from a small
significant drop in its Total Tax Rate. in 2012. The amount of corporate fixed tax on vehicles, a new labour tax
The updating of GNIpc has resulted income tax calculated for the case and an increase in the rate of social
in an almost four-fold increase in study company in 2013 is 1.8 times the security contributions from 5% to 9%,
commercial profit for the case study amount of the minimum tax calculated but the effect of these is small compared
company in the Democratic Republic for the 2012 published data. Following to the changes in Total Tax Rate
of Congo and as a consequence the the increase in the size of the company, described in the preceding paragraphs.
company’s fixed tax payments equate the corporate income tax does however
to a much smaller proportion of the equate to a much smaller proportion
company’s profits. of the company’s commercial profits
than the minimum tax did in 2012. In
In the data for 2012 published in Total Tax Rate terms, the minimum
Paying Taxes 2014, the land and tax accounted for 58.9 percentage
building tax paid by the company points of the Total Tax Rate for the
equated to 50.1% of commercial 2012 published data, but the corporate
profits. The tax is levied at fixed rates, income tax is only 27.5 percentage
determined as a US dollar amount per points of the Total Tax Rate in 2013; a
square metre. The tax liability therefore difference of 31.4 percentage points.
does not increase in proportion to the
size of the company. The calculated
land and buildings tax liability
increased by only 8% as a consequence
of revisions to the 2012 data to update
the exchange rate between US dollars
(the currency in which the tax rate is
determined) and the local currency.
Despite this increase, in the data for
2013 the land and building tax equated
to only 14.1% of commercial profits.
Figure 2.9: Democratic Republic of Congo
This 36.0 percentage point reduction
in the Total Tax Rate is the result of Movement in the Total Tax Rate 2012-2013
the increase in commercial profits %
resulting from the updating of GNIpc 120
swamping the increase the tax liability
2012
resulting from the exchange rate (published)
revision. Overall therefore, after all the 118.1%
100
revisions, the land and buildings tax
equates to a much smaller proportion of
commercial profits.
80
Impact of Increase in
In the Democratic Republic of Congo increased GNIpc social security
companies pay the higher of a minimum on land tax element of
burden Total Tax Rate
tax of USD 2,500 or a corporate income 60 -36.0% +4.5%
tax on profits. For the 2012 published
data, it was determined that the case Impact of paying Other changes 2013
corporate income -0.5% 54.7%
study company would have paid the 40 tax rather than
minimum tax. Following the GNIpc minimum tax
-31.4%
update, the company is subject to the
corporate income tax as its taxable 20
profits have increased dramatically.
Source: PwC Paying Taxes 2015 analysis the changes in the Total Tax Rate
Explaining 46
Uzbekistan – new tax exemptions for
small companies have reduced the Total
Tax Rate by 57.1 percentage points.
Uzbekistan had the third largest The profit taxes were also affected by
reduction in Total Tax Rate in the world an increase in the rate of land tax. This
in 2013, and the largest in the Central increased the absolute amount of tax
Asia & Eastern Europe region. Under due, but the rate of increase was much
Uzbekistan tax legislation, the case smaller than the rate of increase in
study company is viewed as a small the commercial profits. This resulted
company as it has fewer than 100 in a 6.5 percentage point reduction in
employees. From 1 January 2013, micro the land tax element of the Total Tax
and small enterprises are not required Rate. As with the other contributions,
to pay contributions to the pension fund, land tax is deducted from profit when
to the road fund, or to the educational calculating the amount of profit taxes
institution. All three contributions were due and so the change in land tax also
calculated as a percentage of sales and affects profit taxes.
in 2012 accounted for 61.9 percentage
points of the Total Tax Rate, as shown in As a result of all the changes noted
Figure 2.10. above, the profit taxes Total Tax Rate
increased from 0.8% to 12.1%.
The exemption from these contributions
has a knock-on effect on the profit taxes Other small changes in Total Tax Rate
suffered by the case study company, arose from minor data revisions.
namely corporate income tax and
infrastructure tax. As the contributions The changes in Uzbekistan highlight the
are deductible for corporate income fact that taxes cannot be considered in
tax and infrastructure tax purposes, isolation, as changes in one tax may also
there was an increase in 2013 in the affect the amount of other taxes due.
company’s profits that are subject
to corporate income tax and to the
infrastructure tax.
%
100
2012
(published)
99.3%
80
60
40
2013
Exemption of small 42.2%
companies
from various Effect of rate Increase in profit
contributions changes and taxes as a result
20 -61.9% GNIpc changes of reductions
on land tax in other taxes
-6.5% +11.3%
47 Paying Taxes 2015. PwC commentary Source: PwC Paying Taxes 2015 analysis
Guinea – increase in case study
company’s size has led to the effective rate
of IMF minimum forfaitaire tax falling
from 3.0% to 1.8% of turnover.
Another economy driving the African The presence of fixed rate taxes on
Total Tax Rate down is Guinea, vehicles and minor corrections to
which had the third largest decline social security contributions, combined
(22.9 percentage points) in the with the increase in the case study
Total Tax Rate in the African region company’s profits reduced the Total Tax
between Paying Taxes 2014 and Rate by a further 1.6 percentage points.
Paying Taxes 2015. This is shown in
Figure 2.11.
%
100
2012
(published)
80 91.2%
40
20
0
Source: PwC Paying Taxes 2015 analysis the changes in the Total Tax Rate
Explaining 48
Armenia – decline in Total Tax Rate
of 18.4 percentage points mainly due to
unification of employee and employer
social contributions and income tax.
%
50
40
2012
(published)
38.8%
30
20
2013
20.4%
Merger of Effect on corporate
social security income tax of social
10 contributions with security change
income tax +4.6%
-23.0%
49 Paying Taxes 2015. PwC commentary Source: PwC Paying Taxes 2015 analysis
Central African Republic –
fixed taxes and economic growth have
resulted in a decline in Total Tax Rate
of 14.3 percentage points.
%
100
2012
80 (published)
87.6%
Effect of GNIpc increase Other changes 2013
on environmental -0.2% 73.3%
tax burden
60
-14.1%
40
20
0
Source: PwC Paying Taxes 2015 analysis the changes in the Total Tax Rate
Explaining 50
Chad – government corrections to tax
regulations have led to a fall in the Total
Tax Rate.
The Ministry of Domain in Chad has The remaining 1.3 percentage points
recognised a mistake in the regulation of the reduction are due to the fixed
(Article 865 of the Code Général nature of vehicle registration tax
des impôts) for the computation coupled with a 440% increase in
of property taxes. Previously the commercial profits as a consequence of
computation had a multiplier of updating the GNIpc used for estimating
80%, when it should have been 8%. the case study company’s financial
Property tax is now just a tenth of its statements.
previous value, leading to a decline of
9.0 percentage points in the Total Tax
Rate as shown in Figure 2.14.
%
100
80
2012
(published)
73.8%
60 Correction of rate to Impact of GNIpc growth 2013
property taxes on vehicle tax 63.5%
-9.0% burden
-1.3%
40
20
0
51 Paying Taxes 2015. PwC commentary Source: PwC Paying Taxes 2015 analysis
Economies with significant increases in their Total Tax Rates
The Argentinian Total Tax Rate is the Following a reform to turnover tax, The increase in the turnover tax did
cause of the average Total Tax Rate in the 4% rate was increased to 5% for however mean that the company no
South America increasing between the companies with turnover in excess of longer had a corporate income tax
Paying Taxes 2014 data for 2012 and ARG$38m – the revenue of the case liability, as the company was now loss
the data for 2013. study is over ARG$46m following the making. The lack of a corporate income
updating of GNIpc. This increased tax liability reduced the Total Tax
In Argentina our case study company the Total Tax Rate by a further Rate by 3.0 percentage points for 2013
is subject to a progressive turnover tax 17.7 percentage points. compared the 2012 data published in
– as the company’s turnover increases Paying Taxes 2014.
so does the tax rate. Due to the GNIpc
more than tripling since 2005, the case The remaining 0.2 percentage point
study company’s turnover exceeded the increase in Total Tax Rate is largely due
3% turnover tax threshold (ARG$40m) to the recognition of changes to the
and became subject to the 4% tax property tax legislation, coupled with
band. As shown in Figure 2.15 this other minor revisions.
contributed a rise in the Total Rate of
14.6 percentage points.
%
140
Other changes Impact on
and corrections 2013
corporate
+0.2% income tax of
137.3%
120 Impact of company being
increase in loss-making
turnover tax rate -3.0%
2012 Impact of +17.7%
100
(published) GNIpc increase
107.8% moving company
to higher rate
band for turnover
80 tax
+14.6%
60
40
20
0
Source: PwC Paying Taxes 2015 analysis the changes in the Total Tax Rate
Explaining 52
Puerto Rico (U.S.) – due to a corporate
income tax reform and update in the
GNIpc the Total Tax Rate has risen by
15.3 percentage points.
The Central America & the Caribbean levels, is charged at different rates
region’s marginal increase in Total Tax and is subject to a minimum surtax
Rate is largely attributable to changes of 0.5% of gross income and 30%
in Puerto Rico. of computed corporate income tax.
Consequently the case study company
The increase in Puerto Rico’s Total Tax pays corporate income tax at 20%
Rate is due almost wholly to a reform plus the minimum amount of surtax,
to corporate income tax. The tax leading to an increase in Total Tax Rate
liability is calculated using a 20% basic of 16.4 percentage points as shown in
rate and a graduated surtax, which is Figure 2.16.
calculated on surtax net income. As
of 1 January 2013, surtax net income Several small changes and corrections,
is calculated after a surtax deduction including those resulting from the
of USD25,000. In 2012, prior to the GNIpc update, reduced the Total Tax
updating of GNIpc, the surtax was not Rate by 1.1 percentage points giving a
paid by the case study company as it net increase of 15.3 percentage points.
did not generate enough profit to be
subject to the tax and the alternative
minimum tax was also not applicable.
However, in 2013 the surtax applies
to companies regardless of profit
%
100
80
2012 Increase in
(published) surtax rates
40 50.7% +16.4%
20
0
53 Paying Taxes 2015. PwC commentary Source: PwC Paying Taxes 2015 analysis
Ghana – higher social security contributions
and changes to GNIpc have resulted in a
10.3 percentage point increase in Total Tax Rate.
%
40
10
Source: PwC Paying Taxes 2015 analysis the changes in the Total Tax Rate
Explaining 54
The challenges
of tax reform
Tax reform covers a broad agenda of The first theme is to keep tax rates
issues. The Paying Taxes study focuses down by widening the tax base
mainly on the administrative efficiency and minimising exceptions and
of the tax system and the overall exemptions. A second strand of
burden imposed on business (measured economic thinking is to focus taxation
by the Total Tax Rate). But there is a on expenditure and discouraging
broader economic dimension to tax socially and environmentally
reform too. damaging activities, in order to keep
down the tax burden on the creation
Economists have for many years of income and wealth. A third theme
debated the principles which should is to keep down rates of taxation on
underpin taxation– going back to internationally mobile economic
Adam Smith’s Wealth of Nations which activities and productive resources so
set out four “canons of taxation”: the tax regime attracts these resources
equity; certainty; convenience and and activities and they contribute to
efficiency. These principles still remain the strength of the national economy.
valid, but more recent tax reforms –
particularly in the richer economies of
the West – have focussed on ensuring
that the tax system encourages, rather
than discourages, productive wealth
creation. In this context, there have
been three broad economic themes
underpinning tax reforms in the
major economies around the world in
recent decades.
It is time for a new era of tax reform across the key regions
of the world economy...
Figure 2.18
Economies with electronic filing and payment system adopted by the majority of companies
43% 57%
With electronic filing and Without electronic filing
payment systems and payment systems
Figure 2.19
Regional proportion of the economies with an electronic filing and payment system counted for in Paying Taxes
North America
EU & EFTA
South America
Central Asia
& Eastern Europe
Asia Pacific
Central America
& Caribbean
Middle East
Africa
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
With an electronic filing and payment system Without an electronic filing and payment system
Results were limited to 155 economies that provided data on electronic filing Results were limited to 155 economies that provided data on electronic filing
and payment systems. and payment systems.
Source: PwC Paying Taxes 2015 analysis Source: PwC Paying Taxes 2015 analysis
Yes No No data
Figure 2.24
Average time to comply by type of tax (hours)
Consumption
taxes
Labour
taxes
Profit
taxes
0 20 40 60 80 100 120
Majority of companies pay and file tax online Majority of companies do not pay and file tax online
Figure 2.25
Average number of payments by type of tax
Consumption
taxes
Labour
taxes
Profit
taxes
0 5 10 15 20
Majority of companies pay and file tax online Majority of companies do not pay and file tax online
This chapter has three sections. Four of the economies, Romania, Russia has also taken some steps
Firstly, we take a broader look at tax China, Mexico and Russia comment to improve the dissemination of
compliance which goes beyond the on considerable reductions in their information to taxpayers, but has also
insights that are provided by the Paying compliance sub-indicators, while the focussed on making tax calculations
Taxes sub-indicators. We look at the other four, Brazil, France, Tanzania and record keeping simpler by
views provided by PwC contributors and the US, are economies where the introducing simple templates for
in response to additional questions compliance sub-indicators have not recording transactions and enabling
included in the Paying Taxes study. changed much over the course of the software providers to develop a
These questions cover additional study. This is often not because the tax program that links accounting records
aspects of the tax system including authorities are not trying to improve directly to tax software.
legislation, technology, post-filing the system, but rather the changes are
processes and perceptions around taking longer than expected to reduce Electronic filing and payment has made
tax policy. the compliance burden, or because the a significant difference to the time
focus is on areas such as post-filing that required to comply with tax obligations
Secondly, we have a guest article are not currently taken into account in in Romania, coupled with a range of
looking at the area of cooperative the Paying Taxes sub-indicators. other obligations such as consolidating
compliance. A system of cooperative social security contribution reporting
compliance allows tax authorities Looking across all of the articles it can and allowing companies to align their
and taxpayers to work together, be seen that different tax authorities financial and fiscal year ends.
with taxpayers providing data to tax have focussed on different aspects of
authorities in real time and with the tax their systems and have faced a range While Mexico’s compliance sub-
authorities providing more certainty, of challenges. indicators have reduced over the
sooner, on the taxpayer’s tax position. years, this was complicated by the
When effectively implemented, In China, there has been a focus on introduction of new taxes designed to
cooperative compliance can provide improving the relationship between increase tax revenues. After learning
benefits to taxpayers and tax authorities the tax authorities and the taxpayers from prior experiences and seeking
alike, and we consider the history of by providing more information to to align tax policy with broader social
cooperative compliance and what is taxpayers and increasing the access that policy, Mexico is moving towards a
needed to make it work. the taxpayers have to the tax authorities simplified tax system the efficiency of
in order to ask questions, file taxes and which relies on a strong technology
Thirdly, we include articles from PwC make payments. platform for its administration.
partners from a number of economies
looking at how their tax systems
have changed over the period of the
study, but with a particular focus
on compliance.
