Back Matter

Back Matter

Author(s):
Olivier Benon, Katherine Baer, and Juan Toro R.
Published Date:
April 2002
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    Appendix I Summary Tables of LTU Survey Responses
    Table A1.Main Reason for Establishing a Large Taxpayer Unit
    CountryTo Secure

    Tax Revenue
    To Improve Audit

    Effectiveness
    To Provide Better

    Taxpayer Services
    Other
    Central and Eastern European Countries
    Bulgaria1
    Hungary*
    Baltics and the Commonwealth of Independent States
    Azerbaijan
    Georgia*
    Latvia*
    Moldova*
    Tajikistan*
    Ukraine*
    Africa
    Benin*
    Burkina Faso*
    Cameroon*
    Côte d’lvoire*
    Kenya*
    Togo*
    Uganda*
    Asia and Pacific
    Mongolia*
    Philippines*
    Sri Lanka*
    Latin America
    Argentina*
    Bolivia*
    Colombia*
    Ecuador*
    El Salvador*
    Mexico*
    Paraguay*
    Peru*
    Uruguay*
    Venezuela, República Bolivariana de*
    Others
    Australia*
    Japan*
    Netherlands*
    New Zealand2*
    Spain*
    United Kingdom3*
    United States*

    Main reasons listed, but no priority given: to secure revenue, to improve management of arrears, to provide better services to large taxpayers.

    Also, to improve audit effectiveness, to provide better taxpayer services.

    Both Inland Revenue and HMC&E reported “securing revenue” as the most important reason for setting up their large taxpayer operations.

    Table A2.Legal Framework for LTU Operations
    CountrySpecial Legal Provisions

    for Operations of LTU
    No Separate Legal

    Provisions for LTU Operations
    Central and Eastern European Countries
    Bulgaria***
    Hungary***
    Baltics and the Commonwealth of Independent States
    Azerbaijan***
    Georgia***
    Latvia***
    Moldova***
    Tajikistan***1
    Ukraine***
    Africa
    Benin***
    Burkina Faso***
    Cameroon***
    Kenya***
    Togo***
    Uganda***
    Asia and Pacific
    Mongolia***
    Philippines***
    Sri Lanka***
    Latin America
    Argentina***
    Bolivia***
    Colombia***
    Ecuador***
    El Salvador***
    Mexico***
    Paraguay***
    Peru***
    Uruguay***
    Venezuela, República Bolivariana de***
    Others
    Australia***
    Japan***
    Netherlands***
    New Zealand***
    Spain***2
    United Kingdom***3
    United States***4

    Administrative decree establishing LTU.

    There are specific ordinances regarding the structure and functions of the National Audit Office. There are also specific ordinances outlining the obligations of the large taxpayers (e.g., location and deadlines for filing tax returns).

    Relevant for both HMC&E and Inland Revenue.

    The IRS Restructuring & Reform Act of 1998 prescribed certain procedures and responsibilities for the Large and Mid-Size Business Division but also required that certain large taxpayer issues be handled by other pares of the IRS (i.e., appeals, criminal investigation, etc.).

    Table A3.Taxes Administered by the LTU, 1999
    CountryVAT or

    Sales Tax
    Excises and

    Other

    Indirect Taxes
    Personal and

    Corporate

    Income Taxes
    Other Direct

    Taxes
    Social

    Security

    Contributions
    Customs

    Duties
    Local

    Taxes
    Central and Eastern European Countries
    Bulgaria************
    Hungary*********
    Baltics and the Commonwealth of Independent States
    Azerbaijan************
    Georgia******************
    Latvia******************
    Moldova******************
    Tajikistan************
    Ukraine************
    Africa
    Benin************
    Burkina Faso***************
    Cameroon************
    Kenya************
    Togo************
    Uganda***************1
    Asia and Pacific
    Mongolia*********
    Philippines************
    Sri Lanka***2***3******
    Latin America
    Argentina***************
    Bolivia************
    Colombia************4
    Ecuador************
    El Salvador*********
    Mexico***************
    Paraguay************
    Peru***************
    Uruguay************
    Venezuela, República Bolivariana de************
    Others
    Australia***
    Japan******5
    Netherlands************
    New Zealand***************
    Spain******6***
    United Kingdom7***************
    United States************

    Local excise taxes.

    The LTU does not administer the equivalent of the VAT the goods and services tax. It only administers the turnover tax, which is limited to the financial sector.

    National Security Levy.

    Stamp tax.

    Corporate income tax only.

    LTU administers excise tax on insurance. All other excises are administered by customs.

    HMC&E administers the VAT and excises, and Inland Revenue administers personal and corporate income taxes and social security contributions.

    Table A4.Criteria Used to Identify the Largest Taxpayers
    CountryAmount of Tax

    Paid during

    Previous Year/Filing Period
    Annual

    Turnover
    Number of

    Employees
    Level of

    Imports/Exports
    Type of Economic

    Activity (e.g., Public

    or Financial

    Sector, or Taxpayer

    Is a Foreign Firm)
    Central and Eastern European Countries
    Bulgaria***1***
    Hungary******2
    Baltics and the Commonwealth of Independent States
    Azerbaijan***
    Georgia***
    Latvia*********3
    Moldova************
    Tajikistan************
    Ukraine***
    Africa
    Benin***
    Burkina Faso***4
    Cameroon***
    Kenya******5***
    Togo************
    Uganda************
    Asia and Pacific
    Mongolia************
    Philippines******
    Sri Lanka***
    Latin America
    Argentina*********
    Bolivia******6
    Ecuador***************
    El Salvador******
    Mexico******
    Paraguay******
    Peru************7
    Uruguay***************8
    Venezuela, República Bolivariana de*********9
    Others
    Australia***10
    Japan11
    Netherlands******12
    New Zealand******
    Spain***13
    United Kingdom14*********
    United States15

    Other criteria used: amount of tax refunded, value of fixed assets.

    Other criterion used: amount of VAT refund claim.

