Abstract

The logic of the VAT requires that some taxpayers, particularly exporters, receive refunds. The practical problems this creates—often among the most troublesome that arise in implementing the VAT—are the topic of this chapter.

The logic of the VAT requires that some taxpayers, particularly exporters, receive refunds. The practical problems this creates—often among the most troublesome that arise in implementing the VAT—are the topic of this chapter.

Background

It is a key feature of the invoice-credit form of VAT that some businesses will pay more tax on their inputs than is due on their output, and so ought in principle to receive refunds. This will be true, in particular, of exporters (since their output is zero-rated, so long as the destination principle applies), and those whose investment purchases are large relative to their current sales (a group that may well include new enterprises). These are especially important groups in terms of wider economic development. Without effective treatment of excess credits, the VAT runs the risk of introducing significant and costly distortions for these groups.140 At the same time, however, the payment of refunds evidently can create lucrative opportunities for fraud and corruption. Moreover, financially strapped governments may be tempted to delay refunds for sheer need of cash. As discussed in the previous chapter, an effective refund system is also closely connected to the successful implementation of a comprehensive VAT audit program.

In principle, refunds should be paid promptly following the first VAT return after the excess credit arises, and should be paid irrespective of the nature of the enterprise or the circumstances giving rise to the credit. That is indeed typically the case in most developed countries: refunds are usually paid within about three to four weeks of the end of the taxable period. Many developing and transition economies, however, limit the entitlement to refunds. Hard information on this is sparse. Table 15.1 reports on practice in 27 survey countries and FAD advice on somewhat fewer. It should be noted, however, that the practice reported in this table is typically that laid down in law or regulation, which experience suggests can differ quite markedly from that actually implemented.

Table 15.1.

The Treatment of Excess Credits

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Source: IMF staff compilation.

Of which one refunded only after audit.

Clearly many countries focus their refund efforts on exporters. The means by which this is done vary. Nearly one-quarter of respondents give refunds to no other group. FAD has also advised in some cases (for example, Gabon) that imported foreign capital equipment be exempted for certain investors.

There is some evidence that FAD advice on refunds has become less “purist” in recent years: increasing awareness of the risks of fraud, particularly in transition countries, has led to a wider acceptance of departures from the theoretically ideal practice of immediate refunding. The results of the survey show that, in most developing countries, FAD now typically recommends limiting refunds of excess credit to exporters; other taxpayers are thus requested to carry forward their excess VAT credits during at least six months. While this approach is appropriate to deal with most taxpayers whose sales are made predominantly on the domestic market, there is no doubt that in a few cases this recommendation underestimates the difficulties faced by some enterprises with significant excess credits. This may be the case for major investments (with sometimes the business activity beginning several months after the investment is made) or in case of structural credit position due to a dual rate structure (outputs being taxed at the reduced rate while most inputs are taxed at the standard rate).

A critical aspect of the treatment of refunds is the overall VAT audit strategy, including the systems adopted to verify refund claims. Hard evidence is limited to relatively few countries. However, as discussed in the previous chapter, the general impression is that the lack of appropriate audit programs in many countries contributes to the ineffectiveness of the refund system, which relies heavily on extensive pre-refund checks prior to granting refunds rather than the selective post-refund strategy typically recommended by FAD.

A poor refund system can do significant harm. Failure fully to refund excess credits undermines the core principle of the VAT: intermediate transactions between firms should bear no final VAT burden. Such failure creates distortions that imply a real waste of resources: producers will substitute away from taxed inputs, and relative prices between sectors will be affected. The competitiveness of the export sector may be harmed, and the competitive edge tilted against new firms.

The Magnitude of the Issue

The refunds required under an invoice-credit VAT can be substantial, although the appropriate level of refunds will vary across countries according to their circumstances (see Box 15.1). In 1994–95, for instance, the United Kingdom collected over £68 billion in VAT payments and returned over £26 billion in refunds—that is, over 60 percent of net collections. While this is unusually high, reflecting the extensive zero-rating in the United Kingdom, refunds are extensive in many other countries too. In France, for example, VAT refunds amount to 40 percent of the net collections, while in Sweden they are nearly 80 percent; in Korea refunds run at around 50 percent of net VAT receipts.