67 Paying Taxes 2015. PwC perceptions on how tax systems are changing
Looking across all of the articles it can be
seen that different tax authorities have
focussed on different aspects of their
systems and have also faced a range of
challenges.
Despite having the highest number The sub-indicators for France have
of hours for the time to comply of any changed little over the period of the
economy, the Brazilian tax authorities study. While both of the compliance
have been trying to make tax elements are well below the global
compliance easier. This is no easy task and regional averages, the Total Tax
given the number of authorities that Rate has been high throughout and
can levy taxes and a system that until is currently the highest in Europe.
recently required tax to be calculated Becoming more competitive therefore
on a substantially different basis from requires not only improvements to the
financial reporting. Reductions in administrative regime where possible,
the compliance burden are however but also a focus on why the Total Tax
expected as the Government continues Rate is high and a need to consider how
to simplify the tax system and as this might change for the future taking
taxpayers become more familiar with into account economic constraints and
electronic systems. the need to provide a certain level of
social services.
The US paints a very different picture
with the tax authority having focussed Overall, the articles afford some
considerable efforts on the post-filing useful practical insights into how tax
process. The changes here are making authorities are trying, sometimes in
a difference to taxpayers, but as the difficult circumstances, to make life
Paying Taxes sub-indicators look only easier for taxpayers. We hope they
at pre-filing compliance then any will provide inspiration for anyone
improvements in dealing with tax who wishes to improve the tax system
audits and appeals will not be reflected in which they have an interest and
in the Paying Taxes sub-indicators. given the wide range of the steps that
tax authorities round the world have
Recent reforms to electronic systems taken, we hope that everyone will find
in Tanzania have slightly reduced the a new idea that they can apply to their
time to comply sub-indicator, though own situation.
the lack of an electronic payment
system, until 2013, has kept the
number of payments sub-indicator
high. There have however been recent
changes to introduce electronic
payment systems and it remains to
be seen how readily companies will
use these.
Introduction 68
Additional insights
around the tax
compliance burden
and how tax systems
are perceived
69 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The analysis carried out in 2012 by However, the Paying Taxes sub-
PwC UK’s senior economic adviser indicators do not claim to cover all
Andrew Sentance44 suggested that aspects of tax administration and other
the business tax system can slow relevant aspects of the tax rules, and
economic growth both through the so over the years the PwC contributors
overall burden of tax payments and to the study have also been asked a
the complexity of the tax system. His number of supplementary questions
analysis also suggested that reforms developed by the World Bank Group
made to the administrative aspects of and PwC.45 These questions ask the
the tax system had a greater impact on contributors for their views and
economic growth than changes made perspectives concerning a range of
to the amount of tax paid. This perhaps aspects of tax administration including
reflects that while tax revenues taken the overall structure of the tax system,
by government are recycled within the simplicity or otherwise of the tax
economies to support government rules and how easy it is to deal with
spending, the administration and tax authorities, tax audits and post-
complexity of the tax system merely filing processes. This set of views
adds to the overall burden of business is not used in the calculation of the
without providing any compensating Paying Taxes sub-indicators, but it
benefit. Focussing reform on does provide some useful additional
administrative burdens and complexity insights into a number of aspects of
in the tax system therefore gives a lot tax administration and some wider
of scope to tax authorities seeking to perspectives on tax around the world.
improve their economies.
In this section we highlight just a
Using a case study company, the Paying few of the areas covered by these
Taxes study measures both the cost supplementary questions:
of taxes and the compliance burden
for business allowing an effective • Clarity, accessibility of
comparison of tax regimes around the information and transparency of
world on a like for like basis. Over the government data;
ten years of the study, tax reform has • Perceptions of the broader tax
been high on governments’ agendas environment and how tax systems
with 78% of the 189 economies making are used;
significant changes to their regimes. • What is it about the tax system that
While reforms initially focussed on works best and what is most in need
reducing tax rates, more recently of improvement?
the majority of reforms has been • How easy are post-filing processes
focussed on easing the compliance to deal with?
burden. In this respect the Paying • The impact of having additional
Taxes study has been good at tracking levels of government that
the implementation of systems to levy taxes;
facilitate electronic filing of tax returns • The impact of having tax
and electronic payment of tax which regimes for small to medium
is owed. sized companies;
• The use of technology.
44
Paying Taxes 2013
45
The data is this section relates only to the 162 economies for which PwC is one of the data
contributors. The economies that are omitted are: Burundi, Belize, Bhutan, Djibouti, Eritrea, Ethiopia,
Micronesia, Fed. Sts., Guinea-Bissau, Grenada, Haiti, Iran, Islamic Rep., Kiribati, St. Kitts and Nevis,
Marshall Islands, Mauritania, Palau, Sudan, San Marino, South Sudan, São Tomé and Príncipe,
Suriname, Seychelles, Tonga, Trinidad and Tobago, Vanuatu, Samoa, Yemen, Rep.
Additional insights around the tax compliance burden and how tax systems are perceived 70
1) Clarity, accessibility of Contributors in 81% of the economies
information and transparency of surveyed said that their government
government data published information on tax revenues
An important part of open received, but only 75% said data was
government and helping to ensure available by tax type and the view of
that governments are accountable just 57% was that this information was
to their citizens is how transparent up-to-date and provided forecasts for
governments are about the revenues the current year. This suggests that
that they receive and how they spend for many governments there is scope
them. Recent research that PwC has to extend the amount, nature and
undertaken in the UK as part of its accessibility of data on tax revenues.
‘Paying for Tomorrow: The future of
tax’46 project has indicated that citizens The regional breakdown shows
see a need and have an appetite that while the view is that at least
for clearer and more transparent 60% of governments in all regions
communications from government on publish some information on tax data,
tax. The same research also showed governments in the Middle East, Africa
that business would like governments and Central America & the Caribbean
to be clearer, bolder, and more specific are less likely to publish such data than
about the objectives of tax changes governments in other regions.
and policies.
Figure 3.1
Views of PwC contributors on the availability of governments data in their economies
Yes No No data
Source: PwC Paying Taxes 2015 analysis
Figure 3.2
Publication of information on tax revenues, by region, according to contributors’ views
North America
EU & EFTA
Central Asia
& Eastern Europe
South America
Asia Pacific
Central America
& Caribbean
Africa
Middle East
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Yes No No data
46
http://www.pwc.co.uk/issues/futuretax/index.jhtml
71 Paying Taxes 2015. PwC perceptions on how tax systems are changing
2) Perceptions around the Perhaps not surprisingly in the wake
broader tax environment and of the global economic downturn,
how tax systems are used contributors in 82% of the economies
In formulating government policy there surveyed believe that increasing
is a need to balance the need to raise tax revenues is one of the key aims
revenue with the need to encourage for their government, but 60% also
growth. The attitudes of the media think that implementing a system
and civil society organisations and with the specific aim of actively
other pressure groups may also have promoting inbound investment is also
an influence on government policy, an objective.
as may the extent to which additional
revenue can be raised through stronger Increasing revenues was not generally
enforcement of existing tax rules. seen as important in the Middle
East and North America and the
With this in mind the study this year goverments in these regions are
included a number of questions to seen as less likely to use tax policy to
explore what the perception is around promote investment.
the objectives of government when
designing their policies, and how tax
authorities are implementing those
policies. Some broader questions were
also asked around whether contibutors
believe other external stakeholders
aside of government and business
are interested in the tax agenda. The
questions and the responses are shown
in Figure 3.3.
Figure 3.3
How strongly do contributors agree or disagree that...
Additional insights around the tax compliance burden and how tax systems are perceived 72
As shown in Figure 3.4, Central Asia As might be expected given the The view that there is media
& Eastern Europe is the region where need to raise revenues following interest in tax was expressed by
governments were seen as most likely the financial crisis, contributors in contributors in 56% of economies,
to try in increase investment and this is 68% of economies surveyed felt that but in only 39% of economies were
the region that has shown the greatest authorities are more likely to challenge civil society organisations thought
reductions in the Paying Taxes sub- a company’s tax affairs than they were to be campaigning on tax issues (see
indicators over the course of the study. two years ago. The increased challenge Figure 3.3).
could arise from an increased chance
Those economies where contributors of a tax audit, reduced appetite Looking at the regional analysis, as
agreed or strongly agreed that tax of tax inspectors to negotiate, or shown in Figure 3.5, in North America,
policy was being used to attract interpretations of tax laws that are EU & EFTA, Central America & the
investment had an average time to less favourable to taxpayers. These Caribbean and Central Asia & Eastern
comply of 243 hours which is lower increased challenges were identified Europe the media were thought to
than the average of 345 hours for those in at least 70% of economies in all be interested in tax in the majority
economies where attracting investment regions, except Central Asia & Eastern of economies (although we note that
was not thought to be an important Europe and Africa where it was only with only three economies in the North
factor in tax policy. Similarly, the noticed in 47% of economies. America region, this majority may
Total Tax Rate was 37% on average be more easily reached than in other
for economies seeking to encourage regions). A similar regional pattern
investment compared to 43% in those was noted for interest in tax from civil
where attracting investment is not society organisations, though with
thought to be a key aim of tax policy. fewer economies in each region noting
interest from such organisations than
from the media.
Figure 3.4
In the view of contributors, government is promoting inbound investment by region
Central Asia
& Eastern Europe
Asia Pacific
EU & EFTA
South America
Africa
Central America
& Caribbean
Middle East
North America
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Figure 3.5
In the view of contributors, is the media interested in tax?
North America
EU & EFTA
Central America
& Caribbean
Central Asia
& Eastern Europe
Asia Pacific
Africa
South America
Middle East
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
73 Paying Taxes 2015. PwC perceptions on how tax systems are changing
3) What is it about the tax system This might include how open and
that works best and what is most transparent tax authorities are, how
in need of improvement? easy it is for taxpayers to contact the
As shown in Figure 3.6, contributors tax authorities, the willingness of tax
were asked to rate different aspects authorities to provide information and
of the tax system indicating which in the manner in which tax authorities
their view, were the best and which approach audit procedures.
were most in need of improvement.
While most aspects were felt to be at In the view of our contributors, tax
least adequate by contributors in the rules were felt to be the least in need of
majority of economies, there were improvement, though in only 12% of
significant numbers of economies economies were these felt to be the best
where improvements were felt to aspect of the system. This shows that
be necessary. there is clearly scope for tax authorities
and governments to improve their
Globally, post-filing processes were systems across a number of aspects.
identified as being the most in need
of improvement and this perhaps
reflects the changes that we have
seen from some tax authorities as
described later in this chapter. Many of
the changes described in the country
articles also relate to the approach of
tax authorities, which was another
area felt to be in need of considerable
improvement.
Figure 3.6
Which aspects of the tax system do contributors believe to be the best and which need most improvement?
Post-filing processes
Additional insights around the tax compliance burden and how tax systems are perceived 74
4) How easy are post-filing When asked how easy it is for a And for those economies where the
processes to deal with? company to deal with the post-filing view was expressed that the post-
The Paying Taxes study compliance process in their economy, 37% of our filing process is diffcult or very
sub-indicators are specifically focussed contributors said that they found it difficult, the average pre-filing time to
on the pre-filing requirements of the easy or very easy while 43% found comply was also significantly higher
case study company. Clearly once the process difficult or very difficult. suggesting that spending time up front
the tax returns are filed with the tax Similarly, 34% of them said the on complying with the obligations of
authority that is not the end of the process was efficient or very efficient the tax system does not necessarily
story in terms of agreeing the final while 43% said it was inefficient. This translate into an easier time post-filing
tax liability. The post-filing processes, suggests that there is a lot of variation as shown in Figure 3.9. Overall, the
including tax audits, disputes and in post-filing practices and so there suggestion is, it seems, that economies
potentially litigation, can be the most may be considerable opportunity for whose tax systems are hard to comply
difficult interaction that a business economies to learn from each other. with when filing taxes are more
might have with the tax authority. One development in this area is the use likely to be challenging throughout
Indeed, as noted above, in the majority of cooperative compliance to improve the process.
of economies it is the aspect of the post-filing processes for both tax
tax system that our contributors felt authorities and taxpayers and this is
was most in need of improvement. discussed in more detail on page 81.
Where there are disputes between the
taxpayer and the tax authority that
cannot be resolved, it is important
that there is an independent, efficient
appeals process in place. This may
well become even more important
in the future as the current changes
in international taxation such as
the OECD’s BEPS project may result
in increased disputes between
taxpayers and tax authorities and
between different tax authorities.
Tax authorities may need increased
resources to deal with these issues.
3% 7%
Very easy Very efficient
20% 23%
No data No data
34% 27%
Easy Efficient
9%
Very difficult 10%
Very inefficient
34% 33%
Difficult Inefficient
Source: PwC Paying Taxes 2015 analysis Source: PwC Paying Taxes 2015 analysis
Figure 3.9
Average time to comply based on the ease of dealing with post-filing process
Difficult
Easy
0 50 100 150 200 250 300 350
75 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The regional breakdown of the
responses shown in Figure 3.10
suggests that post-filing processes
are felt to be easier in the more
developed economies of North
America and Europe (noting that
with only three economies in the
North America region, a majority is
more easily achieved than in other
regions). South America is where
processes are perceived to be most
difficult. It is interesting to see that
post-filing processes in the Middle East
are considered to be the third most
diffcult, although the region has the
lowest average pre-filing time.
Africa Africa
Central Asia
Middle East
& Eastern Europe
Central Asia Central America
& Eastern Europe & Caribbean
South America South America
0% 25% 50% 75% 100% 0% 25% 50% 75% 100%
Note: The North America region contains only three economies: USA, Canada and Mexico. Results for the region are therefore reliant on data from a much
smaller number of contributors than other regions.
Source: PwC Paying Taxes 2015 analysis
Additional insights around the tax compliance burden and how tax systems are perceived 76
5) The impact of having As shown in Figure 3.14, 41% of The levels of government that can
additional levels of government economies in the study, contributors levy taxes is likely in many cases
that levy taxes have indicated that two levels of to be a reflection of geography and
Tax systems around the world vary in government can levy taxes while 25% the resultant impact on government
their degree of centralisation. Some said they have one level of government structures; governing and taxing a
are centralised with most taxes levied and a further 25% has three levels city state is of course a very different
at the national level, others are more of government with tax raising job to governing an economy that
decentralised with additional layers powers. No data was provided for the covers half a continent. For some
of taxation at the provincial, regional remaining 9% of economies. Lining economies therefore the realities of
or local level. There is a balance this up against the data collected on political geography may mean that it
to be struck here between making the Total Tax Rate suggests that higher is not practical to reduce the levels of
government more independent and rates exist where there are more levels government that can levy taxes.
accountable to citizens and introducing of government. It also suggests that
additional levels of complexity that more time is required to deal with pre-
business has to deal with, involving filing compliance where there are three
additional taxes and also additional levels of government, but that there is
bodies to correspond with. As shown little distinction between having one
above, the levels of government and or two levels of government that can
of tax authorities were not felt to be raise taxes.
in need of improvement by 62% of
our contributors, but by comparing
time to comply with the number of
levels of government it appears that
additional levels of government can
add considerably to the tax burden, as
can be seen from Figures 3.12 and 3.13.