    Other criteria used: taxpayers with complicated structure and several subsidiaries, taxpayers with annual balances higher than a certain amount.

    Another criterion used: if taxpayer is a corporate taxpayer.

    For purposes of determining the corporate income tax.

    Other criteria used: amount of tax assessed, annual purchases.

    Other criteria used: whether or not the taxpayer belongs to a conglomerate or a corporate group, or has significant asset holdings.

    Another criterion used: whether or not the taxpayer is a withholding agent.

    Another criterion used: if taxpayer is in the mining and hydrocarbons sector.

    Other criterion used: taxpayer is “high wealth.”

    Criterion used: corporations with capital of ¥100 million or more.

    Other criterion used: share capital.

    Other criteria used: importance of taxpayer within economic sector, whether taxpayer is member of a corporate group, complexity of operations, whether operations span a large geographic area.

    HMC&E uses the following criterion: amount of tax paid throughout the previous year. Inland Revenue use the following criteria: annual turnover, whether the taxpayer is a public enterprise or financial sector enterprise, and with respect to the corporate income tax, whether there are significant international tax aspects to the enterprise’s operations.

    Criteria used: corporations and partnerships with assets of over $5 million. While corporations with assets in excess of $5 million are now considered customers of the Large and Mid-Size Business Division, a “pointing” system is used to identify the largest and most complex taxpayers within this population, which corresponds to the Large Case Program the IRS had in place prior to its reorganization.

    Table A5.Number of Large Taxpayer Offices/Branches, 1999
    CountrySingle LTUSingle LTU

    with Branches

    (Number of Branches)
    Multiple

    Autonomous LTUs

    (Number of Offices)
    Central and Eastern European Countries
    Bulgaria***(5)
    Hungary***
    Baltics and the Commonwealth of Independent States
    Azerbaijan***(13)
    Georgia***(16)
    Latvia***
    Moldova***(1)
    Tajikistan***(3)
    Ukraine***(6)
    Africa
    Benin***
    Burkina Faso***(2)
    Cameroon***(4)
    Kenya***
    Togo***
    Uganda***(2)
    Asia and Pacific
    Mongolia***
    Philippines***(1)
    Sri Lanka***(2)1
    Latin America
    Argentina***
    Bolivia***(3)
    Colombia***
    Ecuador***(9)
    El Salvador***
    Mexico***(11)
    Paraguay***(2)
    Peru***(17)
    Uruguay***(9)
    Venezuela, República Bolivariana de***(9)
    Others
    Australia***(10)
    Japan***(12)2
    Netherlands***(11)
    New Zealand***(2)3
    Spain4
    United Kingdom5***(32)***(12)
    United States***6

    There is not a single, unified LTU. Rather, the “LTU” in Colombo is separated into two offices, one for collection and enforcement, and one for audit, each reporting to different commissioners.

    Large taxpayer audit units are not autonomous, but rather are part of the regional tax office structure.

    In addition to the main corporates segment office in Wellington, there are two main offices that handle corporate operations: one in Auckland and one in Christchurch. There are also a few corporates segment staff in other locations around the country, but they handle relatively few corporate cases.

    There are for practical purposes two large taxpayer units; (1) the National Audit Office, which carries our. audits of the large taxpayers; and (2) the Central Unit for Management of Large Enterprises, which is responsible for all collection and monitoring functions. A third unit, the National Collection Office, was established recently as a national unit responsible for enforced collection of large tax debts, which generally correspond to the large taxpayers. The National Audit Office has 17 branches at the regional office level that perform audits of the large taxpayers.

    Inland Revenue has a single LTU with 32 branch offices (an increase in relation to the 25 branches that existed in 1997, because of the expansion of the unit’s work to include the administration of national insurance contributions). HMC&E reports having 12 autonomous LTUs.

    There are five industry groups that report to the Large and Mid-Site Business Division at headquarters: Retail, Food, and Pharmaceuticals: Natural Resources; Financial Services and Healthcare: Heavy Manufacturing. Construction, and Transportation: and Communications, Technology, and Media.

    Table A6.Supervision/Reporting Lines for Large Taxpayer Office
    CountryThe Large Taxpayer Office

    Reports Directly to the

    Tax Department Director
    The Large Taxpayer Office

    Reports to the Central Supervisory

    Office for Operations
    Central and Eastern European Countries
    Bulgaria***
    Hungary***
    Baltics and the Commonwealth of Independent States
    Azerbaijan***
    Georgia***
    Latvia***
    Moldova***
    Tajikistan***
    Ukraine***
    Africa
    Benin***
    Burkina Faso***
    Cameroon***
    Kenya***
    Togo***
    Uganda***1
    Asia and Pacific
    Mongolia***
    Philippines******
    Sri Lanka***2
    Latin America
    Argentina***
    Bolivia***
    Colombia***
    Ecuador***
    El Salvador***
    Mexico***
    Paraguay***
    Peru***3
    Uruguay***4
    Venezuela, República Bolivariana de***
    Others
    Australia***5
    Japan***6
    Netherlands***7
    New Zealand***
    Spain***8
    United Kingdom***9
    United States***10

    Reporting fine from the LTU to the commissioner is through the deputy commissioner for revenue.

    Large taxpayer collection and enforcement office reports to headquarters enforcement department, and large taxpayer audit office reports to headquarters corporate tax department.

    The large taxpayer offices are part of the regional tax office network. As such, they report to the national operations office at headquarters.

    The LTU in Montevideo reports to the collection department at headquarters, and the LTUs in the interior of the country report to the headquarters division in charge of supervising operations of tax offices in the interior.

    The LTUs report to a headquarters office responsible for supervising all large taxpayer operations.

    Large taxpayer units are primarily audit units and report to the headquarters audit department.

    The LTUs report to a headquarters office responsible for supervising all large taxpayer operations.

