2023-11-09-IMF-采掘业的增值税_49页_1mb

Value Added Tax in the Extractive Industries
Artur Swistak and Nate Vernon
IMF Working Paper WP/23/221

Key Points

1. Introduction

   • VAT is a consumption-based tax but is often administratively challenged in extractive industries (EIs), especially in low-capacity countries.
   • EIs (mining, petroleum) are capital-intensive, export-heavy, and reliant on imports, making VAT refund delays costly.

2. Challenges in VAT Recovery

   • Deferred VAT Registration: Delays registration during pre-production hinder VAT recovery.
   • Indefinite Carry of Excess Credits: Refunds for large pre-production VAT credits are rare, discouraging investment.
   • Delayed VAT Refunds: Refund delays lead to cash flow issues and bias against EIs and domestic suppliers.

3. Common VAT Schemes

   • Exemptions/Zero-Rating: Applied to imports (reducing investor VAT) but create bias against domestic suppliers.
   • Partial Deeming: Withholding a portion of input VAT (e.g., 50%) balances investor burden and supplier recovery.
   • Administrative Solutions: Interest on unrefunded VAT and tax offsets can mitigate delays but introduce complexity.

4. Evaluation of VAT Schemes

   • Standard VAT with Immediate Refunds: Optimal but often unattainable.
   • Exempting Imports/W-tax Domestic Supplies: Reduces investor burden but harms domestic suppliers.
   • Partial Deeming: Equitable solution, especially with high withholding rates.

5. Composite Index for Stakeholder Balance

   • Optimal policies depend on stakeholder priorities:
     • Investors: Prefer no-VAT zones or exemptions.
     • Domestic Suppliers: Favor standard VAT or tax offsets.
     • Tax Authorities: Prefer cost-recovery schemes for simplicity.

6. Conclusions

   • The first-best policy is a standard VAT with timely refunds.
   • When delays persist, second-best policies like exemptions or partial deeming balance distortions.
   • Tailoring solutions to country-specific capacities (e.g., high-capacity: no-VAT zones; low-capacity: domestic exemptions) is crucial.

Summary: The IMF recommends adopting standard VAT systems with timely refunds to maintain neutrality for EIs and suppliers. In practice, exemptions (especially for imports) or partial deeming balances distortions while addressing refund challenges. Countries should combine administrative reforms (e.g., interest on delayed refunds) with targeted exemptions to maximize revenue and minimize economic disruptions.