3 levels
3 levels 3 levels
3 levels
2 levels
2 levels 2 levels
2 levels
1 level
1 level 1 level
1 level
0 0 100
100 200
200 300
300 400
400 0 0 10%
10% 20%
20% 30%
30% 40%
40% 50%
50%
Source: PwC Paying Taxes 2015 analysis Source: PwC Paying Taxes 2015 analysis
Figure 3.14
Number of levels of government that can levy taxes on business
9%
No data
25%
1 level
25%
3 levels
41%
2 levels
Source: PwC Paying Taxes 2015 analysis
77 Paying Taxes 2015. PwC perceptions on how tax systems are changing
6) The impact of having different This additional time raises some
or special tax regimes for small further questions which can only be
to medium sized companies answered with additional research.
There is an inevitable degree of tension First, to what extent does a small
between making a regime attractive company regime add to the compliance
and introducing reliefs and incentives burden and second, are small company
to achieve this, versus the additional regimes more likely in economies that
administrative burden that this might already have complex tax systems with
place upon businesses. Some incentives a large number of reliefs? In this latter
may be hard to access, too complex case, could it be that small company
or the degree of complexity may be regimes are introduced in an attempt
out of proportion to the value to the to make compliance easier for smaller
taxpayer. Other incentives may not companies, perhaps by simplifying
go far enough to be of real benefit. some of the rules?
Furthermore, as the number of reliefs
and incentives increases, a tax regime
will become increasingly complex. In
the context of the Paying Taxes study,
contributors were asked if a special tax
regime exists for a small to medium
sized company in their economy.
Contributors in 48% of economies
around the world indicated that such a
special regime exists. Interestingly for
those who answered ‘yes’ (and where
the case study company qualified under
the special regime) the average time to
comply was 20% higher than for those
who said that no such regime existed as
shown in Figure 3.15.
Figure 3.15
Average time to comply for economies with a special tax regime for small companies
Economies with
special tax regime
Economies without
special tax regime
Note: The chart includes data only for those economies where there is a special regime for small or medium sized companies which applies to the case study
company.
Source: PwC Paying Taxes 2015 analysis
Additional insights around the tax compliance burden and how tax systems are perceived 78
7) The use of technology Overall this suggests a high level of
It would seem obvious that the use of access around the world to information
software to gather and analyse data, technology systems coupled with
and then to perform tax calculations, considerable computer literacy.
should be beneficial. The question then This in turn suggests that there is
is to what extent is software being a strong base for tax authorities
used in this way around the world to build on for the introduction of
and could it be used more widely or in online filing and payment systems.
different ways? Indeed when asked how computer
software could be improved to help
Contributors in 87% of economies in with the tax compliance process a
the study indicated that they would number of contributors argued for the
expect a company of a similar size to introduction of online payment and
the case study company to use software filing systems.
for at least one element of the corporate
income tax preparation and filing
process. This drops to 79% for labour
taxes and social contributions and to
69% for consumption taxes. Perhaps
not surprisingly these percentages are
all higher for high and upper middle
income economies, but the use of such
systems does not show any savings
in time to comply, see Figures 3.16
to 3.20.
Gathering data
19%
No data Additional analysis
69%
Yes Actual calculation
12%
No Source: PwC 0% 100%
Source: PwC Paying Taxes Paying Taxes
Yes No No data
2015 analysis 2015 analysis
Figure 3.20
Use of software for tax compliance: Use of internal software by income
Low income
High income
Yes No No data
Note: Income groupings are defined in accordance with the World Bank definitions. See http://data.worldbank.org/about/country-and-lending-groups
Source: PwC Paying Taxes 2015 analysis
79 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The question is to what extent is
software being used around the
world and could it be used more
widely or in different ways?
Additional insights around the tax compliance burden and how tax systems are perceived 80
Cooperative compliance –
how can businesses and
tax authorities learn to
trust each other?
87 Paying Taxes 2015. PwC perceptions on how tax systems are changing
Authors
Eelco van der Enden and Katarzyna Bronzewska, PwC Netherlands47
This article is an abbreviated version of “The Concept of Cooperative Compliance” by Eelco van der
47
Enden and Katarzyna Bronzewska published in the Bulletin for International Taxation, 2014 (Volume 68),
No. 10 on 23 September 2014, available at http://www.ibfd.org/sites/ibfd.org/files/content/marketing/
Journal_Previews/BIFD_BIT/BITPreview2014_10.html
The FTA is a subsidiary body of the OECD’s Committee on Fiscal Affairs (CFA). It consists of senior tax
48
officials from 45 OECD member countries and non-OECD countries. See also section 3.
49
OECD, Study into the Role of Tax Intermediaries p. 39 (OECD 2008).
50
Id.
OECD, Cooperative Compliance: A Framework from Enhanced Relationship to Cooperative Compliance
51
p. 28 (OECD 2013).
Cooperative compliance – how can businesses and tax authorities learn to trust each other? 88
A short history of This raises the question as to the The relevant question is, “How do I, as
cooperative compliance need for, and the benefits from, the tax administration, know that the
The FTA was created in 200252 and in cooperative compliance. Often the TCF of a taxpayer indeed works?”
September 2006, following its third compliance and enforcement processes
meeting, the Seoul Declaration53 applied by various tax authorities The tax administration should provide
was issued. In this Declaration, the are no longer adequate, given the certainty and preferably behave in a
participants of the Forum decided to increased complexity of tax laws, predictable manner. How can a taxpayer
focus on four particular areas, including growth in the number and complexity rely on the tax administration behaving
examining the role of tax intermediaries of taxpayers, budgetary constraints in such a manner? According to the
in relation to non-compliance and and the need to achieve more with OECD, a tax administration should:
the promotion of unacceptable tax less. Cooperative compliance may be
minimisation arrangements. This regarded as a remedy for some of these • have business knowledge;
Declaration initiated the OECD problems. The main benefit should • be impartial;
ER Study; the scope of the Study be a win-win situation for taxpayers • be transparent;
was broadened, with the tripartite and tax authorities; the former receive • act proportionately; and
relationship between tax authorities, advance certainty and have reduced • be responsive.59
taxpayers and intermediaries as its compliance costs and the latter benefits
focus. from a more efficient use of limited The concept has been implemented or
resources. By resolving cases earlier, piloted in more than 20 jurisdictions
In May 2013, the OECD followed up on it is possible to avoid litigation and worldwide and each country has
the ER Study and published a report reduce administrative costs. Both developed a different version of
entitled “Cooperative Compliance: parties should also benefit from certain cooperation. In any case, cooperative
A Framework, From Enhanced reputational gains. compliance must be based on sound
Relationship to Cooperative Compliance” tax risk management processes that
(the CC Report).54 The CC Report The practical complications: support the trust, transparency and
gathers the experiences of the first How to make cooperative understanding, required from taxpayers
few years of cooperative compliance compliance work and tax authorities. In whatever form
operations in several countries and The twin pillars on which cooperative executed, all models have in common
is based on surveys from 21 FTA compliance is built are: (1) trust and that “real time assessing”, is a major
members and consultations with transparency; and (2) predictability and feature as it is easier to assess the facts
the Business and Industry Advisory certainty. at the time they arise.
Committee.55 It confirmed that the
five requirements initially set for tax A taxpayer should provide the Recommendations
administrations56 are valid and that tax administration with proper Looking back at the objective of
impartiality and responsiveness are information, going, if necessary, cooperative compliance to deliver
of significant importance.57 The CC beyond its legal obligations. But how quality compliance, which means
Report reiterated that commercial can the tax administration rely on the payment of taxes due on time in an
awareness is a condition for cooperative correctness of the information that it effective and efficient manner, we
compliance, and is a benefit for both receives? It can if the taxpayer has a have noted some issues that hamper a
tax administrations and taxpayers.58 process in place managing the reported successful roll-out.
For taxpayers, there are two main tax positions, i.e. the taxpayer has an
requirements, i.e.,: (1) to be open; and internal validation system that enables It is not easy to change a working
(2) to disclose upfront. it to validate output on behalf of the tax practice that is based on mistrust,
administration: a tax control framework repressive and retroactive audits over
(TCF). It then makes no sense for the many years into real-time auditing
tax administration to audit this data. systems. Under the latter, it is necessary
Of course, the interpretation of the to rely more on the willingness and
law and the fiscal consequences of ability of a taxpayer to be compliant.
transactions remain the prerogative Consequently, it is crucial for tax
of the tax administration. If output administrations to have a well-balanced
data can be “justifiably trusted” by transformation plan for cooperative
the tax administration, it can allocate compliance to become successful.
its resources to those taxpayers that
deserve greater attention.
The FTA was created to facilitate tax administrators to identify and discuss global trends as well as the development of new ideas to enhance the tax
52
54
OECD, supra n. 5
55
Id., at p. 12.
These are: commercial awareness, an impartial approach, proportionality, openness through disclosure and transparency, and responsiveness.
56
57
OECD, supra n. 5, at p. 18.
58
Id., at p. 33.
59
OECD, supra n. 2, at p. 34.
89 Paying Taxes 2015. PwC perceptions on how tax systems are changing
Tax administrations should set Consequently, the cooperative Nothing is more detrimental to
measurable objectives. If it can be shown compliance system should have a relationship built on trust and
that cooperative compliance adds value “noticeable value” for taxpayers; transparency than mismanaged
in terms of reduced cost of compliance to leave this at the discretion of the expectations. We are aware of examples
and more compliant behaviour of individual tax inspector may prove when voluntarily provided information
taxpayers, stakeholder buy-in and inefficient. In line with regulated resulted in penalties and data mining
enhanced cooperation would follow.60 self-assessment, consideration should exercises by the competent authority. A
be given to safeguarding taxpayers’ taxpayer should develop a reporting and
Cooperative compliance will fail without rights by implementing regulations on working process around cooperative
the buy-in of the individuals who have the effective audit approach under a compliance with clear deliverables
to execute it. The civil servants of the cooperative compliance system. for both the company and the tax
tax administration must be trained administration. Of course, if cooperative
properly in this audit approach, and Most companies want to be tax compliance was regulated by way of
tax inspectors provided with tools, compliant in the most efficient way self-assessment with a clear operating
guidelines and a legal framework. and cooperative compliance could be approach, this would not be necessary.
a way of achieving this objective. Until
The cornerstone of cooperative recently, tax was just regarded by most Conclusions
compliance is that tax administrations companies as a cost.62 Discussions on The concept of enhanced relationship
can “trust” the information provided by the tax behaviour of multinational has recently been transformed into
a taxpayer is right. We do not believe enterprises (MNEs) have changed this one of cooperative compliance. We
in credible and sustainable cooperative and put tax governance more at the believe that this is not the end of
compliance if the boundaries of the rules forefront.63 the transformation yet. In order to
when “trust” becomes “justified trust” make cooperative compliance work,
are not set. A legitimate approach exists Communication on taxpayers’ tax boundaries must be defined on the
when guiding principles, regulations governance, objectives and vision on concept of TCF to legitimise “trust”.
or law reduce the compliance burden tax is important in building trust. The Clear objectives must also be set and
by “regulating” part of the cooperative board and senior management must, measured against performance.
compliance model. therefore, have the intrinsic will to be
transparent regarding tax and to be We are strongly of the opinion that no
In addition to boundaries on the compliant. one benefits from a dysfunctional tax
concept of TCF, it is possible to think compliance system. All parties involved
of technology-based alternatives of The concept of a TCF is a part of a should, therefore, be open to any
regulated self-assessment, some of taxpayer’s general risk and compliance suggestions to improve tax compliance,
which already exist.61 This could prove environment. Thinking of tax as more even if it may mean a form of regulation
to be a significant advantage for both than just “costs” means that taxpayers of the cooperative compliance concept.
tax administrations and taxpayers, as may have to reconsider their current
this would provide clear guidance for tax compliance infrastructure. The
internal and external auditors. past approach was that tax returns
were deemed to be right until a tax
Taxpayers, have a legal obligation official came with an adjustment. Now a
to install a functioning TCF, as they taxpayer should be able to demonstrate
are responsible for filing proper tax that data in the relevant tax returns are
returns. However, taxpayers are, in right. This may require investment in
nearly all cases, not legally bound to processes, systems and people.
provide information outside the legal
framework of a general tax act and it is
this extra-statutory information that is
likely to be necessary for cooperative
compliance. Although the voluntary
nature of the provision of such
information fits well in a relationship
based on “trust and transparency”, the
rules of good corporate governance
prescribe that risks should be mitigated
and shareholder value protected.
In the Netherlands, no clear objectives were set and no performance measurement system was implemented from the start, thereby resulting in heated
60
debates on the effectiveness of horizontal monitoring and its value to both business and the tax administration.
61
See, for example, Authorized Economic Operator (AEO), US: Foreign Account Tax Compliance Act (FATCA), etc.
62
See, for example, the recent controversies surrounding Apple, Google and Starbucks.
See, for example, Dutch Association of Investors for Sustainable Development (VBDO), Good Tax Governance in Transition. Transcending the tax debate to
63
CSR ([2014]).
Cooperative compliance – how can businesses and tax authorities learn to trust each other? 90
PwC commentaries on
selected economies
81 Paying Taxes 2015. PwC perceptions on how tax systems are changing
Brazil 82
Brazil
Complex data provision requirements
and frequent changes to tax laws result in
a high compliance burden
Carlos Iacia, PwC Brazil
Figure 3.21
Trend in the Paying Taxes sub-indicators for Brazil
Time to comply
75 2500
2013:
60 2000 68.9%
45 1500
30 1000
2013:
9
15 1500
Number of payments
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
83 Paying Taxes 2015. PwC perceptions on how tax systems are changing
While the time to comply and the number of
payments have been extremely stable over the last
nine years, this does not reflect the considerable
change that has been taking place within the
Brazilian tax system.
Brazil has a complex tax system, Tax rules are created and amended in Certain tax authorities, especially at
mostly because the Federal Brazil on an almost daily basis, at the the federal level, have started trying
Constitution allows many different federal, state and municipal levels. to decrease the number of declarations
government entities to levy taxes. Unfortunately, the wording of these that have to be filed, but as yet these
These include the federal government, rules is sometimes unclear, making have not led to an effective reduction in
each of the 26 states and the Federal it difficult to interpret their content, the amount of effort spent in complying
District, and over 5,000 municipalities. scope and effective dates. with the rules on data provision.
Taxpayers need to monitor each of
these taxes as frequent changes in In addition to the amounts owed On top of the tangled rules, record-
legislation may affect the calculation as taxes (referred to as “primary keeping and reporting obligations,
and payment of taxes, as well as obligations”), the taxpayer is also certain companies have also become
the rules for preparing mandatory required to comply with “ancillary responsible for collecting transaction
tax records. obligations”, which consist of detailed taxes in advance, under a procedure
record-keeping and reporting of certain referred to as “tax substitution”.