Reasons for Failure and Possible Responses

Difficulties

While the appropriate treatment of excess credits in theory is clear—prompt refund—a number of obstacles to this arise in practice. Even when all parties are honest and capable, some transaction costs unavoidably imply some imperfection in the process. Three more considerations also arise.

Consider first the potential for fraud. The point is nicely put by Bird (1993), noting that a VAT is “… uniquely susceptible to fraud to the extent that a supplier’s invoice (or export certificate) in effect constitutes a check drawn on government [and so] inherently constitutes a tempting target for those who would loot the treasury.” By concealing sales to the domestic market, traders not only evade the requirement to charge tax on their output but, moreover, enable themselves to reclaim tax on their input. Overstatement of exports, sometimes with the support of falsified customs documents, can be a particularly attractive way to do this, in that it apparently explains the use that has been made of inputs. Of course, when refunds are restricted to exports, as is the case in a number of countries, it is precisely the assertion that items have been exported that is needed to open the possibility of refund. Temporary shell corporations, false export documentation with respect to actual production sold domestically, falsification of invoices, production and purchase records, and misreporting of prices are all used extensively to support claims of excess credits to be refunded. In the EU, for example, various types of fraud have developed under the VAT regime, with the more complex devices emerging with the recent elimination of the borders between EU members for the circulation of goods, persons, and funds. Other types of fraud have also developed in transition economies in central Europe. In this connection, the capacity of countries such as Poland and Hungary to develop effective VAT audit programs and control the movement of goods on their Eastern borders will clearly be a major challenge for their accession to the EU.

What Is a Reasonable Level of Refunds?

It is important for tax administrations to have a sense of the level of refunds they might reasonably expect to pay, both as a guide to the level of resources that the activity might require and as a warning signal of attempted fraud.

Broadly speaking, refunds as a proportion of (net) VAT revenues under a fully functioning, single-rate, invoice-credit VAT would be

αi+(1-λ)ze

where i and z denote respectively the shares of investment and zero-rated items (including exports) in GDP, α is the proportion of investment that generates excess credits (a quantity one would expect to be higher in faster-growing economies), λ the ratio of value added to sales in the zero-rated sector and e the efficiency ratio. Refunds will clearly be higher (a) in faster-growing economies (both because investment will be higher and more of it is likely to be by new firms with no output tax to take credit against), and (b) in more open economies.

The refunds required can quite plausibly be very large. Suppose, for example, that one is considering an economy in which the investment ratio is 10 percent, and exports account for 40 percent of GDP. Assuming that 5 percent of investment generates excess credits and that value added is 40 percent of sales in the export sector, achieving an efficiency ratio of 35 percent—around the average for a BRO country—will imply paying refunds equal to about 70 percent of net collections.

Second, the power to make refunds provides opportunities for corrupt practices by tax officials. Payment might be extracted in return for prompt provision (or overprovision) of refunds. Anecdotal evidence in some developing countries suggests that there are countries in which there is a widely known price for obtaining refunds of, say, 5 percent of the amount refunded. Customs officials might also connive in issuing false export documentation.

Short of outright corruption, moreover, the need for refunds creates scope for favoritism in the treatment of particular firms or sectors. There have been cases, for instance, in which complaints are voiced that domestic enterprises receive refunds more readily than foreign.

