2018年-IMF国际货币组织全球_Estimating_the_Corporate_Income_Tax_Gap_The_RA_36页_477kb

Summary of Estimating the Corporate Income Tax Gap: The RA-GAP Methodology

Core Content

This document outlines the RA-GAP (Revenue Administration - Gap Analysis Program) methodology developed by the IMF Fiscal Affairs Department, specifically for estimating the Corporate Income Tax (CIT) Gap. The CIT Gap refers to the difference between the potential tax base and revenue that could be collected under current tax legislation and the actual tax base and revenue declared by taxpayers. It is decomposed into two components: the compliance gap (due to noncompliance) and the policy gap (due to tax incentives or exemptions).

The document emphasizes the top-down approach as the preferred method for estimating the CIT Gap, which uses macroeconomic data to derive the potential tax base and revenue. This approach is contrasted with the bottom-up approach, which relies on audit results or other interventions but is more costly and subject to biases.

Main Points

1. Measuring Noncompliance and Revenue Foregone in CIT

• Tax Expenditures: Many countries estimate the fiscal impact of tax reliefs, such as exemptions for public bodies or tax credits for specific activities, which are referred to as 'tax expenditures'.
• Noncompliance: Measuring revenue lost due to noncompliance is more complex, as it involves estimating the difference between actual and potential tax base and revenue. This is challenging due to the nature of noncompliant behaviors, which are often unreported.
• RA-GAP Focus: The RA-GAP methodology is designed to estimate the CIT Gap using macroeconomic data, allowing for an initial assessment of noncompliance without requiring extensive taxpayer data collection.

2. CIT Gap Definition and Components

• The CIT Gap is defined as the difference between potential CIT liabilities and declared CIT liabilities.
• It includes both the compliance gap (due to underreporting of income or overreporting of costs) and the policy gap (due to tax incentives or exemptions).
• The top-down approach is used to estimate the potential CIT base and liabilities based on macroeconomic data, such as Gross Operating Surplus (GOS).

3. CIT Base Concepts

• Current-year Net Tax Base (C-NTB): Reflects both profit and loss-making corporations, netting out losses.
• Current-year Tax Base (C-TB): Reflects only profit-making corporations, before deducting losses.
• Tax Base (TB): Reflects profit-making corporations after deducting losses, and is the base for calculating aggregate CIT liability.

4. Adjustments for Conceptual Differences

• The RA-GAP framework requires adjusting GOS to reflect the Financial Accounting Profit (FAP) and the potential CIT base.
• These adjustments are classified into three categories: D1, D2, and D3.
  • D1: Differences between GOS and FAP (revenue and expense adjustments).
  • D2: Differences between FAP and C-NTB.
  • D3: Differences between C-NTB and TB after considering losses and carry-over effects.

Key Steps to Measure the CIT Gap

A. Determining the Scope

• The scope of the CIT Gap analysis is determined based on the coverage of CIT legislation and the availability of detailed data.
• Entities are classified into five institutional sectors under the System of National Accounts (SNA):
  • S11: Non-financial corporations
  • S12: Financial corporations
  • S13: General government
  • S14: Households
  • S15: Non-profit institutions serving households (NPISH)
• S11 and S12 are the primary sectors considered for CIT Gap analysis, as they represent the majority of entities subject to CIT.

B. Adjustments Between GOS and FAP

• Positive Adjustments:
  • Add interest (after eliminating FISIM components)
  • Add distributed income (dividends, etc.)
  • Add capital gains and losses (IVA)
• Negative Adjustments:
  • Subtract interest and rent payments
  • Subtract depreciation and capital losses
  • Subtract other financial costs such as bad debt provisions

Data Requirements

To estimate the CIT Gap, the following data are necessary:

• National Accounts Data (e.g., GOS)
• Registration Information of all CIT taxpayers
• Individual Tax Return Data for all taxpayers and every tax period
• Individual Payment Data for all taxpayers and every tax period
• CIT Aggregate Revenue Data

These data sources help in calculating the declared CIT base and liability, which are then compared with the potential CIT base and liability derived from macroeconomic data.

Use of CIT Gap for Revenue Performance Analysis

• The CIT base gap is the difference between potential C-TB and declared C-TB, and can be expressed as a ratio to potential C-TB or as a percentage of GDP.
• The CIT gap is the difference between potential CIT liability and declared CIT liability, and can also be expressed as a ratio to potential CIT liability or as a percentage of GDP.
• The CIT Efficiency Ratio is used to assess the overall performance of the CIT system, indicating how effectively the tax system is collecting revenues.

Final Remarks

• The RA-GAP methodology provides a systematic and standardized approach to estimate the CIT Gap.
• It is particularly useful for initial assessments and comparative analyses between countries.
• While the top-down approach has limitations due to data constraints and potential biases, it remains a cost-effective and widely applicable method.
• Sector-level CIT gaps can provide insights into noncompliance patterns and help in designing targeted compliance strategies.

References and Additional Notes

• The methodology is informed by preceding studies such as Mendoza, Razin and Tesar (1994) and IMF (2014).
• The RA-GAP framework includes detailed procedures for adjustments (see Tables 1 and 2).
• The CIT Gap can be a more robust measure than the CIT base gap when deductible credits and additional liabilities are considered.
• Foreign source incomes and foreign entities require special treatment, as outlined in Box 1.
• The magnitude of differences between GOS and C-TB in the United States is discussed in Box 2.

Conclusion

The RA-GAP methodology provides a comprehensive framework for estimating the CIT Gap, which is essential for understanding tax noncompliance and revenue performance. By using macroeconomic data and adjusting for conceptual differences, it enables a systematic and cost-effective approach to assess the efficiency of tax administration and the impact of tax policies. This analysis is critical for policy formulation and revenue enhancement strategies.