    There is a headquarters unit that supervises the operations of the Central Unit for Management of Large Enterprises. The National Audit Office, which carries out audits of the large taxpayers, reports to the headquarters audit department

    In the case of both HMC&E and Inland Revenue, there is a special headquarters unit in charge of supervising the large taxpayer units’ operations.

    The Large and Mid-Size Business Division at headquarters is responsible for supervising all large taxpayer operations.

    Table A7.Organizational Structure of the Large Taxpayer Office/Operation
    CountryFunction-BasedTax-BasedCombination Tax

    and Function-Based
    Central and Eastern European Countries
    Bulgaria***
    Hungary***1
    Baltics and the Commonwealth of Independent States
    Azerbaijan***
    Georgia***
    Latvia***
    Moldova***2
    Tajikistan***
    Ukraine***3
    Africa
    Benin***
    Burkina Faso***
    Cameroon***
    Kenya***
    Togo***
    Uganda***
    Asia and Pacific
    Mongolia***
    Philippines***
    Sri Lanka***4
    Latin America
    Argentina***
    Bolivia***
    Colombia***
    Ecuador***
    El Salvador***
    Mexico***
    Paraguay***
    Peru***5
    Uruguay***6
    Venezuela, República Bolivariana de***
    Others
    Australia7
    Japan***
    Netherlands***
    New Zealand***
    Spain***8***9
    United Kingdom***10
    United States11

    The LTU does nor carry out the enforcement function.

    Functions are limited to audit and enforcement.

    LTUs are in the process of being implemented, and the intention is to set up function-based structures.

    The LTU is separated into two offices performing different functions (i.e., one office carries out collection and enforcement activities; the other, audit activities).

    Initial functions were only collection and enforcement.

    LTUs carry out only collection functions.

    Neither function- nor tax-based. Large Business and International is a matrix of industry segments and “topic” segments (international, capital gains, privatization, etc).

    The National Audit Office focuses on auditing large taxpayers; the Central Unit for Management of Large Enterprises carries out collection and monitoring functions.

    The Central Unit for Management of Large Enterprises is partially organized by tax. It has a separate VAT unit. The unit is responsible for administering all the major taxes as regards the large taxpayers, with the exception of customs duties and excises, which are administered by customs.

    The units in HMC&E focus on VAT and excises and perform the audit function. The units in Inland Revenue administer the direct taxes and national insurance contributions, and perform the following functions: with respect to the corporate income tax, the Large Business Offices perform all the main tax administration functions; with respect to the national insurance contributions, the Large Employer Compliance Offices conduct audit work.

    The IRS’s Large and Mid-Size Business Division is organized by industry type. Other divisions in the IRS are organized around the following functions: prefiling, filing, and postfiling (compliance).

    Table A8.Tax Collection and Payment Procedures Used by the LTU, 1999
    CountryElectronic Filing

    through LTU and

    Payment through Banks
    Joint Filing

    and Payment

    through Banks
    Joint Filing

    and Payment

    through LTU
    Separate Filing

    and Payment (LTU

    Office and Banks)
    Payment through

    an “In-House” Bank

    Located in LTU
    Central Eastern and European Countries
    Bulgaria***
    Hungary***1
    Baltics and the Commonwealth of Independent States
    Azerbaijan***
    Georgia***
    Latvia***
    Moldova2
    Tajikistan***
    Ukraine***
    Africa
    Benin***
    Burkina Faso***
    Cameroon***
    Kenya3
    Togo***
    Uganda******
    Asia and Pacific
    Mongolia***
    Philippines******4
    Sri Lanka***
    Latin America
    Argentina******
    Bolivia*********
    Colombia******
    Ecuador***5
    El Salvador***6*********7
    Mexico***8
    Paraguay***
    Peru******9
    Uruguay***10
    Venezuela, República Bolivariana de***
    Others
    Australia***11
    Japan12
    Netherlands***13
    New Zealand*********
    Spain******
    United Kingdom14***
    United States15*********

    The large taxpayers pay their taxes through the banking system. Payment information is sent to the LTU electronically directly through the clearinghouse system of the banks (also referred to as the GIRO system). The large taxpayers can also pay their taxes electronically.

    LTU performs only audit and enforcement functions. Large taxpayers file their returns at the local offices, and pay taxes through the banks.

    Large taxpayers file their returns and make their payments centrally at the offices of the respective revenue departments (e.g., income tax department, value-added tax department, and customs and excise department).

    Electronic filing and payment envisaged for 2001.

    Payment is electronic (e.g., electronic bank debit).

    No electronic filing yet.

    No electronic filing yet.

    Large taxpayers file their returns at the tax collection department of the Tax Administration Service (SAT), where returns are processed. Large taxpayers make payments through the banking system.

    The large taxpayers have always paid in bank branches located on the premises of the large taxpayer offices of the SUNAT.

    Filing is done electronically.

    Tax collections are managed through the ATO Small Business client segment to avoid unnecessary duplication and reviewed by the Large Business and International client segment, or LB&I For example, the banking and finance segment within LB&I closely monitors its clients’ payments and debts. However, the taxes are paid through a common system administered by the Small Business segment, The ATO has electronic refund transfer arrangements with many large corporations, particularly the “pay-as-you-go” employee deductions remitted on a bi-weekly/monthly basis.

    Not applicable, as the large taxpayer units in Japan only perform audit functions.

    Large taxpayers submit their returns to the LTUs, but the final processing is carried out by a central processing unit.

    Applies to both HMC&E and Inland Revenue.

    Large corporations must file with the IRS. Payments can be made through banks or to the IRS directly. Electronic filing is available for some but not all returns. Electronic payment to banks and the IRS is available.

