2011年-IMF国际货币组织全球_El_Salvador_Report_on_Observance_of_Standards_and_Codes_Fiscal_Transparency_Module_41页_670kb

Summary of the IMF Report on Observance of Standards and Codes (ROSC) - Fiscal Transparency Module for El Salvador (June 9, 2011)

Core Content

This report evaluates El Salvador's fiscal transparency practices in relation to the IMF Code of Good Practices on Fiscal Transparency, based on discussions with the authorities, responses to the fiscal transparency questionnaire, and other relevant sources. It outlines both the strengths and areas for improvement in the country's fiscal management framework.

Main Points and Findings

1. Fiscal Transparency Practices Meet Many Standards

• Government Structure and Budget Process: The central government structure and functions are clearly defined, and its relationship with local governments is specified.
• Budget Calendar: The budget calendar is well-defined and observed.
• Legislative Involvement: The Legislative Assembly has sufficient time to review the draft budget.
• Tax Laws and Procedures: Tax laws and regulations are clear and comprehensible. Appeals are considered in a timely manner.
• Revenue and Expenditure Reporting: The annual budget provides a separate indication of all revenue sources, including external assistance.
• Final Accounts Coverage: Final accounts cover all central government budgetary and extrabudgetary activities.
• Accounting Standards: The final budget accounts indicate the accounting method used and largely apply accepted standards.
• Fiscal Transparency Portal: The Finance Ministry has recently incorporated the Fiscal Transparency Portal (PTF), improving monthly fiscal data dissemination.

2. Areas for Improvement

• Clarification of Government-Corporate Relationships: The relationship between the government and public nonfinancial corporations is unclear. Some entities, such as ANDA (National Drinking Water and Sewer Administration), engage in quasi-fiscal activities but are not fully integrated into the central government budget.
• Midterm Budget Reports: Midterm budget outturn reports are not submitted to the Legislative Assembly.
• Municipal Inclusion in Budget Documentation: Information on municipal governments is not adequately incorporated into the budget documentation.
• Medium-Term Expenditure Framework: Budget preparation in a medium-term expenditure framework needs improvement.
• Comparative Figures: Budget documentation lacks comparative figures for the three preceding years.
• Aggregate Expenditure Estimates: There is no provision for three or five-year aggregate expenditure estimates.
• Fiscal Risk Information: Information on fiscal risks, including contingent liabilities, tax expenditures, and public debt sustainability analysis, is insufficient.
• Quasi-Fiscal Transparency: Transparency in quasi-fiscal activities requires enhancement.

3. Government Structure and Roles

• General Government: Composed of the central government (including 13 ministries, the president’s office, judiciary, and legislature), 58 subsidized institutions, 11 non-subsidized institutions, and 262 municipal governments.
• Public Corporations: Four public nonfinancial enterprises are included in the General State Budget (PGE), while four limited companies and three banks are not. These entities are not reflected in the PGE, leading to unclear relationships with the government.
• Central Government and BCR: The Banco Central de Reserva (BCR) is partially independent and does not carry out significant fiscal functions. It is governed by a board of directors with the President of the Republic as chair. The BCR provides financial support to the government and public institutions, but not all services are remunerated.
• Public Financial Management: The Organic Law on State Financial Administration (AFI Law) and its regulation establish the Integrated Financial Management System (SAFI), which covers budget, credit, investment, and accounting functions. The system is centralized in terms of regulation but decentralized in operations.

4. Taxation and Revenue Management

• Tax Reforms: Tax reforms in 2000 and 2004 simplified the legal framework for tax revenue, reducing the number of taxes and the level of discretion.
• Tax Code: The Tax Code (CT) clearly defines taxpayers’ obligations and rights, as well as the roles of DGII (Domestic Taxes), DGT (Treasury), and DGA (Customs).
• Tax Incentives: Tax incentives are granted through specific laws, such as the Export Reactivation Law, Industrial Free Trade Areas Law, and Marketing of International Services Law, but information on tax expenditures is not publicly disclosed.
• Tax Administration: The tax administration is fragmented, with DGII and DGT handling domestic tax functions, and DGA handling customs. The system of appeals and coercive collection is not fully integrated into these institutions, leading to potential inefficiencies and delays in tax compliance.

5. Public Participation and Communication

• Public Consultation: Public opinion is not sufficiently consulted in the development of new laws or policy amendments.
• Open Budget Report: The Open Budget Report recommends public involvement in legislative budget hearings.
• Fiscal Transparency Portal: The launch of the PTF aims to improve communication with civil society and reflect public opinion more effectively.

Key Institutions and Frameworks

• SAFI (Integrated Financial Management System): Composed of subsystems for budget, credit, investment, and accounting. Centralized in regulation, decentralized in operations.
• DGII, DGT, DGA: Key institutions responsible for domestic tax, treasury, and customs management, respectively.
• TAIIA (Tax Appeals Court): Handles first and second-level appeals related to tax liabilities.
• CCR (National Audit Office): Oversees public accountability and financial reporting.

Conclusion

El Salvador demonstrates a solid foundation in fiscal transparency, particularly in budget preparation, tax law clarity, and information dissemination. However, there are notable gaps in the clarity of government-corporate relationships, the inclusion of municipal budgets, and the provision of fiscal risk information. The Fiscal Transparency Portal (PTF) is a positive development, but further improvements are needed to fully align with the IMF Code of Good Practices on Fiscal Transparency. The report highlights the importance of enhancing transparency in quasi-fiscal activities and fostering a more competitive economic environment for the private sector.