The fundamental structure of the information to the tax authorities, Under tax substitution, a theoretical
Brazilian tax system is just one reason mostly in electronic format. The data retail price is attributed to the goods
for its unusually high time to comply used to calculate the tax liabilities are sold by a manufacturer or importer.
and we outline some of the other reported in electronic declarations This price is then used to calculate
factors in this article. While the time with various layouts that are required the taxes that would be owed on all
to comply and the number of payments to be submitted by multiple dates transfers of those goods in the supply
have been extremely stable over the throughout the year. The complexities chain, from the producer to the
last nine years, this does not reflect of compliance and reporting sometimes distributor to the retailer down to the
the considerable change that has been result in inconsistencies that are final consumer. The total taxes are
taking place within the Brazilian tax questioned by the tax authorities. paid by the manufacturer or importer
system. We are hopeful that as further When this happens tax staff need to as a “substitute taxpayer” at the time
changes are made and as existing spend even more time and effort to of the first sale, and the remaining
changes become embedded in the answer the tax authorities’ questions. parties in the subsequent stages of the
system we will begin to see a reduction supply chain do not pay these taxes
in the tax compliance burden in Brazil. when they resell the goods. Because
tax substitution relies on a theoretical
retail price instead of the actual
price at the final sale, it may cause
distorted results.
Brazil 84
Tax substitution systems effectively Since corporate income tax had been For unconsolidated affiliates outside
increase tax collections because they based on the pre-tax income calculated Brazil, the law permits taxation on a
allow the tax authorities to concentrate under the previous accounting cash basis (as dividends are paid) when
their enforcement at the level of the standards, a transitional tax certain conditions are met.
manufacturer or importer to prevent or mechanism was created to neutralise
detect tax evasion. the impact of the new accounting The taxation of offshore profits,
standards on taxable income. even after the enactment of this
On the other hand, they have a new law, will continue to trigger
negative impact on the cash flow of As a result of this transition, the extensive discussions between the tax
the substitute taxpayer, who must also tax authorities started to require authorities and corporate taxpayers.
maintain a tax compliance team and that corporate taxpayers prepare The tax authorities are trying to
systems to control, estimate and pay financial statements for tax purposes prevent international structures that
these taxes in advance. based exclusively on the previous are created only for tax avoidance
accounting rules, in parallel with purposes. Corporations, on the
In 2007, Brazil implemented the Public the IFRS financial statements other hand, continue to argue that
Digital Bookkeeping System (SPED) for required for financial reporting. the Brazilian legislation should not
the electronic filing of various records, The preparation of the additional oblige them to accelerate the taxation
declarations and reports. The increased statements for tax purposes demanded of undistributed income, which
use of technology by the tax authorities more time and more human and could put Brazilian products at a
created a hope that the cost and the technological resources. competitive disadvantage.
time required for tax compliance
would eventually be lower. Up to This then led to the enactment of Law From the above, we can conclude that
now, however, this hope has not been 12,973 in 2014, which integrates the the new technology implemented
realised as evidenced by the Paying tax legislation with the new Brazilian by the tax authorities has improved
Taxes sub-indicators. Many companies accounting standards and terminates and optimised the process of tax
have incurred additional costs to the transitional tax mechanism inspection and collection, while
update, customise or reconfigure their mentioned above. This change should resulting in higher tax compliance and
systems, purchase new hardware, and reduce the effort required to maintain management costs for businesses. In
train their personnel to meet these new records of the differences between the time, however, as the process matures
requirements. accounting and tax bases. and consolidates, and the government
pursues simplification, an eventual
In 2007, the federal government The same law also changed the reduction in the cost of tax compliance
enacted Law no. 11,638, which taxation of income earned by is expected. A majority of Brazilian
allowed for the convergence of subsidiaries and unconsolidated businesses already have elected
Brazilian accounting standards with affiliates outside Brazil. The law for simplified tax treatment under
International Financial Reporting continues to tax subsidiaries’ profits the presumed-profit method or the
Standards (IFRS). Convergence with on an accruals basis. Profits earned by “SIMPLES”64 uniform tax method.
IFRS was intended to increase the indirect subsidiaries are also taxable, The federal government has made
comparability and transparency of but only after consolidating those these methods available to small
financial statements and to improve profits with the profits and losses of businesses across a wider range of
the standing of Brazilian companies other indirect subsidiaries. Only the activities, in an effort to reduce the
in the international financial and net positive profit arising from this number of businesses that operate
capital markets. consolidation is subject to taxation. informally (i.e., in noncompliance).
64
SIMPLES is a simplified tax regime that is available to small and medium sized companies
85 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The effort to reduce informality
among small businesses is extremely In time as the process matures and consolidates
important, but some attention should
and the government pursues simplification an
also be given to the tax requirements of
large companies, which are a driving eventual reduction in the cost of tax compliance
force for the Brazilian economy and is expected.
GDP growth.
Brazil 86
China
Improving communication between
tax authorities and tax payers
Matthew Mui, PwC China
Figure 3.22
Trend in the Paying Taxes sub-indicators for China
% / Number Hours
85 850
80 800 2013:
64.5%
75 750
70 700
Total Tax Rate
65 650
60 600
55 550
50 500
45 450
40 2013:
400
261
35 350 hours
30 300 Time to comply
25 250
20 200 2013:
7
15 150
10 100 Number of payments
5 50
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
91 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The Chinese tax authorities have shown
a change in approach and have invested
significant amounts of time and money in
providing services to taxpayers.
Since China’s major tax reform in The consequences of many of these Organisational structure of the
1994, the Chinese tax authorities improvements are reflected in the tax authorities
and taxpayers have paid increasing Paying Taxes reports. Adequate staffing is vital to the
attention to the services provided provision of quality services for
to taxpayers, for example providing In the following section, we consider taxpayers. In 2008, the SAT established
information, helping taxpayers to file some of these changes in detail. the Taxpayer Services Department. Tax
returns and answering taxpayers’ officials in that department lead and
questions. In 2001, the Standing Changes in the approach of the supervise local level tax authorities
Committee of the National People’s Chinese tax authorities in the area of taxpayer services. Local
Congress amended China’s Tax In the early stages of China’s tax level tax authorities have also set
Collection and Administration Law reform, taxpayer services in China up Taxpayer Services Divisions to
(TCAL), which clarified for the first were neglected due to insufficient implement taxpayer services in their
time that the tax authorities are manpower, poor use of technology respective jurisdictions. By the end
legally obliged to provide services to and inadequate funding. In 1997, of 2012, 67 out of 70 provincial-level
taxpayers. Subsequently, the Chinese however, taxpayer services were tax authorities had set up designated
tax authorities have shown a change recognised by the State Council as the departments or offices for taxpayer
in approach and have invested foundation of an efficient tax collection services and the number of tax
significant amounts of time and money and administration system. In 2001, officials directly involved in taxpayer
in providing services to taxpayers and TCAL and its detailed implementation services was around 98,000 which is
in improving the ease of paying taxes rules provided the legal basis for the approximately 13% of the total number
in China. optimisation of taxpayer services. As a of tax officials nationwide.
result, the Chinese tax authorities now
Some notable milestones are: appreciate fully that taxpayers are not In addition, the SAT established the
simply required to pay taxes, but that Large Business Taxation Department
• In 2001 the Chinese State they deserve to receive assistance from (LBTD) in 2008 and selected 45
Administration of Taxation the tax authorities in understanding Large Business Enterprises (Groups)
(SAT), as the central government and meeting their tax obligations. In (LBEs) to receive designated services
authority responsible for collecting recent years, the SAT has supervised and focused administration under
and enforcing taxes, officially and drawn up work plans for local the direct supervision of the LBTD.
launched the tax service hotline level tax officials concerning the Subsequently, many local level tax
(Hotline #12366) for the benefit of improvement of taxpayer services. At a authorities identified selected LBEs in
taxpayers in general; symposium for taxpayers in 2013, Mr. their jurisdictions, some of which will
Jun Wang, the Commissioner of the overlap with the LBEs identified by the
• Between 2006 and 2008 the local SAT, mentioned that tax authorities LBTD. Therefore, many LBEs now have
level tax authorities increased and tax officials have four major a further channel through which they
the speed of implementation of tasks, namely: can receive designated services from
online filing and payment systems the Chinese tax authorities.
which significantly reduced the 1. to carry out tax reforms to meet
compliance hours of taxpayers taxpayers’ needs
(reflected in the Paying Taxes time 2. to provide information to help
to comply sub-indicator as a drop taxpayers understand the tax rules
from 832 hours to 464 hours); 3. to administer taxes in a fair
manner; and
• In 2008 the SAT set up the Taxpayer 4. to provide taxpayer services to
Services Department which improve the ease of paying taxes.
provides systematic administration
and oversight of taxpayer services
by designated tax officials leading
to significant improvements
in quality.
China 92
Platforms for the provision of Internet-based platform Services provided to taxpayers
taxpayer services In order to reduce the time taxpayers in China
The Chinese tax authorities have made spend waiting in the tax service The services provided by the Chinese
a significant financial investment in centres, the SAT issued a circular tax authorities include tax consultation
the platforms through which taxpayer in 2005 requiring local level tax and information on tax regulations.
services are provided, including: authorities to expedite the construction
of internet networks and the Tax consultation
Tax service centres and counters implementation of online filing and Tax consultation is the most popular
Tax service centres were first payment systems. Statistics indicated service provided by the Chinese tax
introduced in China in 1997 to help that in 2006 the number of online authorities to taxpayers. Taxpayers
taxpayers to file tax returns and deal filings and payments performed in can consult with the tax authorities
with other tax-related matters in China was around 40%-50% of total on a named or anonymous basis. Tax
person with the tax authorities. In tax filings. By 2013 this had increased consultation is provided in different
order to simplify the procedures and to around 80% on average across the ways; through telephone discussions,
to reduce the compliance costs, tax country and to 90% for some large internet Q&A and in person.
authorities continually improved these cities, such as Beijing and Shanghai.
facilities by setting up one-stop service This increase in online filing and Online consulting is welcomed by
counters inside the tax service centres. payment was reflected in the Paying many taxpayers. According to the SAT’s
By the end of 2012, there were 10,643 Taxes data for 2007 when the number website, the area of “tax consulting”
multi-functional tax service centres of payments went from 35 to 7 as the always has the largest volume of
with 55,460 one-stop service counters number of taxpayers using online filing hits compared to the other areas of
in China. and payment exceeded 50%. the website.
Telephone-based platform (hotline Both the SAT and the local level Hotline #12366 is also often used by
and SMS services) tax authorities have increased the taxpayers to seek advice on tax issues.
In September 2001, “Hotline #12366” capabilities of their websites. The most Figure 3.23 illustrates the increasing
was officially launched. By the end important function of the SAT website volume of consulting calls in 2007,
of 2012, 70 provincial tax authorities is the provision of information on 2009 and 2012.
had set up Hotline #12366 in their tax regulations, while for local level
jurisdictions resulting in a total of tax authorities it is the provision of
3,000 operators with tax knowledge information as well as access to online Figure 3.23
serving the hotline in different tax filing. Volume of consulting calls for the year 2007,
locations across the country. SMS is 2009 and 2012
also used by tax officials to provide Social media
Call volume
services to taxpayers, for example to In April 2014 the SAT developed
16000
send reminders and tax information. a mobile application and opened
By the end of 2010, the Chinese tax official accounts on the two dominant 14000
14300
authorities had answered 45.8 million social media sites (i.e. Weibo and
taxpayer queries through professional Wechat). Taxpayers can now receive 12000
operators, 133.56 million through tax information from the Chinese
automatic voice systems and tax authorities on a more timely 10000
237.78 million by SMS. basis. By August 2014, SAT’s Weibo
account had attracted more than 8000
8300
1 million followers. Many local level
tax authorities also operate their own 6000
5870
accounts in Weibo and Wechat.
4000
2000
0
2007 2009 2012
93 Paying Taxes 2015. PwC perceptions on how tax systems are changing
China is one of the economies in Asia
Pacific that has made the most progress
in increasing the ease of paying taxes in
recent years.
In addition to using the website and Seeking feedback from taxpayers Co-operation with other
hotline, taxpayers can also raise tax To monitor the quality and efficiency government authorities
questions with their in-charge tax of tax administration and collection and agents
officials in person and seek the local nationwide, and to understand the The Chinese tax authorities are
level tax authority’s advice. feedback and needs of taxpayers, the exploring ways to cooperate with other
SAT engaged an independent third government authorities to reduce
Information on tax regulations party to conduct National Taxpayer the compliance costs of taxpayers.
Information on tax regulations is Satisfaction Surveys in 2008, 2010 and For instance, in the Shanghai Pilot
designed to enhance taxpayers’ 2012. According to the SAT, the SAT Free Trade Zone, newly-established
awareness of tax rules and to create may conduct these surveys annually enterprises will have their own
a friendly tax environment. in future in order to have more tax registration number allocated
timely information. automatically thanks to a pilot system
A number of Asia Pacific region that shares information between
economies, including Japan and Effect on tax legislation system the tax authorities, the Shanghai
Singapore, concentrate resources An effective tax legislation system Administration for Industry &
on communicating regulations and should make life as easy as possible Commerce and other government
knowledge to taxpayers for a short, for taxpayers. China has continued to authorities. In future, if the pilot
designated period, and China is no invest significant effort and resource proves successful, the system could
different. The Chinese tax authorities in improving the tax filing process, be implemented nationwide reducing
have designated April as the “Month with some considerable success. the time spent by taxpayers on tax
for Tax Regulation Information”. Each However, some taxpayers are still registration and other formalities.
April, the Chinese tax authorities unhappy with some aspects of the
launch various tax communication Chinese tax legislation. Unclear tax China is one of the economies in Asia
activities on a range of tax topics. legislation, certain tax treatments Pacific that has made the most progress
These activities may take place in and an ineffective dispute resolution in increasing the ease of paying taxes
communities, factories, schools and mechanism may give more cause in recent years. China is continuing
remote areas. for concern than any inefficiency to implement measures to improve
in tax compliance procedures. For taxpayer services, enabled by advances
Daily tax communications by the example, an effective Advance Tax in technology, and these changes
Chinese tax authorities are made Ruling (ATR) mechanism should are expected to ease the compliance
through many channels, including, provide taxpayers with more certainty burden still further in the future.
about the tax positions of future
• Posting the official interpretation of transaction. However, China has yet
SAT circulars on the SAT’s website to adopt a formal ATR mechanism
to help taxpayers better understand although there are some instances of
a new policy; local level tax authorities providing
• Posting typical cases on a no name consulting services to taxpayers on
basis through relevant channels some uncertain tax issues. If an ATR
and providing analysis to help mechanism could be introduced
taxpayers learn lessons from these in China in future, taxpayers
cases and avoid making the same would benefit and tax compliance
mistakes; become easier.