    Table A9.Types of Audits Undertaken by the LTU, 1999
    CountryComprehensive

    Audits
    Single-Issue

    Audits
    Desk AuditsAudit Operations

    Are Structured

    Around Major

    Industry Segments
    Central and Eastern European Countries
    Bulgaria******
    Hungary******
    Baltics and the Commonwealth of Independent States
    Azerbaijan*********
    Georgia***
    Latvia************
    Moldova*********
    Tajikistan***
    Ukraine******
    Africa
    Benin******
    Burkina Faso***
    Cameroon******
    Kenya************
    Togo******
    Uganda************
    Asia and Pacific
    Mongolia******
    Philippines*********
    Sri Lanka*********
    Latin America
    Argentina*********
    Bolivia************
    Colombia*********
    Ecuador1
    El Salvador*********
    Mexico************2
    Paraguay******
    Peru************3
    Uruguay4n.a.n.a.n.a.n.a.
    Venezuela, República Bolivariana de******
    Others
    Australia******
    Japan************
    Netherlands************
    New Zealand************
    Spain5*********
    United Kingdom6************
    United States******n.a.7***

    No significant audit activity is currently undertaken by the LTU. Because of limited resources, the decision was made to concentrate on monitoring large taxpayers’ compliance with filing and payment obligations, as well as enforcing the collection of arrears. The tax administration authorities intend to develop the LTU’s audit capacity in the future.

    Audits are organized according to different sectors of economic activity (financial, government, others) as well as by type of issue (fiscal consolidation, related parties, transfer pricing, etc.).

    In addition, other criteria are used to classify taxpayers with a view to minimizing their noncompliance.

    Large taxpayer unit only performs tax collection function.

    Comprehensive audits are carried out by the national audit office; single-issue audits are carried out both by the national audit office and by the large taxpayer office, and desk audits are carried out by the LTO.

    Applies to both HMC&E and Inland Revenue.

    Desk audits are generally not conducted in the LMSB Division, except for a limited number completed in the international examination program.

    Table A10.Collection Enforcement Functions of the LTU
    CountryIs the LTU Responsible for Enforcing Payment of

    Tax Arrears of the Largest Taxpayers?
    YesNo
    Central and Eastern European Countries
    Bulgaria*
    Hungary*
    Baltics and the Commonwealth of Independent States
    Azerbaijan*1
    Georgia*
    Latvia*
    Moldova*2
    Tajikistan*3
    Ukraine*4
    Africa
    Benin*
    Burkina Faso*
    Cameroon*5
    Kenya*
    Togo*
    Uganda*
    Asia and Pacific
    Mongolia*
    Philippines*
    Sri Lanka*
    Latin America
    Argentina*
    Bolivia*
    Colombia*
    Ecuador*
    El Salvador*6
    Mexico*7
    Paraguay*
    Peru*
    Uruguay*8
    Venezuela, República Bolivariana de*
    Others
    Australia*9
    Japann.a.l0n.a.
    Netherlands*
    New Zealand*
    Spain*
    United Kingdom*11*12
    United States*13

    Another department in the state tax ministry is responsible for this function. The ministry of the interior also carries out some enforcement functions.

    The financial police also carry out some collection enforcement work, which leads to duplication of activities and complicates the recovery of overdue tax.

    The LTU tax police unit carries out enforcement work.

    The tax police perform some enforcement activities.

    Initially, the treasury was responsible for enforcing payment of tax arrears. This function was subsequently transferred to the LTU.

    The LTU refers cases of enforced collection to the treasury, which is Legally responsible for enforcing payment of tax arrears. In case the treasury is unable to recover the refunds, the case is transferred to the public prosecutor’s office for further action.

    The local tax offices have the authority to initiate collection enforcement action until such time as an Agreement of Initiation of Activities by the large taxpayer offices is published in the Official Diary of the Federation.

    The tax revenue unit, and not the LTU, enforces collections.

    Industry segments monitor and assist with debt collection.

    Audit work only.

    In the case of Inland Revenue, the Large Business Offices enforce collections with respect to the corporate income tax only. The Large Employer Compliance Offices perform audit work only.

    The large taxpayer units in HMC&E are not responsible for enforcing collections.

    The collection enforcement function is “contracted out” to the IRS’s Small Business/Self-Employed Division.

    Table A11.Number of Staff in LTU/Large Taxpayer Audit Unit, 1999
    CountryTotal

    Number of Staff
    As a Percent of Total Tax

    Administration Staff
    Central and Eastern European Countries
    Bulgaria3673.9
    Hungary1971.5
    Baltics and the Commonwealth of Independent States
    Azerbaijan822.6
    Georgia150
    Latvia643.5
    Moldova792.9
    Tajikistan783.0
    Ukraine1,0571.7
    Africa
    Benin688.5
    Burkina Faso10310.0
    Cameroon12010.0
    Kenya561.4
    Togo248.0
    Uganda110
    Asia and Pacific
    Mongolia17
    Philippines2491.9
    Sri Lanka547.0
    Latin America
    Argentina6553.7
    Bolivia18016.0
    Colombia2393.1
    Ecuador2210.0
    El Salvador13112.3
    Mexico1,4913.8
    Paraguay2309.0
    Peru
    Uruguay443.3
    Venezuela, República Bolivariana de2954.3
    Others
    Australia1,2508.6
    Japan12,1153.7
    Netherlands2,1507.0
    New Zealand2405.5
    Spain6542.4
    United Kingdom275012.0
    United Kingdom36701.0
    United States7,03547.0

    Audit function only.

    HMC&E (indirect taxes).

    Inland Revenue (direct taxes and national insurance contributions).

    Figures are based on an initial plan for staffing of Large and Mid-Size Business. Actual staffing at the time of the survey was around 500 fewer staff members, who are largely planned headquarters staff.