Third, particularly in transition countries with no history of voluntary tax compliance as well as in the many other countries that find themselves short of revenue, governments may find delaying the payment of refunds a tempting source of funds. By delaying payment, the government may be able to extract a forced interest-free loan from taxpayers.141 In some cases, such practices have resulted in a major reaction of the exporter community. In recent years, complicated exemption and zero-rating schemes applied to exporters and their suppliers (so called indirect exporters), have been implemented in a few developing countries (mainly in Asia), in an attempt to deal with cash flow problems resulting from excessively slow refund of excess VAT credits. Similar schemes also apply in some developed countries’ VAT systems (such as the Irish and the Netherlands VAT systems; see below). However, while EU countries can afford the administrative burden of such complex mechanisms, developing countries with weak administrative capacity clearly cannot. Indeed, in those developing countries, such schemes send the wrong message to the business community regarding governments’ commitment to simplifying and enforcing the tax system, with the immediate result of further degrading the design of the VAT and significantly complicating its operations.

Responses

Some of these difficulties evidently extend far beyond the context of VAT. Dealing with corruption, in particular, is a matter for wider civil service and other reforms. Within that wider setting, however, there are a number of approaches that might be taken to achieve an acceptably smooth system of refunds.

Offsetting excess VAT credits against VAT and other tax arrears

Some experts would argue that excess VAT credits (refunds) should never be offset against taxes other than future VAT liabilities, as is sometimes done. Such cross-offsetting would result in loss of control over data on taxpayers in all the affected taxes. This view may be excessively rigid for most developing and transition economies, where tax administrations have to cope with significant noncompliance problems, including, in many cases, substantial tax arrears. In these countries, the most common practice is to ensure that a taxpayer has no outstanding tax arrears (from VAT and other taxes) before processing VAT refunds.

Limiting entitlement to refunds

Scarce administrative capacity might be focused on the most important refund claims by simply denying some kinds of refund that, in principle, ought to be allowed. The simplest such rule is a de minimis requirement specifying an absolute amount, which must be exceeded before a refund is granted. This, however, will inevitably bear proportionately more heavily on small (perhaps new) firms rather than large.

A preferable approach would be to require excess credits to be carried forward for some specified time (three to six months, for example) and pay a refund only if they remain unrecovered. This is rough justice: a credit delayed is to some degree a credit denied. But it may be an acceptable means of excluding less important excess credit positions from the requirements for refund monitoring. In some contexts, tax administration may be so weak that even this exposes the revenue to too much risk. One might then require the indefinite carry forward of all excess VAT credits against future VAT liabilities.

Carry forward, however, is unlikely to prove satisfactory for exporters—who will find themselves permanently carrying forward unrelieved excess credits—or for firms that incur considerable costs prior to beginning operations. Even a requirement to carry forward for some fixed period effectively implies a charge equal to the interest foregone in deferring credit for the period of the carry forward, which can be a substantial sum.

Treatment of exporters

Many countries make special arrangements for exporters. These arrangements seek to ensure that exporters of good repute, at least, obtain prompt refund. This might involve a “gold card” scheme, for instance, under which exporters with good payment records obtain repayment within some specified period; silver card holders, and those in any lower groups, receive somewhat less prompt treatment. However, these schemes create their own difficulties and distortions. They create administrative complications in requiring some apportionment of credits for enterprises that both export and sell domestically. Moreover, schemes that offer beneficial treatment of those with established reputations inevitably disfavor firms that may be honest but are simply too new to have built up such a record; this, however, seems to be an inevitable consequence of the optimal audit strategy.

The refund processing system for exporters recommended by FAD is based on a few simple principles,142 namely:

  • distinguishing between refund claimants with a history of compliance and those claimants with poor or unknown compliance histories;

  • using pre-refund audits for high risk refund claims and postrefund audits for claims of lesser risk;

  • the application of criteria to determine the likely extent of revenue risk associated with each refund claim;

  • maintenance of historical profiles for each refund claimant; and

  • the performance of refund audits that focus only on verifying the facts of the refund claimed.

VAT excess credits related to import of capital goods

While recommendations regarding the prompt treatment of refunds in developing countries are usually targeted to exporters, efforts have also been made recently to better deal with excess credits due to large capital expenditures. VAT exemptions for investors who import large amounts of capital equipment have been limited to very few countries. Indeed, this practice may be easily abused and result in pressures to extend VAT exemptions to other imports. As described in Box 15.2, the development of a simple deferred-payment scheme for large amounts of imports of capital goods has recently been seen to be a more appropriate approach.