• Printing and distributing booklets
on specific tax topics (e.g., business
tax to VAT transformation pilot
programme) to help taxpayers
understand tax policies and tax
administration practices;
• Organising seminars and training
for taxpayers along or together with
other government authorities
China 94
France
The French tax system is beginning to change
Thierry Morgant, PwC/Landwell France
Figure 3.24
Trend in the Paying Taxes sub-indicators for France
60 180
50 150
2013:
40 120
137
hours
30 90 Time to comply
2013:
20 60 8
Number of payments
10 30
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
95 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The tide has started to turn in 2014 with a number
of reforms now in place but which have not yet
affected the Paying Taxes sub-indicators.
At 95, France’s position within the We now have ten years’ worth of For France, the critical indicator
Paying Taxes study could appear Paying Taxes data enabling not only a which explains the country’s overall
surprising at a first glance, but a more comparison from one year to the next, ranking is the Total Tax Rate. It will
thorough consideration shows that it but also the analysis of a trend over not surprise economic observers that
is a reasonable reflection of the overall the nine years of the study. The trend France has the highest Total Tax Rate
environment, the tax system currently is absolutely clear: all the Paying Taxes amongst EU countries and the third
faced by many French taxpayers, and sub-indicators for France have been highest amongst the G20 economies
in particular the relative position of relatively stable for most of the study (only Brazil and Argentina have higher
France’s Total Tax Rate compared to period whereas most other countries Total Tax Rates). Furthermore, the
those of the other 188 economies. have engaged in reforms which have French Total Tax Rate is significantly
materially reduced each of their Paying higher than that of the vast majority
The three Paying Taxes sub-indicators Taxes sub-indicators. of other economies; at 66.6% the
for France have been relatively stable, French Total Tax Rate is 63% higher
but a combination of revisions to the With regard to the number of than the world average Total Tax Rate.
underlying data and changes to the payments and the time to comply, Finally, the exclusion from the ranking
methodology used for the study in France is within the best in class distribution of the outlying Total Tax
the latest period has meant that they economies for both the EU and G20 Rates introduced by recent changes
have increased when compared with groups of economies. For each group to the ranking methodology places
the results published for the previous it performs significantly better than France much closer to the upper limit
year. The Total Tax Rate has increased the average. But it is worth noting that for the Total Tax Rate in the study than
by 1.9 percentage points to 66.6%, the average is deeply dependent upon in previous years when all economies’
the time to comply has increased by some economies having extremely Total Tax Rates were considered in the
5 hours to give an annual compliance burdensome compliance obligations. ranking distribution.
burden of 137 hours and the number As such, the relatively good position
of payments has increased by 1 to give of France for these sub-indicators France’s attractions are often perceived
8 payments in total. provides limited benefit in terms of its as lying in areas other than being a
rank compared to most of its peers. business friendly environment and it is
widely acknowledged that significant
changes are needed to overcome this
general perception. In this respect,
the tide has started to turn in 2014
with a number of tax reforms now in
place, but which have not yet affected
the Paying Taxes sub-indicators. Other
reforms are still being discussed and
are aimed at addressing the overall
burden of managing and paying taxes
and social contributions in France.
France 96
The extent to which such reforms Becoming more competitive from a tax
would positively impact the French perspective will require more than just
ranking remains uncertain, given reducing some of the administrative
both the nature of the reforms and burdens faced by companies. Most
incentives and the fact pattern used for economies that have made significant
the Paying Taxes study. An example of progress within Paying Taxes were
one of the most visible actions taken starting from a low base that could
in the past two years was the creation be improved materially or have
of an employment tax credit for undertaken significant reforms
entities with employees whose annual to attract new activities, facilitate
remuneration is less than twice the employment and start new businesses.
minimum salary. This credit with a As for many other OECD member
total cost of €20 billion will represent countries, the shift to electronic
a real change in the taxation of those compliance has already happened in
entities that qualify. France and the only remaining element
to consider is the reason for the high
Given the overall budget constraints Total Tax Rate.
of the country, a material real net
reduction in the taxation level is Not surprisingly, France remains
probably unrealistic in the short term. the most expensive economy in the
A number of initiatives have however entire study when it comes to labour
been set in motion to facilitate the taxes, with a labour tax Total Tax
management of tax affairs by French Rate of 51.7%, unchanged from the
based companies. At the initiative prior year. The introduction of the
of the government, several working employment tax credit mentioned
groups are currently in place to above may help improve the French
identify redundant requirements and taxation environment, but there are
obligations. In the best case scenario, of course still difficult decisions to be
this could lead to a reduction in the taken regarding the need to balance
“time to comply”, but as we saw objectives around providing a tax
earlier this represents a marginal system which encourages businesses
element of the French ranking where to invest and grow, with objectives
France already compares well with its around providing the social services
international peers. These reforms are that the public may demand.
in any case necessary and all benefits
are to be welcomed if they encourage To conclude on a positive note, we are
and facilitate business activities. hopeful that over the next ten years,
France will begin to make reforms to its
tax system that will make a difference.
There is the potential for progress to be
made with regard to the administrative
burden, and the restriction of the
budget deficit within acceptable limits
may also help with the potential
to revisit the level of taxation that
is applied.
97 Paying Taxes 2015. PwC perceptions on how tax systems are changing
There is the potential for progress to be made with regard
to the administrative burden, and the restriction of the
budget deficit within acceptable limits may also help with
a reduction in the overall Total Tax Rate.
France 98
Mexico
Mexico’s tax compliance system –
a story of progress
Mauricio Hurtado de Mendoza, PwC Mexico
Figure 3.25
Trend in the Paying Taxes sub-indicators for Mexico
50 500
2013:
334
40 400 hours
Time to comply
30 300
20 200
2013:
6
10 100
Number of payments
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
99 Paying Taxes 2015. PwC perceptions on how tax systems are changing
In the past decade, Mexico has seen the introduction
of a series of measures aimed specifically at
addressing the trends of the global economy.
Fast and efficient administration of Aware of the necessity to keep up with While the simplification of a tax system
tax collection can translate into less the global economy, as early as two in its design and implementation is
hassle for businesses – and often decades ago, Mexico embarked on often seen as a valuable goal by both
higher revenue for governments. an initiative to negotiate a network taxpayers and governments, the need
In a competitive global market, the of tax treaties, with as many as 50 to raise tax revenues cannot be ignored.
design of a tax system can influence countries. And in the past decade, Policies may be required to raise
multinationals when deciding where Mexico has seen the introduction of a necessary revenues which will make
to invest, or the timing for a decision series of measures aimed specifically a tax system more complex. In these
to make a long term commitment to a at addressing the trends of the instances governments need to measure
specific country. global economy. Mexico has been the various factors involved in the
faced with the necessity to find the development of tax policy, including the
For any jurisdiction, a tax system needs correct balance between offering an sensitive topic as to how much revenue a
to be both fast and efficient, while attractive environment for investors particular policy is expected to generate
at the same time having the ability and establishing an efficient tax system and what the cost will be to business in
to meet the revenue needs of that that delivers sufficient revenue for the complying with that policy.
jurisdiction. An overriding principle country’s needs.
for governments to consider (among Mexico saw the implementation of an
a number of other factors) is that Perhaps one of the most noticeable alternative minimum tax, the asset tax,
simple tax systems coupled with fast actions that the Mexican government as early as 1989, when the Mexican
and efficient administrations can help has taken began in 2003 when, in government sought to put in place a
promote economic growth by creating an attempt to encourage investment measure that would complement the
a predictable environment from which and stimulate economic activity both then established income tax system.
both businesses and governments can nationally and internationally, it This was an attempt to restore the
benefit in the long run. started steadily to reduce its corporate level of government revenue which
and individual income tax rates from had been eroded over the years. While
Ensuring that the tax system keeps up 35%. Since 2010, the corporate tax the implementation of the asset tax
with the ever changing global economy rate has remained at 30% as part was successful in so far as it reached
in this modern age is no easy task, of Mexico’s response to the global its goal of increasing the amounts of
and this is of concern to emerging financial crisis, despite announcing revenue collected, over the years it
and developed economies alike. intentions to reduce the rate further. has also resulted in an erosion of the
Governments need to make policy The 30% rate has, in effect, become effectiveness of the revenue collection
choices based on what they perceive permanent as an integral part of system. In 2008 the need arose again
their own individual needs to be, the Mexico’s measures to generate to reinforce the income tax system,
policy direction they wish to take, and revenues to finance its economic including measures aimed at dealing
taking into consideration where they advancement. Other measures with the global financial crisis. This
believe they are in the context of their introduced with the same aim included included measures such as increasing
worldwide competitive position and an increase in the VAT rate from tax rates and the introduction of a flat
investor ranking. The Paying Taxes 15% to 16% in 2010 and its general tax which replaced the asset tax. While
sub-indicators can help inform that application throughout the country, the introduction of this new tax could
decision making process. plus the implementation in parallel of a be perceived as adding unnecessary
minimum tax system and the decision complexity and additional burdens to an
The following paragraphs show the to levy a tax on cash deposits, which otherwise stable system, the impact on
evolution of the Mexican tax system served as a measure to address issues taxpayers of the additional compliance
over the period of the Paying Taxes around the informal economy. burden was expected to be far less than
study and earlier. the impact on increasing government
revenues and on the promotion of
economic activity and investment.
Compared with the asset tax, the flat tax
was less likely to deter investment, as all
cash disbursements for expenditure and
capital investment were deductible.
Mexico 100
The 2008 fiscal year also saw the With expertise and experience in both Once again in 2014, Mexico saw
introduction of a tax on cash deposits the private and public sectors, this the need to adjust its tax system to
which sought to regulate Mexico’s team was assigned by the Mexican build a strong economy that is able
informal economy. The tax was government to integrate electronic to withstand the effects of a global
creditable against federal taxes systems and platforms into Mexico’s recession and with high expectations
and was intended to raise revenues tax system. This led to a series of for national economic development
from the informal sector, to promote achievements including the adoption and growth. The Executive, driven
incorporation and so to increase the of an online portal through which tax by The Pact for Mexico, sought to
number of registered taxpayers. payers can perform compliance and promote tax reform that would, among
consulting operations, the introduction other things, give permanence to,
Despite the introduction of these new of security certificates in order to simplify and make more efficient the
taxes, simplification of the tax system perform electronic transactions, the collection of taxes, combat tax evasion
is also seen as important. Starting implementation of electronic tax and eliminate what were viewed as
in 2014, Mexico has implemented payments and the cross referencing of excessive tax privileges.
measures to simplify its VAT system tax information. These achievements,
by the unification of the VAT rates which were intended to speed up In light of these expectations, the
applied at 16%, repealing the 11% the various processes involved in Mexican government secured
VAT rate (10% before 2013), which filing taxes, have provided Mexico’s congressional approval of major
had been applicable to transactions current tax compliance system with changes in its tax legislation with its
performed within Mexico’s border improved administration processes success dependent on the Integral
zone. This is intended to make both (though there is still room for further Solution of the Tax Administration and
the collection and administration of improvements). This achievement, in its related platform. A clear example
this particular tax efficient for the combination with other economic and of this can be seen in one of the
government administration and tax deregulatory measures, is expected to major changes to Mexico’s legislation
contributors alike. help promote sustainable growth in the mentioned above – the repeal of both
immediate future. the tax on cash deposits and the flat
The changes to the tax system tax and the introduction of the new
mentioned above would have been far The Pact for Mexico income tax law. The new law relies on
more difficult to implement if it were The day after taking office on the experience gained from the flat tax
not for a series of efforts made by the 1 December 2012, Mexico’s current and the reporting processes introduced
Mexican government aimed at making President met with leaders and with tax on cash deposits. Significant
the most of technological advances. In key members of Mexico’s political changes in the structure of the system
particular, significant improvements parties to sign a national political have been inspired by the flat tax,
have been made to ensure the agreement. Composed of a series of which eliminated all tax incentives,
rapid exchange of information public proposals, The Pact for Mexico and suspended tax consolidation and
and automation of processes. This has led to the implementation of a restricted deductions based on the
was largely achieved through the series of reforms touching various OECD BEPS principles. Several changes
appointment in 2002 of an advanced topics ranging from education, made to the income tax law were based
and competent technical team led telecommunication, finance and on not having to rely on alternative
by an engineer who headed the Tax energy and, crucially, Mexico’s minimum taxes, and so resulted in
Administration Service during that tax reform. limitations on deductions which help
administration. achieve one of the political agreement’s
major goals of eliminating privileges
while also simplifying the system and
making the collection of taxes more
efficient.
101 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The Pact for Mexico has led to the implementation
of a series of reforms touching topics ranging from
education, telecommunication, finance and energy
and crucially Mexico’s tax reform.
Most recently, the secretary of Treasury The intention is for these reforms to
and Public Credit (the finance ministry support a growing middle class and a
of Mexico) has announced the signing declining poverty rate with the goal
of a further agreement focused entirely for Mexico to be the world’s fifth-
on tax matters. This states that there largest economy by 2040. It seems
will be no further tax modifications likely therefore, notwithstanding the
initiated by the executive power until current commitment of the Mexican
November 2018, placing trust in the government to make no further tax
implementation of measures already law changes for the rest of its six year
approved and in the strength of the administration, that the Mexican
technological platform which supports Congress or the States could initiate
the tax administration. changes to the tax system to further
promote economic development or
In summary, two decades after the benefit the business community. Such
start of the government’s current changes might include measures to
mission to reform the tax system: promote investment and employment,
as well as people development and
1. Currently all taxpayers file innovation. This could be achieved
their taxes through paperless by offering benefits such as simplified
electronic means. tax incentives for investments, the
2. The corporate tax rate is set at 30%, creation of jobs, to support innovation
with a dividend tax applied to net and for enhancing productivity.
profit distributions to individuals Other measures to reinforce those
and foreigners, while the graduated already taken by the Executive, and
rates of individual income tax are which could facilitate an eventual
levied at a maximum of 35% on corporate tax rate reduction, may
global income with very limited include redesigning consumption
personal deductions. taxes, excluding basic foodstuffs and
3. All deductions need to meet strict the coordination of the registration
requirements, with transfer pricing and enforcement efforts with the State
standards and BEPS restrictions governments to encourage participants
already in place. in the informal sector to become
4. Group taxation is no longer registered taxpayers.
available, as it was viewed as one
of the tax privileges that were
not in line with the government’s
broader policy.
5. All tax incentives have been
eliminated to reduce their impact
on revenues and the complexity
that they add to the system.
Mexico 102
Romania
Fiscal and economic changes are helping
to improve growth and increase investment
Mihaela Mitroi, PwC Romania
Figure 3.26
Trend in the Paying Taxes sub-indicators for Romania
% / Number Hours
120 240
110 220
2013:
100 200
159
hours
90 180
Time to comply
80 160
70 140
2013:
60 120 43.2%
40 80
2013:
30 60 14
20 40
Number of payments
10 20
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
103 Paying Taxes 2015. PwC perceptions on how tax systems are changing
In 2004 all tax regulations were unified
into a single Fiscal Code, an important
step to bring clarity to the Romanian
fiscal legislation.
