IMF-利用反洗钱措施提高税收合规性并帮助调动国内收入（英）-2023.4-51页_731kb

Leveraging Anti-Money Laundering (AML) measures offers significant potential to improve tax compliance, tackle tax crimes, and help mobilize domestic revenues, especially in the context of economic strain from the COVID-19 pandemic and other global challenges. The paper argues that while AML frameworks already exist, their benefits for tax compliance are not fully realized. Money laundering and tax crimes are intrinsically linked—often sharing objectives, techniques, and even criminal actors. Tax crimes, classified as predicate offenses to money laundering under international standards like the FATF Recommendations, provide opportunities for synergistic legal and operational cooperation.

The integration of AML measures into tax compliance strategies entails formalizing the economy and enhancing transparency through Customer Due Diligence (CDD), beneficial ownership registries, and country-wide bank account registries. Sharing financial intelligence, such as through Suspicious Transaction Reports (STRs), facilitates tax evasion detection and targeted audits. Enforcement can be bolstered by leveraging AML investigative powers, including freezing and seizing illicit assets, extended liability for intermediaries, and international cooperation for asset recovery. The deterrence effect of AML frameworks, with heightened transparency and severe sanctions (including imprisonment), further discourages tax crimes.

Several challenges hinder the effective leveraging of AML for tax purposes. These include political resistance from jurisdictions reliant on opaque financial systems, legal barriers such as differing national definitions of "tax crimes," and operational hurdles like inadequate capacity and weak inter-agency cooperation. Proposed solutions involve strengthening international standards (e.g., harmonizing definitions), peer review mechanisms like FATF mutual evaluations, robust civil society engagement, digital tools for intelligence sharing, and technical assistance to build capacity.

To harness these synergies, countries should formally designate tax crimes as predicate offenses, ensure systematic cooperation between AML and tax authorities (e.g., via Memoranda of Understanding), and integrate AML measures into broader fiscal reforms. The global economic context underscores the urgency to address revenue shortfalls by enhancing tax integrity through AML leverage, which avoids redundancies across frameworks while fostering systemic financial stability.