2024-06-02-世界银行-发展中国家的离岸数据泄露和税收执法（英）_36页_1mb

Summary of "Offshore Data Leaks and Tax Enforcement in Developing Countries"

Core Content

This report explores the use of offshore data leaks, particularly from the ICIJ Offshore Leaks Database (OLD), to enhance tax enforcement in developing countries. It provides a practical guide for tax authorities to clean and match ICIJ data with their administrative taxpayer records, enabling better understanding and targeting of offshore tax evasion.

The study focuses on three countries: Honduras, Ecuador, and Senegal, where the authors have engaged with national tax administrations. The data is used to analyze the distribution of offshore company ownership and the prevalence of offshore tax evasion among high-income individuals.

Main Points

1. Scale and Nature of Offshore Evasion

• Offshore tax evasion is a significant issue in low- and middle-income countries, often involving shell companies and hidden ownership structures.
• Globally, offshore financial wealth is estimated at $12 trillion, equivalent to 12% of world GDP.
• Individuals at the top of the income and wealth distribution are more likely to use offshore structures to evade taxes.

2. Policy Efforts to Reduce Offshore Evasion

• Two major policy tools are used to combat offshore evasion:
  • Voluntary Disclosure Schemes (VDS): These allow taxpayers to report offshore assets without facing penalties.
  • Information Exchange Treaties: These enable tax authorities to share data on offshore assets, either on request or automatically.
• The Common Reporting Standard (CRS), established by the OECD, has led to a reduction in offshore deposits in participating countries, though some tax evaders have moved to non-cooperating jurisdictions.

3. Data and Methodology

• The ICIJ OLD contains five major leaks from 2013 to 2021, including the Panama Papers, Pandora Papers, and Paradise Papers.
• The authors followed a three-step process to clean and assign the data:
  1. Assigning officers to countries using nationality, residency, and other identifiers.
  2. Selecting firms based on the presence of assigned officers.
  3. Cleaning name lists to facilitate matching with administrative data.
• All code and methods are available on GitHub for replication.

4. Key Findings from Leaked Data

• Individuals Identified in Leaks:
  • The ICIJ dataset includes over 500,000 individuals, with 178 in Honduras, 38 in Senegal, and 939 in Ecuador.
  • Most individuals are shareholders or beneficial owners, with a smaller proportion in management roles.
  • The Pandora Papers are the most significant source for Honduras, with 80.9% of officers linked to it. The Panama Papers dominate in Ecuador, with 82.89% of officers connected to it.
• Legal Entities:
  • Over 413,937 legal entities are documented in the ICIJ dataset.
  • The British Virgin Islands (BVI) is the most common jurisdiction for offshore entities, followed by Malta and Barbados.
  • For the case study countries:
    • Honduras: 70.49% of entities are in the BVI, 7.1% in Panama.
    • Senegal: 60.61% in the BVI, 9.09% in Panama, 12.12% in the Seychelles.
    • Ecuador: 38.61% in the BVI, 22.79% in Panama, 6.24% in Nevada.

5. Matching with Administrative Data

• Honduras:
  • 89% of individuals in the ICIJ data can be matched to a taxpayer with a tax ID.
  • 86% can be matched to a taxpayer who has filed some form of domestic income.
  • Individuals in the leaks are among the highest earners, representing 6% to 20% of the top 100 richest individuals and 0.01% richest individuals.
  • They are also more likely to own substantial shares in domestic companies.
• Ecuador:
  • 90% of individuals can be matched to a tax ID.
  • Only 56% can be matched to a taxpayer who has reported domestic income.
• Senegal:
  • Only 34% of individuals can be matched to a taxpayer.
  • All matched individuals have reported income.
• Disparate match rates reflect differences in data quality, tax administration capacity, and offshore activity patterns.

6. Geographic and Income Patterns

• Offshore use is more prevalent in high-income countries, with 85 individuals per million inhabitants on average.
• Low- and middle-income countries have 22 individuals per million inhabitants.
• The case study countries align with these trends, with 2 in Senegal, 17 in Honduras, and 54 in Ecuador.
• Africa shows relatively fewer individuals in the leaks compared to South America, Eastern Europe, and Central Asia.
• North America, Scandinavia, and Oceania have the highest relative use of tax havens.

7. Time Trends in Offshore Incorporation

• The number of offshore entities incorporated increases over time, peaking around 2014.
• Post-2015 data is limited, and the decline observed after that period may reflect data constraints.
• For Honduras, most incorporations occurred after 1990, with a peak in 2016.
• For Senegal, the first incorporation was in 2003, with a peak in 2016.
• For Ecuador, the first incorporation was in 1905, with a peak in January 2014.

8. Conclusion

• Leaked data can be a valuable tool for tax authorities in developing countries to detect offshore tax evasion, especially when formal information exchange mechanisms are lacking.
• The data highlights the need for systematic and regular information sharing between jurisdictions.
• Despite the utility of leaked data, it may not always provide a complete picture, due to data limitations and evolving evasion strategies.
• The practical guide offered in this report serves as an interim solution to improve tax enforcement capabilities in the short term.

Key Information

• Match rates:
  • Honduras: 89% (tax ID), 86% (domestic income)
  • Ecuador: 90% (tax ID), 56% (domestic income)
  • Senegal: 34% (tax ID), 100% (domestic income)
• Top 0.01%:
  • Represent 6% to 20% of the individuals in the leaks.
• CRS Adoption:
  • As of 2023, only Ecuador has adopted the CRS.
• Jurisdictional Use:
  • BVI is the most common jurisdiction for offshore entities.
  • Panama and Malta are also frequently used, especially in the case study countries.
• Data Sources:
  • ICIJ Offshore Leaks Database (OLD) is the primary source.
  • Data cleaning and matching procedures are essential for effective analysis.

Implications

• Leaked data can help identify high-income individuals and their offshore holdings.
• It can support tax transparency and enforcement in countries with limited access to cross-border ownership data.
• However, systematic information exchange remains critical for long-term tax compliance and enforcement.