    Table A12.Salaries and Benefits of LTU/Large Taxpayer Audit Unit Staff, 1999
    CountrySalaries/Benefits Same

    as Rest of Tax

    Administration Staff
    Higher Salaries/Benefits

    Compared to Rest of Tax

    Administration Staff
    Central and Eastern European Countries
    Bulgaria***1
    Hungary***
    Baltics and the Commonwealth of Independent States
    Azerbaijan***
    Georgia***
    Latvia***2
    Moldova***3
    Tajikistan***
    Ukraine***
    Africa
    Benin***
    Burkina Faso***
    Cameroon***
    Kenya***
    Togo***
    Uganda***
    Asia and Pacific
    Mongolia***
    Philippines***4
    Sri Lanka***
    Latin America
    Argentina***
    Bolivia***5
    Colombia***
    Ecuador***
    El Salvador***
    Mexico***
    Paraguay***
    Peru***
    Uruguay***
    Venezuela, República Bolivariana de***
    Others
    Australia***6
    Japan7***
    Netherlands***8
    New Zealand***9
    Spain***
    United Kingdom***10
    United States***

    Salaries are same as in other tax offices but individual bonuses are higher.

    Salaries are 26 percent higher than rest of tax administration staff.

    Bonuses are higher starting end of 1999. Amount of bonus is determined on the basis of performance indicators for the LTU.

    The tax administration authorities noted that in their view, “higher salaries and/or benefits would be a very good incentive for LTU personnel who were selected under higher qualification standards.”

    At the time of LTU establishment in I9$B, LTU staff salaries were 100 percent higher than average salary in rest of tax administration.

    By virtue of higher qualifications required to deal with the level of complexity of the large taxpayers.

    Performs audit functions only.

    Salaries are 20 percent higher.

    Salaries are around 5 percent higher.

    For both HMC&E and Inland Revenue, there is a slightly higher overall job grading, and there is a move to establish greater salary differentiation.

    Appendix II Country Responses to LTU Survey and LTU Survey Form
    Table A13.Country Responses to LTU Survey
    No ResponseComplete ResponsePartial Response
    Central and Eastern European Countries
    Albania*
    Bulgaria*
    Hungary*
    Baltics and the Commonwealth of Independent States
    Azerbaijan*
    Georgia*
    Latvia*
    Moldova*
    Russia*
    Tajikistan*
    Ukraine*
    Africa
    Benin*
    Burkina Faso*
    Cameroon*
    Côte d’Ivoire*
    Kenya*
    Togo*
    Uganda*
    Asia and Pacific
    Cambodia*
    Philippines*
    Sri Lanka*
    Latin America
    Argentina*
    Bolivia*
    Colombia*
    Ecuador*
    El Salvador*
    Mexico*
    Paraguay*
    Peru*
    Uruguay*
    Venezuela, República Bolivariana de*
    Others
    Australia*
    Austria*
    Japan*
    New Zealand*
    Netherlands*
    Spain*
    United Kingdom*
    United States*
    LTU Survey Form
    A. General Information1
    Country:
    1. Date of establishment of the LTU:_______
    2. Role of the IMF:
    a. Did the IMF recommend implementation of an LTU?Yes ______No ______
    b. Did the IMF assist with LTU implementation?Yes ______No ______
    c. If you answered “yes” to 2b. please specify what type of IMF assistance was provided (e.g., technical assistance missions, long-term experts, short-term experts):
    d. Other technical assistance providers were involved with LTU establishment: (e.g., they provided technical advice, financing, etc.)Yes ______No ______
    e. Prior to the establishment of the LTU, was there any focus on monitoring/controlling the large taxpayers?Yes ______No ______
    3. Context of LTU establishment
    a. Was the LTU established as part of an overall reform of the tax administration?Yes ______No ______
    b. If your answer to question 3a. was yes, please indicate the other areas of tax
    administration that were included in the reform program:
    4. Main reasons for implementing LTU: (please list the three main reasons in order of priority: 1,2, and 3)
    a. Secure revenue______
    b. Improve management of arrears______
    c. Improve audit program______
    d. Provide better services to large taxpayers______
    e. Develop new organization, procedures, systems______
    f. Other reason (please specify)______
    5. LTU staffing:At introductionCurrently
    (please indicate the actual number and distribution of staff)
    a. Total number of LTU staff (if applicable, including staff at headquarters and
    b. Distribution of LTU staff by level:
    1. Managerial staff____________
    2. Professional staff____________
    3. Support staff____________
    c. Distribution of LTU professional staff by function:
    1. Processing and accounting for tax returns and payments____________
    2. Audit____________
    3. Collection enforcement____________
    4. Tax payer services____________
    5. Information systems____________
    6. Other (please specify)____________
    d. Number of staff as a percent of total tax administration staff:____________
    6. Please indicate which taxes are administered by the LTU:At introductionCurrently
    a. VAT or sales tax:____________
    b. Excises and other indirect taxes:____________
    c. Personal and corporate income taxes:____________
    d. Other direct taxes:____________
    e. Social security contributions:____________
    f. Customs duties:____________
    g. Local taxes:____________
    7. Please indicate the number of taxpayers controlled by the LTU and the total taxpayer population by tax type:At introductionCurrently
    a. Number of large taxpayers in the LTU:2____________
    b. Total number of taxpayers in the general masterfile:3____________
    1. Total number of taxpayers in the VAT or sales tax masterfile:____________
    2. Total number of taxpayers in the Income Tax masterfile:____________
    8. Please place a check next to the criteria used to identify the large taxpayers:At introductionCurrently
    a. Amount of taxes paid during previous year/filing period(s):____________
    b. Annual turnover:____________
    c. Number of employees:____________
    d. Level of imports/exports:____________
    e. The taxpayer is a public enterprise/financial sector enterprise____________
    f. Other (please describe):____________
    9. Please indicate the LTU’s main functions:At introductionCurrently
    a. Full-fledged LTU (e.g., filing and payment, audit, collection enforcement, taxpayer services, updating register):____________
    b. Only accounting and collection functions:____________
    c. Only audit of large taxpayers:____________
    d. Only enforced collection:____________
    e. Other:____________
    10. Structure of LTU offices/branchesAt introductionCurrently
    a. There is a single LTU:____________
    b. There is a single LTU with branch offices (please specify the number of
    branch offices):____________
    c. There are multiple autonomous LTUs (please specify the number of
    autonomous LTUs):____________
    11. Please indicate the organizational structure of the LTU:At introductionCurrently
    a. Function-based (e.g., filing and payment, audit, enforcement):____________
    b. Tax-based (e.g., VAT. Income Tax. Excise Taxes, etc.):____________
    c. Combination function-based and tax-based:____________
    d. Is the organization different from that of other tax offices?____________
    (If yes, describe):
    e. Please provide organizational diagrams of the LTU and the tax administration.____________
    12. Supervision/reporting lines: (please place a check mark next to the item which best describes the situation in your country)At introductionCurrently
    a. There is a special headquarters unit in charge of supervising LTU operations:____________
    b. The LTU reports to the head of the tax administration:____________
    c. The LTU reports to both headquarters and to the local government:____________
    d. LTU branches report to the head of the central LTU:____________
    e. LTU branches report to their respective regional offices:____________
    f. Other (please specify):____________
    13. LTU staff salaries and benefits:At introductionCurrently
    a. Same as in other tax offices:____________
    b. Higher salaries/benefits (e.g., bonuses, etc.) compared to other tax offices (please indicate the difference in percent):____________
    14. Legal background:At introductionCurrently
    a. There are special provisions (laws, regulations, decrees) regarding LTU operations in the tax legislation:____________
    b. If answer to point a. above was yes, please describe:
    15. LTU Procedures: (please place a check mark next to the relevant procedures carried out by the LTU in your country)At introductionCurrently
    Collection procedures:
    a. Electronic filing through LTU and payment through banks____________
    b. Joint filing and payment through banks:____________
    c. Joint filing and payment through the LTU:____________
    d. Separate filing and payment (LTU office and banks):____________
    e. Payment is through an “in-house” bank located in LTU:____________
    Audit procedures:At introductionCurrently
    f. Comprehensive audits:____________
    g. Single-issue audits:____________
    h. Desk audits:____________
    i. Audit operations are structured around major industry segments:____________
    Collection enforcement procedures:
    j. Collection enforcement work is an integral part of the LTU s operations:____________
    k. If the answer to question j. is no, please specify: (e.g., another part of the
    tax administration or another government agency carries out this function)
    Taxpayer services:
    l. There are specialized taxpayer services for large taxpayers:____________
    m. Are any tax administration procedures different from those of other tax offices?
    If yes, please describe.
    16. Computer systems: (place a check mark next to the items that best describe the computer support systems in your LTU)At introductionCurrently
    a. There is an integrated computer system used to supervise large taxpayers’
    liabilities: 4____________
    b. There are separate computer modules (e.g., by tax and by function) used to
    supervise large taxpayers’ liabilities (please describe):
    c. The computer support system is identical to one used for other tax offices:____________
    d. Number of personal computers:____________
    e. There is no computer support of LTU operations (e.g., LTU procedures are manual):____________
    B. LTU Performance, 1995–99
    (Please provide statistics that are available for this period)