Audit strategy

A well-designed and executed audit strategy is critical to the construction of a smooth refund system. Many countries rely heavily on extensive pre-refund auditing, which is clearly a misuse of audit resources. In such cases, the vast majority of VAT audit resources are absorbed in the verification of VAT refunds as a result of the requirement that every claim be audited prior to approval. This preoccupation with the pre-refund audit of all claims leaves very few audit resources available to implement a comprehensive audit program. Even strong tax administrations would typically be unable to provide timely clearance of all refunds in this way.

Guidelines for a Deferral System for VAT on Imported Capital Goods

A deferral system for the VAT on imports should have the following characteristics:

  • The scheme should be limited to importers of large amounts of capital goods who are registered VAT taxpayers.

  • Capital goods, both imported and domestic, are subject to the standard rate VAT.

  • Imports of capital goods by persons who are not registered VAT taxpayers are subject to VAT at the time of import. VAT is paid, as usual, before the clearance of goods.

  • Importers of capital goods who are registered VAT taxpayers are permitted to defer accounting for the VAT until their next VAT return.

  • In this return, the value of the capital goods and the VAT applicable to those goods are reported as a VAT liability, and, in the same return, the appropriate VAT input tax credit is taken for the capital goods.

  • If the importer is entitled to 100 percent input tax credit (equipment used exclusively in taxable activities) the VAT applicable to the importation, reported as a liability, will be completely offset by the corresponding input credit.

  • The customs office is furnished a copy of the VAT return to close their records of the importation.

The strategy recommended by FAD envisages prerefund audits only for first and unusually large refund claims, with emphasis concentrated instead on selective post-refund audits. Claims for refunds in excess of a certain level should be subject to quick, issue-oriented refund audits. New Zealand, for example, assigns each taxpayer a limit below which refunds will be made automatically. However, insofar as they are known to taxpayers, such regularities in audit may facilitate some evasion devices; even dishonest taxpayers, for instance, will ensure that their first refund claim is accurate. “Gold card” schemes of the kind described above also provide an incentive to acquire a reputation for honest dealing, and then abuse it. This is clearly an area where all risks of fraud cannot be entirely eliminated—the success of any audit and refund programs depends on the capacity of the tax administration to adapt its methods and procedures to taxpayers’ changes of behavior (that is, they depend, ultimately, on the good judgment of experienced, skilled auditors).

To limit the risks of abuse, any refund system that limits pre-refund audits to a few cases—those with the highest risks for tax revenue—needs to be complemented by an effective audit program. This program needs to have a broad coverage and to include taxpayers for whom the refunds are usually processed without prerefund verifications. Information collected during these audits, especially data on refunds that were processed without pre-refund audits, are critical to updating taxpayers’ profiles and the criteria used for the processing of refunds.

Removing input tax on those likely to have excess credits

An alternative strategy is to remove the need for refunds altogether by eliminating tax on the inputs of enterprises most likely to run up excess credits. As mentioned above:

  • Certain countries effectively zero-rate supplies to exporters. In Ireland, for instance, those who export more than 75 percent of their output can obtain an authorization that enables their suppliers not to charge VAT. In Korea, those who supply exporters (referred to as “indirect exporters”) are zero-rated in respect of selected transactions if they can produce an authorized letter of credit relating to the final export.

  • A number of transition economies and some developing countries exempt from VAT the import of foreign capital equipment, at least by foreign investors. This precludes ensuring that the VAT is collected at the easiest point, import, but, in principle, achieves the same substantive result (assuming output tax is charged appropriately by the investor on later sales) as imposing the tax at the border, and crediting it and refunding excess credits in a timely manner.143

These devices, however, do break the VAT chain, and so significantly increase the complexity of the VAT, and, eventually, expose revenue to major risks.