As with many other European One important development in the Some reforms intended to improve
countries, Romania began to feel the Romanian tax framework, however, the tax system have followed. These
effects of the economic crisis from took place a long time ago, before tax efforts helped Romania achieve its
early 2008; budget revenues declined many of these macroeconomic changes fiscal targets and also had a positive
while public spending increased to took place and prior to the instability impact on the sub-indicators analysed
support the financial sector, increase in the fiscal climate resulting from in the Paying Taxes study as shown in
social spending and provide the the economic crisis. In 2004 all Figure 3.26. For example, the number
necessary stimulus to mitigate the tax regulations were unified into a of payments has decreased from
economic downturn and set the basis single Fiscal Code. This was a big 113 tax payments per year in 2007, to
for recovery. step forward and was intended to 39 tax payments per year in 2012 and
bring clarity to the Romanian fiscal fell even further to just 14 payments
Romania struggled to recover from the legislation. in 2013. Beneficial reforms have also
crisis and it was some time before the lead to reductions in the time to comply
results of the counter measures started Another key moment in Romania’s from its peak of 228 hours per year
to become visible. The most important fiscal history was the accession to in 2009, to 200 hours in 2012 and
sign of recovery was seen in 2013, the EU in January 2007. Romania’s 159 hours in 2013.
when Romania registered one of the EU accession had a hugely important
highest economic growth rates in the impact on VAT regulation, for example.
EU. According to the National Institute Romanian VAT legislation is now
of Statistics, Romania’s GDP grew by almost completely in accordance
3.5% in 2013 exceeding the forecasts with the EU’s common VAT system
made 12 months before which had which is very familiar not only to
expected growth to be below 2%. Both EU companies, but also to non-EU
annual and quarterly growth figures companies that do business in the EU.
reached their highest values since As of 1 January 2007, the Romanian
the beginning of the crisis. Moreover, authorities were obliged to comply
macroeconomic indicators in Romania with the EU VAT system principles,
pointed towards good economic the rulings of the Court of Justice of
stability. These welcome signs have the European Union (CJEU) and the
begun to increase the trust of investors. European Regulations. Taxpayers may
therefore base their VAT compliance
The fiscal climate in Romania has been not only on local legislation (which in
relatively unstable during the last ten some areas is not as clear as it perhaps
years, but this instability was in part could be), but also based on CJEU case
the results of the efforts by tax officials law and European fiscal principles
to achieve an optimal mix of fiscal which override local legislation.
measures to generate revenues and,
at the same time, maintain business
confidence in the fiscal and economic
environment.
Romania 104
We provide an outline below of some • From June 2012 the VAT • From the beginning of 2014,
of the important measures introduced registration threshold for small taxpayers may claim refundable
by the tax authorities in recent years undertakings was increased VAT amounts below €10,000
which were intended to reduce the high from a turnover of €35,000 (45,000 RON) with post-approval
tax compliance burden faced by many (119,000 RON) to a turnover of inspection. Approximately half of
taxpayers. Some of these measures €50,000 (220,000 RON). This all VAT refund claims are under this
have helped to improve the Paying had a significant impact on the threshold and the total amounts
Taxes compliance sub-indicators as Romanian business environment for such claims do not exceed 5%
mentioned earlier: as around 70% of the total number of the total VAT refunds requested.
of companies in Romania have Speeding up VAT refunds in this
• From October 2010, online filing a turnover below this increased way should have a positive impact
for corporate income tax and VAT threshold; thus, almost 70% on around 50% of companies
has been mandatory for large of small Romanian companies requesting VAT refunds, compared
and medium sized companies. In have the option, but are not to the current situation. These
addition, online filing of labour obliged (unless they perform companies have only to tick the
taxes became mandatory for intra-community transactions), VAT refund box on the VAT return
all categories of taxpayers from to register for VAT purposes and to claim the refund and they
1 July 2011. The introduction of submit VAT returns. should normally receive the refund
online filing had a big impact on the within 45 days. Alternatively, the
time spent by taxpayers in filing tax • As of January 2013, the anticipated balance can be carried forward
returns and this impact can be seen profit tax payments system was against future VAT liabilities. This
in the reduction in the Paying Taxes introduced. This gives taxpayers measure also has benefits for the
sub-indicators from 2010 onwards. the opportunity to compute tax authorities as it significantly
their profit tax liability only at diminishes their workload.
• In addition, a single statement the year-end and to make their
for social security contributions quarterly tax payments based on • Last but not least, as of
was introduced at the beginning the profit tax computed for the 1 January 2014, at the request of
of 2011. The introduction of this previous year. Previously, taxpayers business, the Cash Accounting VAT
unique statement (Form 112) has could only compute their profit Scheme (which was mandatory
made it much easier for taxpayers to tax liability quarterly in order to since 1 January 2013) became
meet their compliance obligations. calculate the amounts of their optional for companies with taxable
Specifically, data which was quarterly payments. VAT turnover below €500,000. This
previously collected by three system allows taxpayers, whose
institutions is now consolidated • During 2014, there were further tax customers pay invoices only after
and gathered by one institution: reforms aimed at easing taxpayers’ a delay, to pay the output VAT to
the National Agency for Fiscal compliance burden. More the state budget only after they
Administration. This reduced specifically, since 1 January 2014, have received payments from
the number of tax statements taxpayers can choose to align their their customers. This benefits the
from six statements with multiple fiscal year with their financial taxpayer’s cash flow. However, the
annexes per month to just one year. Previously a company’s fiscal right of the taxpayer to deduct input
monthly statement. Similar to the year had to be in line with the VAT is also deferred until the date
introduction of online filing, this calendar year. This measure was the payment is made.
measure has reduced the number introduced in order to more closely
of hours needed for tax statement align accounting and tax provisions
preparation and submission and and to help certain categories
had a significant impact on the of taxpayers.
Paying Taxes sub-indicators.
105 Paying Taxes 2015. PwC perceptions on how tax systems are changing
In addition to the measures aimed at
helping to ease compliance further reforms
have been introduced with the aim of
increasing the level of investment.
In addition to the measures aimed • From 1 January 2014, the • In order to encourage investment
at helping to ease the compliance government introduced fiscal and innovation at a time when
burden, further tax reforms have been measures to encourage the setting the private sector needed to
introduced in Romania in recent years, up of holding companies in strengthen its financial position to
with the main purpose of increasing Romania. In particular, dividend compensate for the lower demand
the level of investment at a national revenues, capital gains and income from European and international
level. These reforms included: derived from the liquidation of markets, the Romanian authorities
other entities are not taxable introduced an important new
• As part of a fiscal policy focused provided that the Romanian tax facility which allows profits
on further developing research holding company holds a minimum reinvested in new technological
and innovation in Romania, in of 10% of the share capital of its equipment to be exempt from tax.
2008 the government introduced subsidiary (Romanian company According to the tax law in force,
a tax incentive for R&D activities or a company set up in a state the tax exemption applies to profits
performed in Romania, through with which Romania has a Double reinvested in new technological
which companies could benefit Tax Treaty) for a continuous equipment manufactured and/
from an additional 20% deduction period of at least one year. The or acquired and commissioned
for eligible expenses; accelerated introduction of this regime in during the period 1 July 2014 –
depreciation could also be applied Romania is expected to generate 31 December 2016.
for equipment used in research and multiple benefits especially for
development (R&D). This incentive Romanian head-quartered groups • Another important area for
was further improved in 2013, as it will allow more efficient business is the state aid schemes
when the additional deduction management of the group structure proposed by the government.
percentage was increased to 50% and related costs, but it should Regulations on state aid have
and the incentive was extended for also benefit the government. From existed in Romania since 1999.
R&D activities performed in the the government’s perspective, the The strategy of the government
EU or in countries belonging to the implementation of the holding is consistent with the intention to
European Economic Area. company regime could bring rebuild investor confidence and
indirect, but not necessarily to boost foreign direct investment
• Another tax incentive introduced immediate, benefits; a positive that helps create and maintain
in 2008 was the reduced VAT rate indirect impact in the medium jobs and regional welfare. For the
of 5% for dwellings delivered as to long term could be expected period 2014-2020 two state aid
part of social policy, including old if the regime attracts companies schemes were approved by the
people’s homes, retirement homes, to Romania that develop other government: the first supports
orphanages and rehabilitation activities (e.g. management, investments that create new
centers for children with accounting, legal and consulting jobs and the second supports
disabilities. In addition to the social services). This could lead in turn investments that have a major
impact, this measure was designed to the creation of new jobs. In impact on the economy. For the job
to encourage the recovery of the addition, a holding regime could creation scheme, the government
real estate market following the encourage the preservation of provides non-reimbursable funds
economic crisis. local capital and would benefit to a maximum of between 15%
Romania within the global and 50% of the salary costs for two
economy. Furthermore, Romania consecutive years for the new jobs
could become a location for created. For the scheme supporting
regional holding structures investments with a major economic
thereby increasing the country’s impact, companies which make an
attractiveness to foreign investors investment of at least €10 million
and promoting the accumulation can receive state aid of between
of foreign capital. This would 15% and 50% of the investment.
ultimately generate a larger tax
base and higher tax revenues for
the authorities.
Romania 106
To help fight tax evasion, the Romanian In a nutshell, we see that Romania’s
VAT legislation will introduce a fiscal and economic framework
reverse charge mechanism for certain is increasingly moving towards a
domestic supplies, such as cereals and climate of internal political stability,
industrial crops, the supply of energy reflected in the economic recovery,
to taxable persons, green certificates greater confidence for investors, more
transactions, emission certificates, budgetary discipline and increased
wood materials and waste. Businesses efficiency. Currently, tax officials
have welcomed these measures are heavily involved in a process of
as benefiting cash flows as well as improving the tax administration
combating tax fraud. system and staying close to the
business community to ensure a
In the current global economic climate, framework for continuous cooperation
attracting and maintaining investment and development. Progress has been
is high on every government’s made with a view to achieving the right
agenda with each country seeking to balance between fiscal consolidation
adopt measures which improve the and sustainable economic recovery,
attractiveness and the competitiveness and between economic and social
of the market. One current project on credibility and predictability; yet, there
the Romanian government’s agenda is still room for improvement. The
is the reduction by 5 percentage business community acknowledges
points of the employer social security all the positive tax reforms already
contributions which came into effect in implemented and is actively involved
October 2014. The business community in the process of restructuring the
welcomes this initiative and considers legislative framework by working
it a tax measure which will favour together with the Romanian officials in
companies of all sizes. optimising the tax system.
107 Paying Taxes 2015. PwC perceptions on how tax systems are changing
Currently, tax officials are heavily
involved in a process of improving
the tax administration system
and staying close to the business
community to ensure a framework
for continuous cooperation
and development.
Romania 108
Russian Federation
Simplified processes and the integration of
tax and accounting systems have made the
Russian tax system easier to comply with
Andrey Kolchin, PwC Russia
Figure 3.27
Trend in the Paying Taxes sub-indicators for Russian Federation
% / Number Hours
60 600 2013:
49.0%
40 400
30 300
2013:
168
hours
10 100
2013:
7
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Number of payments
Source: PwC Paying Taxes 2015 analysis
109 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The overall trend to reduce tax rates has
been accompanied by a number of steps
aimed at easing the tax compliance burden.
The Russian tax system has been 4. A range of other tax changes
relatively stable in terms of the effectively reducing the tax burden
structure of taxes since the codification on the case study company. Of
of tax law that was concluded in particular note, from 2013 newly
2001. Profit tax on organisations, acquired movable assets are exempt
personal income tax on individuals from property tax on organisations.
and VAT remain the key contributors
to national tax revenues, together with The overall trend to reduce tax rates
payments to the pension, social and has been accompanied by a number
mandatory medical insurance funds of steps aimed at easing the tax
bundled together in one legislative compliance burden, especially through
act and subject to the same rules for electronic data exchange between the
calculating the taxable base to which tax office and taxpayers. The initial
the different rates are applied and foundations for this were laid down
timing of payments and reporting. in the late 1990s. Further progress
The main trend that affected the was a function of the increased
Russian Paying Taxes results from penetration of the internet in Russia
2004 to 2009 was a series of reductions and the spread of internet banking
in key tax rates. Since 2009, the and tax accounting software. New
improvements recorded in the Paying impetus was given in 2010, with a
Taxes sub-indicators have been more push by the tax administration into a
closely linked to reductions in the dramatic widening of the number and
time required to comply with tax functionality of electronic services for
obligations. taxpayers (the total number of services
went up to over 30 in a short timespan).
The main changes in the tax rates This has been accompanied by a range
have been: of other initiatives aimed at reducing
the time and effort that taxpayers
1. A reduction in the headline profits need to comply, especially in the area
tax rate in 2009 from 24% to 20%. of profits tax and VAT as the most
material taxes.
2. An overall reduction in the top
statutory rate for consolidated
social contributions (through a
series of increases and decreases)
from 35.6% in 2004 to 32.5%
in 2013. Limits have also been
effectively reduced on the tax base
to which the top rate is applied.
111 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The latest available data
suggest almost an 80%
uptake of electronic
tax filing.
Figure 3.28
Trend in the Paying Taxes sub-indicators for Tanzania
2013:
181
hours
% / Number Hours
70 210 Time to comply
2013:
60 180 49
Number of payments
50 150
2013:
40 120
44.3%
20 60
10 30
0 0
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
113 Paying Taxes 2015. PwC perceptions on how tax systems are changing
Electronic filing of tax returns is currently
limited to VAT returns but it is anticipated
that in due course the ability to file
electronically will be extended to other
tax returns.