    Please place a check mark in the appropriate space, except where otherwise indicated.

    If there is more than one LTU, specify the number of large taxpayers monitored by all the LTU offices/branches.

    Refers to the total number of registered taxpayers, and not exclusively to the large taxpayers.

    E.g., the systems are integrated across taxes and across functions (taxpayer register, taxpayer masterfile, collection enforcement, audit).

    VAT stop-filers would be defined as those who did not submit VAT returns during two or more filing periods during one year.

    Performance Indicator19951996199719981999
    1. Number of large taxpayers
    2. Tax collection performance (in nominal terms)
    2.1. Total LTU collections (net of tax refund):
    2.2. Total domestic tax revenue collections (net of tax refunds).
    for all taxpayers:
    2.3. Amount of LTU arrears (at December 31 of each year):
    2.4. Amount of total domestic tax revenue arrears (at December 31
    of each year), for all taxpayers:
    3. Compliance performance
    3.1. Number of stop-filers with respect to the major taxes
    (VAT and Income Tax):5
    a. Number of large taxpayers who are stop-filers:
    b. Total number of stop-filers (refers to all registered taxpayers):
    3.2. Number of taxpayers in arrears:
    a. Number of large taxpayers in arrears:
    b. Total number of taxpayers in arrears (refers to all registered
    taxpayers):
    4. Audit performance
    LTU audit results (in nominal terms)
    4.1. Total amount of additional assessments resulting from audits
    4.2. Total amount of additional assessments which were actually
    collected
    4.3. Number of VAT audits carried out by the LTU (if possible,
    please indicate number of field audits, and number of desk audits)
    4.4. Number of other issue-oriented audits (e.g., wage withholding)
    carried out by the LTU
    4.5. Number of comprehensive audits carried out by the LTU
    5. VAT refund performance
    5.1. Amount of VAT refunds processed by the LTU (at December 31
    of each year)
    5.2. Amount of VAT refunds processed by the tax administration
    (at December 31 of each year)
    5.3. Amount of pending VAT refunds in LTU (at December 31 of
    each year)
    5.4. Amount of pending VAT refunds for all taxpayers (at December
    31 of each year)
    5.5. Number of VAT refunds processed by the LTU (at December 31
    of each year)
    5.6. Number of VAT refunds processed by the tax administration
    (at December 31 of each year)
    6. LTU resources
    6.1. LTU budget as a percent of total tax administration budget
    C. General Assessment of the LTU
    1. In your view, has the establishment of the LTU been successful in terms of improving the effectiveness of tax administration, revenue collection, and large taxpayers’ compliance (e.g., have procedures such as filing and payment, audit, collection enforcement, and taxpayer services improved)? Please provide concrete examples.
    2. If the answer to 1. is yes, how have these improvements been reflected in terms of improved compliance of the How would you evaluate the compliance of the large taxpayers compared with the compliance of the rest of the population? Please provide concrete examples.
    3. Please describe the main difficulties encountered in implementing the LTU (e.g., resource constraints, lack of legal authority, staffing problems, lack of high-level support, lack of sustainability of LTU, etc.)
    4. Please describe the main challenges ahead in ensuring the LTU operates as an effective and efficient part of the tax administration. What changes would you recommend in terms of the LTU’s (a) structure; (b) operational procedures?

