2013年-IMF国际货币组织全球_United_Kingdom_Technical_Assistance_ReportAssessment_of_HMRC’s_Tax_Gap_Analysis_57页_1mb

Summary of the United Kingdom: Technical Assistance Report—Assessment of HMRC's Tax Gap Analysis

Core Content

This report, prepared by the IMF Fiscal Affairs Department in August 2013, evaluates HMRC's tax gap analysis program. It provides an assessment of HMRC's current methodologies, frameworks, and use of tax gap data in revenue administration and compliance management. The report is part of a technical assistance initiative and is intended to guide HMRC in improving its approach to measuring and addressing the tax gap.

Main Findings

• HMRC's tax gap analysis program is comprehensive, covering most taxes it administers and providing one of the most detailed studies of tax gap estimates globally.
• The program uses both bottom-up and top-down methodologies to estimate tax gaps:
  • Bottom-up methods are used for direct taxes (income tax, NIC, self-assessment, etc.).
  • Top-down methods are applied for indirect taxes such as VAT and excise duties.
• The tax gap is defined as the difference between tax collected and the theoretical liability, which includes both compliance and policy components.
• The tax gap estimates are used to support HMRC's strategic vision of closing the gap, improving efficiency, and enhancing the perception of fairness in the tax system.
• The report highlights the need to distinguish between compliance and policy gaps, especially in the context of legal tax avoidance schemes.
• HMRC's current approach avoids linking small changes in tax gap estimates to administrative actions, which is considered a sensible practice given the complexity and data limitations.

Key Recommendations

The report outlines several recommendations aimed at improving the robustness and clarity of HMRC's tax gap analysis:

Defining the Tax Gap

• Distinguish between compliance and policy components of tax avoidance schemes in reporting the tax gap.

Measuring the Tax Gap – Direct Taxes

• Taxpayer segmentation: Random audit programs should be based on risk profiles.
• Outlier exclusion: The practice of excluding outliers from audit samples should be reviewed.
• Wage assumptions: The assumed wage levels for "ghosts" and "moonlighters" need a stronger basis.
• Audit results: Use targeted audit results to validate tax gap estimates and assumptions.
• Uplift factors: Domestic uplift factors should be estimated for better accuracy.

Measuring the Tax Gap – Indirect Taxes

• Better data: Improved data on VAT collected on inputs into exempt supplies is needed.
• Volume surveys: Excise tax gap estimates should use volume survey data.

Reporting the Tax Gap

• Aggregation review: The aggregation of tax gap estimates should be reviewed to better represent tax types.
• Method segmentation: Tax gap estimates should be segmented by estimation method.
• Gross and net gaps: Both gross and net gaps should be reported in addition to the anticipated net gap.
• Accruals report: A proper accruals report for VAT revenues should be created.

Using the Tax Gap

• Performance measurement: Reporting both gross and net gap estimates improves performance measurement.
• Resource allocation: HMRC should continue using tax gap data to support resource allocation for tackling noncompliance.

Tax Gap Estimates and Methodologies (2011)

Key Methodologies and Models

• Noncorporation Taxes:
  • Random-enquiry program: Used to estimate tax gaps for SMEs and other taxpayer segments.
  • Data-matching: Involves cross-checking information with third-party data.
  • Ad-hoc modeling: Used to estimate tax gaps in the "hidden economy."
• Corporation Tax:
  • Relies on data from the LBS case management system and random audit results.
• Indirect Taxes:
  • VAT: Top-down estimates based on consumption data; bottom-up estimates used to determine the composition of the gap.
  • Excise Taxes: Top-down estimates based on consumption and travel data.

Possible Future Research

• Top-down models for income tax gaps: Could be explored to improve the accuracy of estimates.
• Policy gap assessment: Extend the analysis to measure the size of the policy gap by tax type.
• VAT gap model: Compare the current consumption-based VAT gap model with a value-added-based model.
• Policy gap measurement: Further research could help assess the impact of policy choices on tax revenue.

Conclusion

The report emphasizes the importance of a comprehensive and transparent tax gap analysis for HMRC, highlighting both its strengths and areas for improvement. It recommends a more detailed and structured approach to reporting, segmenting, and using tax gap data, while also suggesting future research directions to better understand the broader implications of tax policy and compliance on revenue performance.