Tanzania’s performance in the World The 2013 Budget had seen a reduction banks directly into specific TRA systems,
Bank annual global report on the ‘Ease in this levy from 6% to 5% and it was and (iii) mobile payments, and enables
of Doing Business’ has consistently anticipated that subsequent budgets multiple tax payments to be made
been poor – and this notwithstanding would see a continuation of this trend simultaneously. A significant immediate
the preparation and endorsement in with the ultimate aim being a rate no success (since its introduction in
July 2010 of a government sponsored higher than 2% – however the 2014 August 2013) has been the facility to use
roadmap for the improvement of Budget saw no further reduction. mobile phones to remit annual motor
Tanzania’s investment climate. The vehicle licence fees.
objective of the roadmap was to seek By contrast Tanzania performs well in
to improve Tanzania’s ranking from its terms of time to comply (better than Electronic filing of tax returns is
historic three digit ranking to two (that all countries in the EAC and below the currently limited to VAT returns only,
is within the top 99 economies). This world average) notwithstanding the but it is anticipated that in due course
objective however remains elusive. higher number of tax payments to be the ability to file electronically will also
made (significantly higher than both be extended to other tax returns. Where
The Paying Taxes indicator is one of the the EAC and world average). In terms electronic filing and payment for a tax is
ten indicators from which the ease of of easing the administrative burden available and it is used by the majority of
doing business ranking is derived. In the of complying with tax obligations, it companies of the size of the case study
Paying Taxes 2015 report Tanzania ranks is clear that the greatest opportunity company, the payments sub-indicator for
148, a decline of one place from 2014’s lies with prioritising a reduction in the that tax is recorded as one, even though
restated ranking of 147.65 In seeking number of payments that taxpayers multiple payments are required. It will
to understand what is driving this low are required to make. The number of be interesting to see if reforms in this
ranking it is instructive to review the payments continues to be particularly area can be successfully implemented
country’s performance on the three high in view of a lack of an electronic and used by the majority of businesses.
separate components that make up the system for filing and paying the social
ease of paying taxes ranking, namely (i) security contributions, the skills and In 2013 Tanzania adopted the “Big
the total cost of taxes borne by business development levy and the corporate Results Now” (BRN) initiative based on
(the Total Tax Rate), (ii) the time it takes income tax. For VAT as of October 2012 the Malaysian model of development
to comply, and (iii) the number of tax an e-filing system was introduced for as part of the effort to transition
payments made. all VAT registered taxpayers reducing the country from a low to middle-
the time it takes to prepare and file income economy. This comprehensive
Although Tanzania’s Total Tax Rate the VAT return. However, there is no implementation system focuses on
(44.3%) is broadly in line with the online payment system in place yet six priority areas of the economy
average for Africa (46.6%), this value and therefore the number of payments including (i) energy and natural gas (ii)
should be considered in the context of for VAT remains at 12 as measured agriculture (iii) water (iv) education
Africa having the second highest Total by Paying Taxes. At 49 the number (v) transport and (vi) mobilisation of
Tax Rate of any region and it is above the of payments is well above the global resources. When focussing on resource
overall world average of 40.9%. A more average of 25.9 and the African average mobilisation, the practical challenge
pertinent comparison in the context of of 36.2. will be to balance the need to ensure
the East African Community (EAC)’s sufficient public revenues and at the
moves towards a Common Market The year 2014 will be the first full same time incentivise investment and
to promote regional competitiveness calendar year of the operation of the economic growth. In addition, the
within the EAC. The concern here is that Tanzania Revenue Authority (TRA) Paying Taxes report makes clear that
Tanzania’s Total Tax Rate is much higher Revenue Gateway System launched in initiatives to streamline tax procedures
than Rwanda (33.5%), Uganda (36.5%) July 2013 to act as an interface between and reduce time spent on compliance
and Kenya (38.1%). A key differentiator the TRA, Bank of Tanzania, commercial can make an important difference –
with the other countries is the high level banks and other stakeholders such as particularly so for small and medium
of labour taxes charged. For example, mobile phone operators. The Gateway enterprises.
employers in Tanzania are subject is used for the following three types
not only to employer social security of payments: (i) Tanzania Inter-bank
contributions but also to a “skills and Settlement System (TISS) payments,
development” levy on payroll costs. (ii) other tax payments made through
The Paying Taxes 2014 report ranked Tanzania at 141st however this figure has now been restated to take account of certain methodology changes
65
Tanzania 114
United States
Efforts to reduce tax compliance burden
hampered by mounting complexity and
resource scarcity
Mark Mendola, PwC US
Figure 3.29
Trend in the Paying Taxes sub-indicators for United States
% / Number Hours
60 600
2013:
45.8%
50 500
Total Tax Rate
40 400
30 300 2013:
175
hours
Time to comply
20 200
10 100
2013:
11
0 0 Number of payments
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
115 Paying Taxes 2015. PwC perceptions on how tax systems are changing
In recent years, the government has
increased its focus on formal initiatives to
reduce the tax compliance burden.
The Internal Revenue Service (IRS) A primary challenge is that the Real-time information through
wants to make it easier for US complexity surrounding tax online resources
taxpayers to pay their proper federal compliance in the United States has Pre-filing tools aimed at educating and
tax liability and achieve greater tax been mounting for decades. Another helping taxpayers
compliance. In recent years, the hurdle is that US lawmakers have A core IRS focus has been so-called
government has increased its focus continued to reduce the agency’s ‘outreach and education’ initiatives so
on formal initiatives to reduce the budget and resources while at the as to enhance voluntary compliance
tax compliance burden. As a result, same time adding new requirements. and provide tools for taxpayers to file
the IRS has made successful strides The former is not necessarily the accurate returns. Striving to meet
streamlining and increasing the case with the actual process of taxpayers’ desire for service, the
efficiency of specific areas within its submitting a tax return, but rather IRS has offered a range of self and
compliance programme resulting in with what information is reported on electronic service technology options
benefits not only for taxpayers, but it. A telling statistic is that between on the IRS website (IRS.gov) since
for the IRS as well – a win-win for 2000 and 2010, the IRS was tasked its re-launch in 2012. Taxpayers are
both parties. with implementing over 4,000 tax utilising these tools and information –
code changes enacted by the US in 2013, taxpayers viewed IRS.gov web
One might assume that under the Congress. Sometimes contributing pages more than 450 million times.
Paying Taxes study, the time to comply to this complexity is the fact that the The following is a non-exhaustive
for the United States would show a US Treasury Department has added list of digital applications and
steady decline over the past several numerous sets of regulations and capabilities that aim to save time and
years due to these initiatives. However, other guidance that taxpayers must taxpayer effort:
this year’s survey shows this as understand and act on.
175 hours. While this is lower than the • IRS forms, once finalised, are
world average (264), the OECD average How the IRS is easing uploaded and immediately
(185), the G8 average (192), and the taxpayer burden available.
region average (213), it is the same The IRS has streamlined specific • calculators help taxpayers compute
as the previous two years and down compliance processes within various employer withholding obligations
only slightly from 187 hours for the stages of the tax compliance cycle – and alternative minimum tax.
four years before that. So why doesn’t pre-filing, filing, audits, and disputes. • tax identification numbers may be
the US’ ranking show improvement While the benefit of these initiatives applied for and obtained online.
over this period? Unfortunately, no depends on the specific taxpayer’s • the ‘IRS en Espanol’ Spanish-
one factor can explain this stagnation. circumstances, they generally help language website helps taxpayers
In fact, the IRS continues to face taxpayers reduce compliance burdens with limited English proficiency
numerous obstacles that are hampering by providing real-time information understand and meet their tax
these welcomed efforts for taxpayers. through online channels. These responsibilities.
initiatives have enabled greater • ‘Where’s My Refund?’ provides an
upfront certainty by facilitating early electronic tracking tool and was
communication with the IRS to reduce used 200.5 million times in 2013.
risk. Initiatives to leverage technology • ‘IRS Direct Pay’ was introduced in
for the filing of returns have had 2014 to provide taxpayers with a
a tremendous impact, while other secure and free way to make tax
efforts have led to more consistency payments.
with respect to audits and quicker • ‘Get Transcript’ allows taxpayers to
resolutions for disputes. The following view and print a record of their IRS
describes some of the agency’s more account in minutes.
significant endeavours.
117 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The IRS also has made tremendous
strides creating mobile phone
applications that help make tax
compliance more user-friendly.
Industry issue resolution (IIR) Additional focus on the limited issue Eliminating the coordinated issue case
The IRS more recently has emphasised focus examination (LIFE) programme (CIC) designation
the IIR programme to resolve The IRS has placed additional In an attempt to streamline the
frequently disputed or burdensome emphasis on the LIFE programme, examination process, the IRS is
tax issues affecting a significant which is a streamlined, focused considering eliminating the CIC
number of taxpayers within a specific examination process designed to limit designation and moving away from
industry. This resolution is shared the scope and reduce the cycle time of continuous audits towards an issue-
through the issuance of guidance such an audit in an effort to reduce resource focused approach. Under this new
as a regulation, revenue procedure, utilisation. In a LIFE examination, the approach, the IRS would rely largely
revenue ruling, or notice. Depending taxpayer and examiner work together on Schedule UTP (Uncertain Tax
upon the issue, the programme can on the most significant issues on the Position Statement), to identify issues
enable greater certainty of issues tax return. Initial issue selection is and allocate appropriate resources
before taxpayers prepare their returns. based on risk analysis and materiality to conduct targeted issue-specific
It also reduces the time and expense thresholds are applied to both the IRS audits. This risk-based approach may
associated with the resolution of issues expansion of the audit scope and the provide reduced audit times for those
on a taxpayer-by-taxpayer basis. taxpayer’s claims. Both parties must companies that have traditionally
sign a memorandum of understanding had to dedicate resources to address a
Greater consistency and reduced detailing the process, roles and continuous audit process.
timeframes for audits responsibilities, issues selected,
Changes to the quality exam process materiality thresholds, and timelines. Quicker resolution if a dispute arises
(QEP) Fast-track settlement (FTS) and the
Launched in 2010, QEP is a required New information document request rapid appeals programme (RAP)
systematic approach for engaging (IDR) issuance and enforcement process The IRS Office of Appeals (IRS
and involving taxpayers in the tax The IRS recently introduced a new IDR Appeals) has recently aimed to
examination process, from the earliest issuance and enforcement process to improve the efficiency of the appeals
planning stages through resolution of increase efficiency and transparency process by expanding the use of
all issues and completion of the case. during an audit. Specifically, the the FTS programme. FTS is a non-
It is intended to set the foundation for new process provides that all IDRs binding, voluntary negotiation process
improved communication between the issued after 30 June 2013 must be between a taxpayer and the IRS
IRS and taxpayers and supports greater issue focused and discussed with the to help taxpayers resolve disputed
consistency in the exam process. taxpayer in advance. In addition, both issues before a formal administrative
Based on recent comments from IRS the IRS and the taxpayer are required appeal. FTS may be initiated once an
executives, the agency will continue to to determine a reasonable timeframe issue has been fully developed in the
revamp QEP to make audits more issue for the taxpayer’s response. This examination process and is intended
focused. upfront communication can result in to be completed in approximately
reduced taxpayer burden by narrowing 120 days – a much faster timeframe
and refining the precise information than the multi-year process of a
that the IRS is requiring, avoiding traditional appeal.
unnecessary work. However, this
burden reduction will likely depend IRS Appeals has also attempted to
upon the taxpayer’s relationship improve the efficiency of the appeals
with the IRS audit team and negative process by expanding the use of the
consequences can occur if the taxpayer RAP programme. RAP is a relatively
does not respond within the agreed new voluntary procedure intended
upon timeframe (e.g., delinquency to improve the efficiency and
notices, pre-summons letters, or even timeliness of IRS Appeals resolutions.
a summons.) In RAP, the pre-conference meeting
is used as a means of resolving
issues using the techniques of the
FTS process. If agreement is not
reached, the traditional IRS Appeals
process continues.
119 Paying Taxes 2015. PwC perceptions on how tax systems are changing
The road ahead The IRS may also consider adopting Budget constraints and rising
Continued vigilance to reduce a more ‘plain English’ approach with complexity loom
compliance burdens respect to all guidance and regulatory Prioritising resources means
Keeping up with taxpayer’s appetite for projects. While many IRS publications slower progress
online services and form instructions strive to IRS budget constraints over the
The IRS has set forth plans to reduce describe technical tax requirements past three years unfortunately may
tax compliance burden by pursuing in simple terms, not all guidance is have lasting impacts on the agency’s
a number of core initiatives such as developed with this mindset. Even efforts to pursue positive change to
the expansion of electronic filing sophisticated taxpayers with seasoned tax compliance processes. Unfunded
and the acceleration of the receipt tax departments must closely analyse mandates are also taking priority
of information returns to improve IRS guidance, taking significant as resources are being shifted to
document matching and validation of time and resources to build expertise implement two major pieces of US
return accuracy. But a significant area and understanding. This time could legislation: The Affordable Care Act
of focus has been and will continue to be minimised by issuing easier-to- and the so-called Foreign Account Tax
be the expansion of online resources understand guidance, which may Compliance Act (FATCA) regime. The
and self-service tools. A primary driver take more upfront effort to craft, but result is that resource constraints are
has been taxpayers’ appetite for self- could ease taxpayer burdens for years likely to hamper various initiatives
service and electronic service options. to come. relating to the pre-filing, filing,
While the IRS has made great strides audit, and dispute stages of the tax
in this area, the strong demand by Expanding options for tax resolution compliance life cycle, even those that
the global tax community for tools to Controversies and disputes between are ready for implementation. Basic
ease compliance burdens is mounting the IRS and taxpayers require communication between taxpayers
at a rapid pace. Many agree that the significant time and resources to and the IRS also will likely suffer. Only
IRS still has a way to go to reach their achieve resolution. And the non-filing about 74% of taxpayers who called
vision of an interactive, fully integrated of tax returns and non-payment of tax the IRS during this past filing season
online tax administration agency. due continues to be a challenge for the got through to IRS personnel and the
agency. Not surprisingly, the IRS wants agency has noted that it is concerned
Driving a ‘simplification’ mindset to expand the options available for tax that the average level of phone service
Outside of efforts relating to online resolution, including new alternative may drop below 70%.
resources, there are a host of other dispute resolution programmes,
endeavours that could reduce streamlined payment agreements, Is it time for a revamp?
taxpayer burden. For example, cutting and fresh start collection and While the IRS seeks creative ways
the amount of information that a payment processes. These are aimed to reduce compliance burdens, the
taxpayer must report to the IRS is at providing various opportunities underlying complexity of the US
a fundamental way of reducing the for taxpayers to become compliant tax rules keeps growing. Taxpayers
burden. Accordingly, the IRS may want and easing their burden for doing so. will benefit from IRS efforts to ease
to consider amplifying its efforts to But these compliance initiatives are their burdens, but they must face
simplify reporting for more taxpayers. only the tip of the iceberg and there the continuing need to analyse, plan
As an example, similar to efforts made are many other avenues that could for, and comply with the US federal
with respect to individual income tax enhance opportunities for taxpayers to tax rules and regulations – an often
returns (Form 1040), a streamlined get back on the compliance track. daunting task requiring increasingly
Form 1120 for mid-sized corporations specialised resources and expertise.
could be very effective for reducing Many in the US government and other
the compliance burden of smaller stakeholders are calling for tax reform
businesses. in the United States, which could entail
not only a potential rate change, but
also the simplification of the rules for
both companies and individuals.