    Please place a check mark in the appropriate space, except where otherwise indicated.

    If there is more than one LTU, specify the number of large taxpayers monitored by all the LTU offices/branches.

    Refers to the total number of registered taxpayers, and not exclusively to the large taxpayers.

    E.g., the systems are integrated across taxes and across functions (taxpayer register, taxpayer masterfile, collection enforcement, audit).

    VAT stop-filers would be defined as those who did not submit VAT returns during two or more filing periods during one year.

    References

      Australian Taxation Office,Commissioner of Taxation Annual Report, 1999–2000.Available via Internet: http://www.ato.gov.au

      Bodin, Jean-Paul,2000, “Implementing a LTU and Self-Assessment Procedures in Iran,”Fiscal Affairs Department (unpublished; Washington:International Monetary Fund).

      Dos Santos, Paulo,1994, “Administration of Large Taxpayers,”Fiscal Affairs Department (unpublished; Washington:International Monetary Fund).

      Ebrill, Liam, MichaelKeen, Jean-PaulBodin, and VictoriaSummers,2001, The Modern VAT (Washington:International Monetary Fund).

      New Zealand, Inland Revenue Department,Commissioner’s Annual Report 2000.Available via Internet: http://www.ird.govt.nz

      United Kingdom, H.M. Inland Revenue,Annual Report of the Commissioners,1998–2001.Available via Internet: http://www.inlandrevenue.gov.uk

      United States, Department of the Treasury, Internal Revenue Service,“Modernizing America’s Tax Agency,”Publication 3349 (Rev. 1–2000), Catalog Number 27171U.Available via Internet: http://www.irs.gov/pub/irs-pdf/p3349.pdf

      Vehorn, Charles L. and JohnBrondolo,1999, “Organizational Options for Tax Administration,Bulletin for International Fiscal Documentation,Vol. 53 (November), pp. 499512.

    Taxpayers that make significant tax payments and that account for a large percent of total tax collection–50 percent or more.

    Operations to control the compliance of the large taxpayers vary according to the type of organizational structure of each tax administration and may be referred to as large taxpayer units, large taxpayer departments (LTDs), large taxpayer offices (LTOs), and so forth.

    The effectiveness of tax administration is measured by the degree of taxpayers’ compliance with the tax laws (e.g., the tax administration’s capacity to enforce the tax laws), while efficiency reflects the actual costs of tax administration.

    If, for example, not all large taxpayers are administered by the LTU or system of LTUs, the LTU does not perform all major tax administration functions, the LTU lacks appropriate staffing or resources, and so forth.

    The United Kingdom has two separate tax administration departments, each with its own large taxpayer control operation. Her Majesty’s Customs and Excise (HMC&E) is responsible for administering the indirect taxes, and Inland Revenue (IR) administers the direct taxes, Each department has policy responsibility for its own tax work. Both HMC&E and Inland Revenue are non-ministerial government departments that report to HM treasury ministers.

    However, each of these groupings, or taxpayer segments, has continued to be functionally based.

    Includes about 30 developed and transition countries, and 7 developed countries.

    Appendix II contains a copy of the survey and a list of countries that responded to the survey. The list indicates the countries that provided complete responses, partial responses, or no response. Surveys were issued in English, French, Spanish, and Russian.

    In France, for example, 15,000 enterprises (0.1 percent of the total) reported 55 percent of the total turnover and 35 percent of the base for the corporate income tax in 1999. In Australia, for the 1998 income tax year, the 5 percent of companies that are covered by the LTU paid 74 percent of total corporate tax collection.

    “Joint filing and payment” refers to the simultaneous submission of tax returns and payment of taxes.

    A further change was made during 2000 to include individuals within the second segment. Return filing by individuals and wage earners was eliminated, removing the need for a separate segment.

    These countries include Benin, Bulgaria, Cameroon, Mexico, Moldova, Mongolia, the Philippines, Tajikistan, Togo, Uganda, and the Ukraine.

    A common IMF recommendation is that firms benefiting from tax holiday schemes also be monitored by the tax administration (they should submit tax returns showing their volume of sales or income, for example) to ensure they are complying with the conditions of the specific tax holiday program. This would also assist governments to identify the costs to revenue of tax holiday arrangements.

    Generally, the IMF recommends that countries use annual sales, rather than quarterly or semiannual sales, as the principal criterion for identifying large taxpayers, as seasonal fluctuations in sales lend to diminish over a 12-month period. This would prevent a situation in which taxpayers with high year-end sales would be categorized as large taxpayers simply because of the increase in one quarter’s economic activity.

    In several developed countries where specialized audit units for the large taxpayers were established in the 1970s and l980s (e.g., France, Spain), the trend is to broaden the mandate of the large taxpayer unit/operation to include more functions, creating a “full-service” unit (i.e., one that also monitors compliance with filing and payment obligations, enforces tax arrears, and provides taxpayer services).

    However, the criteria used to classify taxpayers by type in the Baltics and the CIS are different from those generally referred to in this paper, and usually consist of the following: state-owned enterprises, joint ventures, sole proprietorships and individuals, etc.

    Developed countries may not always have the equivalent of “full-service” LTUs, but this is because their tax administrations face different conditions from developing countries. In the case of modern tax administrations. (1) basic tax administration functions tend to be better integrated, making it easier for functional departments to support specialized large taxpayer operations. (2) computerized information systems are generally more flexible and integrated, and (3) there is a concern that functions could be duplicated, as large taxpayer compliance operations tend to depend on other departments of the tax administration for basic functions such as returns processing. For example, in the U.S., the Large and Mid-Size Business (LMSB) Division’s primary focus is audit, with increasing emphasis on prefiling services and outreach to taxpayers. The LMSB Division contracts out with other IRS divisions for collection, processing, and accounts management services.

