2018年-IMF国际货币组织全球_Republic_of_Poland_Technical_Assistance_Report_46页_1mb

Summary of the Revenue Administration Gap Analysis Program—The Value-Added Tax Gap in Poland

Core Content

This report, prepared by the International Monetary Fund (IMF), presents the results of applying the RA-GAP methodology to estimate the Value-Added Tax (VAT) gap in Poland from 2010 to 2016. The RA-GAP program is a comprehensive tool used to assess the gap between potential and actual tax revenues, focusing on the VAT system. It breaks down the VAT gap into two main components: the compliance gap and the policy gap, and further into the assessment gap, collection gap, expenditure gap, and non-taxable gap.

The analysis is based on national accounts data and aims to evaluate the efficiency of the VAT system in Poland, comparing it with other European countries. The report also highlights the importance of using the RA-GAP model for fiscal monitoring and tax gap analysis, and suggests areas for improvement in tax administration and policy design.

Main Findings

• VAT Revenue Performance:

  • Nominal VAT revenues increased from 2008 to 2017, but real revenues declined from 2008 to 2015 before recovering in 2017.
  • As a percentage of GDP, VAT revenues fell from 7.9% in 2008 to 7.0% in 2015, then rose to 7.8% in 2017.
  • Domestic VAT collections increased from 80% to 95% of total VAT collections between 2010 and 2016.
  • Import VAT decreased from 1.6% to 0.4% of GDP due to changes in the VAT Act in 2015.

• Compliance Gap:

  • The compliance gap averaged around 20% of potential VAT between 2010 and 2016, peaking at 27% in 2013.
  • In terms of GDP, the compliance gap ranged from 1.8% to 2.6%.
  • The compliance gap is largely concentrated in the trade and transport sectors and professional and other services sectors.
  • The assessment gap (unidentified liabilities) is the largest contributor to the compliance gap, while the collection gap (identified liabilities) is smaller and often slightly negative due to missing data.

• Policy Gap:

  • The policy gap remained stable between 8.1% and 8.4% of GDP during 2010–2016.
  • It is influenced by changes in the tax base composition and policy structure, such as the shift in final consumption from standard-rated items to exempt or reduced-rate items.
  • The policy gap is composed of the expenditure gap (tax expenditure decisions) and the non-taxable gap (exemptions and reduced rates).
  • The expenditure gap increased slightly from 2.7% to 2.9% of GDP, while the non-taxable gap decreased from 5.4% to 5.3% of GDP.

• Overall VAT Gap:

  • The total VAT gap increased from 10.1% to 11% of GDP between 2010 and 2013, then declined back to 10% in 2016.
  • The overall VAT gap is composed of the compliance gap and the policy gap.
  • The non-taxable gap is the largest component of the overall VAT gap, but does not represent potential revenue mobilization.
  • The expenditure gap and assessment gap do represent potential for revenue mobilization.

• C-Efficiency Ratio:

  • The c-efficiency ratio for Poland was below the European average throughout 2008–2016, ranging from 38% in 2013 to 42% in 2017.
  • The European average c-efficiency was around 55%.
  • The c-efficiency ratio is closely related to the VAT gap, with (1 - VAT gap) being very close to the observed c-efficiency.
  • Most changes in c-efficiency are due to changes in the compliance gap, particularly the expenditure gap.

Key Recommendations

• Continue to estimate the VAT compliance gap as part of fiscal monitoring, including periodic updates to the RA-GAP model.
• Use VAT gap estimates to evaluate tax morale and progress in closing the VAT gap.
• Broaden the scope of tax gap analysis to include other taxes.
• Use tax gap analysis as a foundation for strategic compliance risk management.
• Investigate the causes of the compliance gap in the utilities sector.
• Consider measures to tackle compliance risks in professional and personal services.
• Strengthen cooperation with the Central Statistical Office.
• Develop a national database of individual VAT transactions using the Standard Audit File (SAF) initiative for a more systematic approach to risk analysis.

Key Terms Glossary

• EC: European Commission
• EU: European Union
• GDP: Gross Domestic Product
• IMF: International Monetary Fund
• KAS: National Fiscal Administration
• MoF: Ministry of Finance
• PLN: Polish złoty (currency)
• RA-GAP: Revenue Administration Gap Analysis Program
• SAF: Standard Audit File
• TAXUD: Taxation and Customs Union Directorate-General (EC)
• VAT: Value-Added Tax

Figures Overview

• Figure 1: VAT Revenues (2008–17)
• Figure 2: VAT Compliance Gap (2010–16)
• Figure 3: VAT Gap, Compliance Gap, and Policy Gap (2010–16)
• Figure 4: Compliance Gap by Sector (2010–16)
• Figure 5: Compliance Gap Estimates (2010–16)
• Figure 6: VAT Revenues (2008–17)
• Figure 7: Breakdown of Net VAT Revenues (2010–16)
• Figure 8: C-Efficiency for Poland Compared to Average for European Countries (2008–16)
• Figure 9: Average C-Efficiency for Europe over the Period (2008–16)
• Figure 10: VAT Compliance Gap (2010–16)
• Figure 11: Assessment and Collection Gap (2010–16)
• Figure 12: Policy Gap and Compliance Gap (2010–16)
• Figure 13: Expenditure and Non-Taxable Gap (2010–16)
• Figure 14: VAT Gap, Compliance Gap, and Policy Gap (2010–16)
• Figure 15: Actual VAT and Components of the Tax Gap (2010–16)
• Figure 16: (1 - VAT Gap) versus the C-Efficiency Ratio (2010–16)
• Figure 17: Impact of the Tax Gap Components on C-Efficiency (2010–16)
• Figure 18: Measures of VAT Collections (2010–16)
• Figure 19: Illustrative RA-GAP Accrual Measurement and Official Values for VAT Collections

Conclusion

The RA-GAP methodology provides a robust framework for analyzing the VAT gap in Poland. It reveals that the compliance gap is the main driver of changes in VAT performance, with the trade and transport sectors being the most affected. The policy gap remains relatively stable, mainly due to the structure of VAT exemptions and reduced rates. The report emphasizes the need for improved tax administration, data accuracy, and strategic risk management to enhance revenue collection and reduce the VAT gap.