Methodology and
example calculations for
each of the Paying Taxes
sub-indicators, including
methodology changes for
the current year
Table A1.1
USA, New York City: Number of payments
Tax type World bank indicator Actual payments Notes
NY City and State property tax 1 1
NY State unemployment tax 1 4 online filing
Federal unemployment tax 1 4 online filing
Federal old-age, survivors and disability insurance tax – employer 1 12 online filing
Hospital insurance contributions – employer 0 12 paid jointly
NY City real estate transfer tax 1 1
NY City corporation tax 1 4 online filing
NY State corporation tax 0 4 paid jointly
Federal corporate income tax 1 4 online filing
NY City and State sales and use tax of lease truck 1 1
Metropolitan commuter transportation mobility tax (MCTMT) 1 1 online filing
Fuel tax 1 1*
Sales tax 1 12 online filing
Federal old-age, survivors and disability insurance tax – employee 0 12 paid jointly
Hospital insurance contributions – employee 0 12 paid jointly
Total 11 85
Table A1.2
Panama: Time to comply
Corporate Labour Consumption
income tax taxes tax Total
Compliance process
Preparation
Data gathering from internal sources (for example accounting records) if held 36 24 48
Additional analysis of accounting information to highlight tax sensitive items 16 24 56
Actual calculation of tax liability including data inputting into software/ 24 36 24
spreadsheets or hard copy records
Time spent maintaining/updating accounting systems for changes in 0 12 2
tax rates and rules
Preparation and maintenance of mandatory tax records if required 0 0 12
Total 76 96 142 314
Filing
Completion of tax return forms 4 18 12
Time spent submitting forms to tax authority, which may include time for 1 6 12
electronic filing, waiting time at tax authority office etc
Total 5 24 24 53
Payment
Calculations of tax payments required including if necessary extraction of data 0 0 0
from accounting records
Analysis of forecast data and 1 12 12
ssociated calculations if advance payments are required
Time to make the necessary tax payments, either online or at the tax authority 1 12 12
office (include time for waiting in line and travel if necessary)
Total 2 24 24 50
Grand total 83 144 190 417
Table A1.3
France: Total Tax Rate
EUR '000 EUR '000
Profit before tax (PBT) 762, 365
66
www.pwc.com/totaltaxcontribution
Changes made to the Where an economy levies taxes which It should also be noted that for some
methodology in Paying are calculated by simply applying a economies updating the GNIpc to the
Taxes 2015 tax rate to turnover, profits, salary or 2012 value is not sufficient to bring the
The base for the financial statements some other element that is a multiple salaries of all the case study employees
and GNIpc of GNIpc, its Total Tax Rate should not up to the minimum wage thresholds
The case study company’s financial be affected by the change in the GNIpc that exist in those economies. In those
statements are based upon the gross value used (assuming no reforms instances an additional multiple of
national income per capita (GNIpc) have been implemented). However, two or three times the GNIpc has
in each economy. Turnover, for where an economy imposes fixed been used.67
example, is assumed to be 1,050 tax liabilities, where thresholds are
times GNIpc giving after deducting applied to the taxable bases or where The impact on the compliance sub-
various expenses a commercial profit the change in the GNIpc results in the indicators is expected to be small
of 59.4 times GNIpc. Previously and company being subject to different and only seems to be evident in the
throughout the study from 2004 to tax rules (for example because of the payments sub-indicator where the
2012 the GNIpc value for 2005 has change in the size of the company), change in the size of the case study
been used to ensure consistency and the Total Tax Rate will be affected. company has meant that it would have
comparability. For Paying Taxes 2015, Essentially where taxes are charged to make payments with a different
however, (for the calendar year 2013 as a fixed amount then these will frequency – e.g., a large company
and restated figures for calendar year become smaller in relation to the many have to make four payments of
2012) and subsequent studies this overall taxes calculated (unless the corporate income tax a year whereas a
figure has been updated to the 2012 fixed amount has been increased) and small or medium sized company would
value in each economy; the intention is the Total Tax Rate for the economy only need make one payment.
that the case study company will now will fall as a consequence. A secondary
be more in line with the present size of effect will be evident where the fixed
its domestic economy. levy is deductible for other taxes
that the company has to bear. If the
The impact of this change on the fixed charge is unchanged then the
Paying Taxes sub-indicators is expected deductible amount will become smaller
to be limited. and the other taxes will increase as a
consequence. Examples of the effect
of the change in GNIpc are provided
in “Explaining the changes in Total Tax
Rate” on page 43.
The economies for which a multiple of three times GNIpc has been used are: Honduras, Mozambique, West Bank and Gaza, Zimbabwe. The economies
67
for which a multiple of two times GNIpc has been used are: Belize, Benin, Bosnia and Herzegovina, Burkina Faso, Central African Republic, Chad, Fiji,
Guatemala, Haiti, Kenya, Lesotho, Madagascar, Micronesia, Fed. Sts., Morocco, Nepal, Nicaragua, Niger, Nigeria, Philippines, Solomon Islands, South Africa,
South Sudan, Tanzania, Togo, Vanuatu, Zambia
Table A1.4
Economy Cities
Bangladesh Dhaka, Chittagong
Brazil Sao Paulo, Rio de Janeiro
China Shanghai, Beijing
India Mumbai, Delhi
Indonesia Jakarta, Surabaya
Japan Tokyo, Osaka
Mexico Mexico City, Monterrey
Nigeria Lagos, Kano
Pakistan Karachi, Lahore
Russian Federation Moscow, St. Petersburg
USA New York City, Los Angeles
Where the second and third largest cities were very close in population size, the GDP of the city or relevant state was used to determine which city was the
68
Table A1.5
Economy Population Weight Total Tax Time to Number of Distance to
Rate (%) comply (hours) payments frontier
Bangladesh Dhaka 14,730,537 78% 32.5 302 21.0 74.0
Bangladesh Chittagong 4,106,060 22% 32.5 302 21.0 74.0
Bangladesh - - 32.5 302 21.1 74.0
Brazil Sao Paulo 19,659,808 61% 68.9 2600 9.0 41.4
Brazil Rio de Janeiro 12,373,884 39% 69.2 2600 9.0 41.2
Brazil - - 69.0 2600 9.0 41.3
China Shanghai 19,979,977 55% 64.5 261 7.0 67.5
China Beijing 16,189,572 45% 64.6 261 7.0 67.4
China - - 64.6 261 7.0 67.4
India Mumbai 19,421,983 47% 61.7 243 33.0 55.5
India Delhi 21,935,142 53% 61.7 243 33.0 55.5
India - - 61.7 243 33.0 55.5
Indonesia Jakarta 9,629,953 78% 31.4 254 65.0 53.7
Indonesia Surabaya 2,768,199 22% 31.4 254 65.0 53.7
Indonesia - - 31.4 254 65.0 53.7
Japan Tokyo 36,833,979 65% 51.2 330 14.0 67.2
Japan Osaka 19,491,722 35% 51.4 330 14.0 67.1
Japan - - 51.3 330 14.0 67.2
Mexico Mexico City 20,131,688 83% 51.7 334 6.0 71.2
Mexico Monterrey 4,112,643 17% 52.1 334 6.0 71.0
Mexico - - 51.8 334 6.0 71.2
Nigeria Lagos 10,780,986 77% 32.7 956 47.0 39.1
Nigeria Kano 3,220,929 23% 32.7 747 47.0 39.1
Nigeria - - 32.7 908 47.0 39.1
Pakinstan Karachi 14,080,737 65% 32.5 594 47.0 44.5
Pakistan Lahore 7,487,415 35% 32.8 594 47.0 44.4
Pakistan - - 32.6 594 47.0 44.5
Russian Federation Moscow 11,461,264 70% 49.0 168 7.0 80.6
Russian Federation Saint Petersburg 4,871,556 30% 48.7 168 7.0 80.7
Russian Federation - - 48.9 168 7.0 80.6
United States New York 18,365,262 60% 45.8 175 11.0 79.7
United States Los Angeles 12,160,151 40% 40.9 175 10.0 82.6
United States - - 43.8 175 10.6 80.8
Source: United Nations, Department of Economic and Social Affairs, Population Division, World Urbanization Prospects, 2014 Revision, “File 12: Population
of Urban Agglomerations with 300,000 Inhabitants or More in 2014, by Country, 1950-2030 (thousands).” Available at http://esa.un.org/unpd/wup/CD-ROM/
Default.aspx.
Distance to frontier
100
80
B
A
60
40
D
Distance to frontier
20 for Total Tax Rate –
linear
Distance to frontier
for Total Tax Rate –
non-linear
0
0 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Total Tax Rate
Note: The non-linear distance to frontier for the Total Tax Rate is equal to the distance to frontier for the Total Tax Rate to the power of 0.8.
Source: Doing Business database.
DTF for the time to comply and the DTF for the Total Tax Rate (TTR) is The overall Paying Taxes DTF will
number of payments is computed as: computed as: then take the form;
100 * (max – y) / (max – min) TTR DTF = 100 * [(max – y) / Paying TaxesDTF = 1/3 [TTR DTF +
(max – min)] 0.8 Time DTF + Payments DTF]
Where y := sub-indicator value for TTR above the 15th percentile.
for a given economy
For a TTR value below the 15th
percentile, TTR DTF is set at 100.
Economy sub-indicator
results by region
Seychelles 40 36 12 88
Comoros 4 48 48 100
Rwanda 20 36 51 107
Swaziland 8 48 54 110
Tunisia 64 30 50 144
Liberia 60 60 31 151
Botswana 40 40 72 152
Mauritius 36 48 68 152
Malawi 67 78 30 175
Zambia 60 60 57 177
Sudan 70 70 40 180
Tanzania 62 54 65 181
Eritrea 24 96 96 216
Ghana 40 88 96 224
Zimbabwe 78 96 68 242
South Africa 1 2 4 7
Mauritius 11 6 8
Tunisia 1 4 3 8
Rwanda 4 4 9 17
Libya 4 12 3 19
Madagascar 1 8 14 23
Burundi 6 4 15 25
Gabon 3 4 19 26
Namibia 3 12 11 26
Algeria 12 15 27
Seychelles 12 12 4 28
Angola 4 12 14 30
Cabo Verde 3 13 14 30
Eritrea 2 12 16 30
Ethiopia 2 12 16 30
Kenya 5 14 11 30
Uganda 3 12 16 31
Ghana 6 12 14 32
Lesotho 4 12 16 32
Comoros 3 12 18 33
Liberia 5 12 16 33
Sierra Leone 5 12 16 33
Swaziland 2 13 18 33
Botswana 6 13 15 34
Djibouti 5 12 18 35
Mali 4 24 7 35
Malawi 5 13 17 35
South Sudan 5 12 19 36
Mozambique 7 12 18 37
Zambia 5 13 19 37
Niger 3 14 24 41
Sudan 2 12 28 42
Cameroon 13 12 19 44
Burkina Faso 1 24 20 45
Guinea-Bissau 5 12 29 46
Equatorial Guinea 1 24 21 46
Nigeria 2 26 19 47
Congo, Rep. 5 24 20 49
Mauritania 1 25 23 49
Tanzania 5 24 20 49
Zimbabwe 5 14 30 49
Gambia, The 5 13 32 50
Togo 5 24 21 50
Chad 12 24 18 54
Benin 5 24 26 55
Guinea 3 36 18 57
Senegal 3 36 19 58
Côte d'Ivoire 3 24 36 63
Solomon Islands 8 30 42 80
Singapore 32 10 40 82
Brunei Darussalam 66 27 93
Australia 37 18 50 105
Kiribati 48 72 120
Vanuatu 24 96 120
Malaysia 26 77 30 133
Palau 46 96 142
Mongolia 46 48 54 148
Myanmar 32 25 98 155
Cambodia 23 84 66 173
Fiji 57 68 70 195
Samoa 48 96 80 224
Indonesia 75 89 90 254
Singapore 11 3 5
China 2 1 4 7
Kiribati 5 2 7
New Zealand 1 2 5 8
Korea, Rep. 1 2 7 10
Australia 1 4 6 11
Palau 4 4 3 11
Taiwan, China 2 3 6 11
Malaysia 2 2 9 13
Japan 3 2 9 14
Timor-Leste 5 12 1 18
Bhutan 2 13 4 19
Afghanistan 1 12 7 20
Bangladesh 5 16 21
Marshall Islands 16 5 21
Thailand 2 13 7 22
Brunei Darussalam 1 24 2 27
Tonga 1 12 16 29
Maldives 3 12 15 30
Myanmar 5 12 14 31
Vanuatu 12 19 31
Vietnam 6 12 14 32
India 2 24 7 33
Nepal 4 12 18 34
Solomon Islands 5 12 17 34
Lao PDR 4 12 19 35
Philippines 1 25 10 36
Samoa 5 24 8 37
Fiji 5 18 15 38
Cambodia 12 12 16 40
Mongolia 12 12 17 41
Pakistan 5 25 17 47
Sri Lanka 5 13 29 47
Indonesia 13 36 16 65
Dominica 15 48 54 117
Grenada 32 72 36 140
Belize 27 60 60 147
Haiti 40 72 72 184
Nicaragua 67 76 64 207
Honduras 35 93 96 224
Dominican Republic 1 4 4 9
Puerto Rico 5 6 5 16
Bahamas, The 12 6 18
Costa Rica 4 2 17 23
Barbados 3 12 12 27
Belize 12 1 16 29
Grenada 1 12 17 30
St. Lucia 1 12 19 32
Jamaica 4 12 20 36
Dominica 5 12 20 37
Nicaragua 1 24 18 43
Haiti 6 25 16 47
Honduras 5 13 30 48
Panama 5 16 31 52
El Salvador 13 24 16 53
Ukraine 11 3 5
Kazakhstan 11 4 6
Azerbaijan 11 5 7
Belarus 1 2 4 7
Macedonia, FYR 11 5 7
Russian Federation 1 2 4 7
Armenia 11 8 10
Turkey 11 9 11
Moldova 1 14 6 21
Montenegro 1 12 16 29
Tajikistan 3 7 21 31
Israel 2 12 19 33
Kosovo 5 12 16 33
Uzbekistan 8 12 13 33
Albania 5 12 17 34
Kyrgyz Republic 5 12 35 52
Serbia 12 12 43 67
Sweden 1 1 4 6
Estonia 1 6 7
Latvia 1 1 5 7
Malta 1 1 5 7
Czech Republic 1 2 5 8
Finland 1 3 4 8
France 1 2 5 8
Greece 1 1 6 8
Portugal 1 1 6 8
Spain 1 1 6 8
United Kingdom 1 1 6 8
Germany 2 1 6 9
Ireland 1 1 7 9
Netherlands 1 1 7 9
Denmark 3 1 6 10
Belgium 1 2 8 11
Hungary 2 2 7 11
Lithuania 1 2 8 11
Slovenia 1 1 9 11
Austria 1 3 8 12
Bulgaria 1 1 11 13
Romania 1 1 12 14
Italy 2 1 12 15
Poland 1 1 16 18
Croatia 1 1 17 19
San Marino 3 12 4 19
Switzerland 2 7 10 19
Slovak Republic 1 1 18 20
Luxembourg 5 12 6 23
Iceland 1 13 12 26
Cyprus 4 12 13 29
Qatar 1 1 2 4
Kuwait 12 12
Bahrain 12 1 13
Iraq 1 12 13
Oman 1 12 1 14
Lebanon 1 12 6 19
Jordan 1 12 12 25
Yemen, Rep. 1 24 19 44
Canada 1 3 4 8
United States 2 4 5 11
Ecuador 2 1 5 8
Argentina 11 7 9
Brazil 2 2 5 9
Peru 1 2 6 9
Colombia 2 1 8 11
Paraguay 1 12 7 20
Suriname 5 12 13 30
Uruguay 1 24 8 33
Guyana 6 12 17 35
Bolivia 1 12 29 42
Venezuela, RB 15 28 28 71