    In many developing and transition countries, mailing the paper return to the LTU is not a good option, as the postal system is inefficient and the chances are high that the return will not arrive by the filing due date.

    The VAT is paid through the banks.

    The taxpayer current account is the record that shows the taxpayer’s liabilities and payments for all the taxes for which he is registered.

    By contrast, because developed country tax administrations tend to have more integrated operations and more complete and accurate information flows, requiring the large taxpayer to file returns through a specific office may not be so critical. In Australia, for example, most large taxpayers file their returns electronically. This information is then managed through the ATO’s “Small Business” segment, and reviewed by the Large Business and International (LB&I) segment.

    For example, in France and Australia, about 2 percent of taxpayers generate about 40 percent of the value of assessments raised after an audit.

    The actual audit coverage will vary depending on the number of auditors available to conduct audits, and other resources available to support audits. The audit coverage will also depend on the statute of limitations for audits: the shorter the statute of limitations, the higher the percent of tax payers that should be audited.

    Issue-oriented audits can be performed for the VAT (e.g., checking mark-up margins), excise taxes, and the CIT (e.g., the auditing of financial leases).

    In several developed countries (e.g., France, Japan, and the U.K.), the third level is a headquarters-based audit unit (staffed with highly skilled auditors), responsible for auditing large companies’ tax liabilities (including those of complex multinational corporations, and large companies with a number of subsidiaries).

    These recommendations are also valid for the tax administration as a whole, not only for the LTU.

    There may be other factors that have affected the reduction in tax arrears, including, for example, the arrears reduction program that was undertaken by the Hungarian tax administration (APEH) during the late 1990s. The APEH assigned, for a fee, the recovery of delinquent taxpayers’ assets to external companies that, due to their skills and proficiency in recovering outstanding debts, were able to collect the outstanding tax due more effectively. The result was a major reduction in the stock of outstanding tax arrears.

    The Australian Tax Office, the General Directorate for Tax and Customs Administration of the Netherlands, and the New Zealand Inland Revenue Department offer more beneficial salaries and/or benefits to staff who administer the largest taxpayers. Australian tax officials indicate that this is “by virtue of higher qualifications required to deal with the level of complexity of the large taxpayers,” and because these positions have a higher classification.

    These indicators reflect the answers provided by the countries in the LTU surveys, as well as the evaluation provided by IMF staff and experts who are familiar with LTUs in the different countries.

    The survey results are presented by Ebrill and others (2001).

    In some countries, under exceptional circumstances, another risk may be the personal security of LTU staff.

    This refers to cases in which the LTU has operated for only 6 to 12 months, a period considered too short to gauge the effectiveness of new systems and procedures.

    Large taxpayers’ tax arrears as a percent of taxes paid by the large taxpayers increased from 38 percent in 1997 to 379 percent in 1999.

    More recently, however, there has been progress on a number of fronts: an LTU structure was adopted that centralizes administration of all large taxpayers in one unit; the unit is now organized by functions, and training is envisaged to improve LTU staff skills in a number of specialized areas.

    However, the authorities have recently taken steps to introduce more systematic and transparent selection criteria.

    Some officials have indicated that lack of support for the LTU stems partly from the suspicion that it may facilitate corrupt practices among taxpayers and tax officials.

    The IMF has recently recommended establishment of an LTU in the Democratic Republic of Congo, Eritrea, and Ethiopia.

    The turnover threshold above which taxpayers are required to register for the VAT is similar to that used as a criterion for reporting to the LTU.

    In the early 1990s, a common feature of tax administration in French-speaking countries was the split of main functions between two separate agencies: the tax department responsible for assessment and audit, and the treasury, responsible for collection and enforced collection. Transferring the collection function to the tax department, beginning with a small number of large taxpayers, was therefore a critical step in improving tax administration in these countries.

    An excise taxpayer service (ETS), including the full range of tax administration functions, was created at the same time and for all intents and purposes, represented a parallel large taxpayer unit, albeit for excise taxpayers only. The ETS was abolished in November 2000 and its work incorporated into the LTS starting January 2001.

    The LTU collects the following taxes: CIT, PAYE, turnover tax, national security levy, and the Save the Nation contribution.

    There are four major groups of taxpayers in Argentina: (1) the largest taxpayers at the national level: (2) the medium-size taxpayers, which are the other taxpayers in the DOSMIL system; (3) the small taxpayers; and (4) the taxpayers in the simplified tax system (the monotributo system).

    For example, in response to the LTU survey, the tax administration authorities stated: “The establishment of the large taxpayer control system has contributed to improving the effectiveness of tax administration. The taxpayers that contribute the most (e.g., 50 percent) to total tax collection are now identified, the system allows the tax administration to monitor the large taxpayers in a specific and integrated manner, and the type of operations and the characteristics of the large taxpayers are well known. The system improves audit effectiveness because audits are grouped according to economic activity. There is also a more personalized service for the taxpayers.”

    There is one LTU in Bogotá, in other major cities a few tax officials at the local office level have been assigned to monitor the largest taxpayers in each region.

    The IMF provided technical assistance in the design of the overall tax administration reform strategy, as well as subsequent long-term assistance in the use of modern audit procedures, including the implementation of massive audit programs.

    In 1999, the national LTU administered about 2,400 taxpayers (about 13 percent of the total number of huge taxpayers), which accounted for about 65 percent of domestic tax collections.

    This has been facilitated by better prefiling advice to taxpayers and by simplified filing and payment procedures such as electronic filing, automatic bank debiting, and in-house bank branches.

    These include, for example, the rate of nonfilers and delinquent taxpayers, stock of tax arrears, audit coverage, audit productivity, timeliness of VAT refunds, and so forth.

    Then, again, in several countries large taxpayers have welcomed the establishment of an LTU as a way to increase the degree of transparency in tax administration, introduce greater standardization in the treatment of large taxpayers, and improve the quality of taxpayer services.

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