2016年-IMF国际货币组织全球_Ukraine_Technical_Assistance_Report_61页_699kb

Summary of the Technical Assistance Report on Ukraine: Tax Administration Reforms and Governance Options

Core Content

This Technical Assistance Report (TAR) from the International Monetary Fund (IMF) provides an in-depth analysis of Ukraine's tax administration challenges and outlines a series of short-term and medium-term reforms to improve revenue collection, tax compliance, and governance structures. The report was prepared in August 2014 in response to a request from the Minister of Finance and is based on information available at the time.

Main Recommendations

1. Immediate Revenue Enhancement Measures

• Cease Revenue Deferral from Tax Disputes: Require partial payment of disputed tax before appeal proceedings.
• Installment Schemes: Offer installment plans for tax arrears with a maximum term of 24 months.
• Strengthen Routine Monitoring: Improve controls over filing and payment obligations.
• Centralized Management of Large Taxpayers: Transfer all large taxpayers to the Large Taxpayer Inspectorate (LTI) for better oversight.
• Independent Internal Appeals Unit: Establish an independent and centrally managed unit for resolving tax disputes.
• Remove Legislative Barriers: Eliminate legal obstacles to effective USC audits.
• Expand Payroll Audits: Implement a more extensive on-site payroll audit program for USC and PIT compliance.
• Publicize Compliance Efforts: Launch a well-publicized program to improve USC compliance.
• Court Dispute Reforms: Require 50% of disputed tax to be paid before court proceedings.

2. Value-Added Tax (VAT) Reforms

• Raise VAT Registration Threshold: Increase the VAT registration threshold to UAH 1 million.
• Sunset Clause for VAT Bank Accounts: Implement a one-year sunset clause for VAT bank accounts to avoid disadvantaging small businesses and exporters.
• Fast Track De-Registration: Develop a fast-track procedure for de-registering businesses that no longer meet VAT criteria.
• Screen New Registrants: Carefully screen new and voluntary VAT registrants to detect fraud.

3. Governance and Institutional Reforms

• Announce Governance Model: By August 31, 2014, the government should announce the future model for tax administration governance.
• Form New Revenue Authority: Establish the State Fiscal Service (SFS) by July 2014 to replace the Ministry of Revenue and Duties (MRD).
• Staff Reductions: Plan for an 8.6% reduction in staff across regional and local offices and a 10% reduction in the headquarters.
• Deputy Chairman for Tax Administration: Appoint a new deputy head of MRD responsible for tax administration by August 31, 2014.
• Autonomy for New Institution: The SFS should be autonomous and coordinated by the Cabinet of Ministers, with the head appointed by the Prime Minister.

Key Information

Tax Administration Overview

• In 2013, Ukraine's tax revenues (including social security taxes) accounted for 37.9% of GDP.
• The largest revenue component is social security contributions at 13.3% of GDP.
• VAT is close to 9% of GDP, and income taxes are similar in magnitude.
• The tax administration faces significant integrity and governance issues, including corruption and weak enforcement.

Current Tax Administration Challenges

• Large Taxpayers: Only 35.2% of large taxpayers are managed by the LTI, despite its potential to better control tax affairs.
• Tax Arrears: Tax arrears for large taxpayers total UAH 2.641 billion, with a further UAH 5.456 billion likely collectible.
• Tax Disputes: Disputes have increased by 65% between 2011 and 2013, with over 50,000 appeals pending.
• USC Compliance: USC compliance is weak, with arrears rising by 36% since October 2013, reaching UAH 3.6 billion by May 2014.
• VAT Fraud: "Tax pits" involving chains of small and medium entities are a major concern, and the current VAT bank account system is seen as disproportionate and ineffective.

Reforms and Implementation Timeline

• August 31, 2014: Appoint a new deputy head for tax administration and announce governance reforms.
• September 30, 2014: Implement installment plans for tax arrears.
• November 30, 2014: Establish an independent internal review process for tax disputes.
• December 31, 2014: Transfer large taxpayers to the LTI.
• Mid-2016: Commence the High Net Wealth Individuals (HNWI) program after the LTI reaches full operational capacity.

Institutional Changes

• The MRD is being replaced by the SFS, which will be in place from July 2014.
• Tax policy functions will be returned to the Ministry of Finance (MOF), while tax police and customs functions will remain within the SFS.
• The SFS will be coordinated by the Cabinet of Ministers and have a deputy chairman responsible for tax administration.

Tax Compliance Measures

• Managing Large Taxpayers: The LTI should be expanded to cover all large taxpayers, which would require tripling its current taxpayer base.
• Staffing Reforms: The LTI has reduced its staff from 2560 in 2012 to 2088 in 2014. Additional audit staff may be redeployed from regional offices to support this expansion.
• Payroll Audits: Expand the payroll audit program for USC and PIT compliance.
• HNWI Program: Develop a program targeting high net wealth individuals, who are often de-facto controllers of large businesses. This program should be implemented from mid-2016.

Governance and Integrity

• The current tax administration is perceived as vulnerable to corruption and lacks public trust.
• The mission emphasizes the need for an independent and fair internal dispute resolution system.
• The new SFS must be autonomous and free from political interference to ensure effective governance.

Conclusion

The report outlines a comprehensive set of reforms aimed at improving tax administration in Ukraine, with a focus on increasing revenue, enhancing compliance, and restoring public trust. These measures include both immediate actions to address short-term revenue and compliance gaps, as well as longer-term institutional changes to establish a more efficient and fair tax administration system. The proposed reforms are aligned with the IMF's support program and require strong political commitment and coordination.