  • If supplies to exporters are zero-rated, it becomes necessary to ensure that final output is not diverted to the domestic market tax-free. Moreover, if indirect exporters consequently find themselves in an excess credit position, the problem is merely shifted back one stage perhaps to even more enterprises, and ones typically harder to control. In Korea, extending the logic of effectively zero-rating indirect exporters has led to similar zero-rating, in some circumstances, for the second or third preexport stage, complicating control problems still further: indeed it has been suggested that these provisions underlie the high ratio of refunds to net receipts in Korea.

  • If exemption on capital purchases is to be granted only to foreign investors, it becomes necessary to guard against fraudulent shell corporations set up offshore by domestic persons to take advantage of the exemption. Breaking the chain in this way can also distort economic activity: exemption for capital goods imported by established foreign producers, for instance, distorts the system by lowering costs in those instances, relative to the use of domestically manufactured capital equipment, and relative to domestic owners. Extension of such import exemptions to eliminate the competitive distortion, or exemptions for all capital equipment purchases, simply extends the opportunities for fraud and abuse.

When tax administration is weak, breaking the chain in these ways is likely to be unduly risky. And when it is not weak, breaking the chain is unnecessary.

Conclusions

The refund system is one of the principal pressure points in the administration of the invoice-credit VAT. This is obviously an area in which tax policy advice has been strongly influenced by tax administration constraints over the past years, recognizing that implementation of best practices, including immediate refund of all VAT excess credits, was simply not possible in countries with weak administrative capacities.

In many developing and transition countries, the lack of effective audit programs is certainly a main factor explaining the difficulties faced in implementing sound collection procedures and effective refund systems, based on self-assessment principles. During the early part of the renewed spread of the VAT over the past ten years, it seems that technical assistance recommendations have been rather successful in dealing with the risks of weak collection procedures, especially when effective debt collection systems have been implemented for large taxpayers in an LTU. However, during the same period, it may be that the capacity of tax administrations to develop effective audit programs and, hence, to provide timely refunds without inviting excessive abuses has been overestimated.

In recent years, however, audit issues and refund problems have become a major concern in technical assistance work and this can be expected to continue. FAD’s current strategy to improve the operation of refunds is to limit entitlement to refunds, by ensuring prompt refunds to exporters (and, more recently, to enterprises importing large amounts of capital goods), while imposing some delays on others. This, however, does compromise the basic nature of the VAT, which requires that all excess credits be refunded without loss of value in order to avoid competitive distortion.

As discussed in Chapter 14, future improvements in current refund practices are subject to the development of appropriate audit strategies: better audit selection and methods, better coordination of income tax, VAT, and customs operations, increased training of auditors, and stronger tax administration management and supervision. However, this is an area in which achieving decisive progress is difficult, and refunds are likely to be a continuing concern in some developing countries and transition economies for some time. The difficulty of dealing with refunds has proved, to some degree, the Achilles’ heel of the VAT.

  • Ab Iorwerth, Aled, and John Whalley, 1998, “Meals on Wheels: Restaurant and Home Meal Production and the Exemption of Food from Sales and Value-Added Taxes,” NBER Working Paper 6653 (Cambridge, Massachusetts: National Bureau of Economic Research).

    • Search Google Scholar
    • Export Citation
  • Adams, Thomas S., 1921, “Fundamental Problems of Federal Income Taxation,” Quarterly Journal of Economics, Vol. 35 (No. 4), pp. 52756.

    • Search Google Scholar
    • Export Citation
  • Agha, Ali, and Jonathan Haughton, 1996, “Designing VAT Systems: Some Efficiency Considerations,” Review of Economics and Statistics, Vol. 78, pp. 30308.

    • Search Google Scholar
    • Export Citation
  • Alesina, Alberto, and Romain Wacziarg, 1998, “Openness, Country Size, and Government,” Journal of Public Economics, Vol. 69, pp. 30521.

    • Search Google Scholar
    • Export Citation
  • Atkinson, Anthony B., and Joseph E. Stiglitz, 1976, “The Design of Tax Structure: Direct Versus Indirect Taxation,” Journal of Public Economics, Vol. 6, pp. 5575.

    • Search Google Scholar
    • Export Citation
  • Atkinson, Anthony B., and Joseph E. Stiglitz, 1980, Lectures on Public Economics (London and New York: McGraw-Hill).

  • Auerbach, Alan, and L.J. Kotlikoff, 1987, Dynamic Fiscal Policy (Cambridge, U.K., and New York: Cambridge University Press).

  • Aujean, M., Peter Jenkins, and Satya Poddar, 1999, “A New Approach to Public Sector Bodies,” International VAT Monitor, Vol. 10 (No. 4), pp. 14449.

    • Search Google Scholar
    • Export Citation
  • Baer, Katherine, Victoria Summers, and Emil Sunley, 1996, “A Destination VAT for CIS Trade,” MOCT-MOST: Economic Policy in Transitional Economies, Vol. 6, pp. 87106.

    • Search Google Scholar
    • Export Citation
  • Ballard, Charles L., and John B. Shoven, 1987, “The Value-Added Tax: The Efficiency Cost of Achieving Progressivity by Using Exemptions,” in Modern Developments in Public Finance: Essays In Honor of Arnold Harberger, ed. by M. Boskin (New York and London: Blackwell).

    • Search Google Scholar
    • Export Citation
  • Besley, Timothy, and Ian Jewitt, 1995, “Uniform Taxation and Consumer Preferences,” Journal of Public Economics, Vol. 58, pp. 7384.

    • Search Google Scholar
    • Export Citation
  • Bird, Richard, M., 1993, “Review of ‘Principles and Practice of Value Added Taxation: Lessons for Developing Countries,’” Canadian Tax Journal, Vol. 41 (No. 6), pp. 122225.

    • Search Google Scholar
    • Export Citation
  • Bird, Richard, M., 1995, “Indirect Taxes in Belarus: VAT by Subtraction,” Tax Notes International, Vol. 10, pp. 58999.

  • Bird, Richard, M., 1999, “Rethinking Tax Assignment: The Need for Better Subnational Taxes” (unpublished; Toronto: University of Toronto).

    • Search Google Scholar
    • Export Citation
  • Bird, Richard, M., and Pierre Pascal Gendron, 1998, “Dual VATs and Cross-Border Trade: Two Problems, One Solution?” International Tax and Public Finance, Vol. 5, pp. 42942.

    • Search Google Scholar
    • Export Citation
  • Bird, Richard, M., and Pierre Pascal Gendron, 2000, “CVAT, VIVAT, and Dual VAT: Vertical ‘Sharing’ and Interstate Trade,” International Tax and Public Finance, Vol. 7 (No. 6), pp. 75361.

    • Search Google Scholar
    • Export Citation
  • Bird, Richard M., and Jack Mintz, 1999, “Tax Assignment in Canada: A Modest Proposal” (unpublished; Toronto: University of Toronto).

    • Search Google Scholar
    • Export Citation
  • Boadway, Robin, and Michael Keen, 2000, “Redistribution,” in Handbook of Income Distribution, ed. by A.B. Atkinson and F. Bourguignon (Amsterdam: North-Holland), pp. 677789.

    • Search Google Scholar
    • Export Citation
  • Bogetić, Zeljko, and Fareed M.A. Hassan, 1993, “Determinants of Value-Added Tax Revenue: A Cross-Section Analysis,” World Bank Policy Research Discussion Paper WPS 1203 (Washington: World Bank).

    • Search Google Scholar
    • Export Citation
  • Bogetić, Zeljko, and Fareed M.A. Hassan, 1995, “Explaining the Revenue Potential of VAT,” Tax Notes International, Vol. 10, pp. 104346.

    • Search Google Scholar
    • Export Citation
  • Bovenberg, A. Lans, 1987, “Indirect Taxation in Developing Countries: A General Equilibrium Approach” Staff Papers, International Monetary Fund, Vol. 34, pp. 33373.

    • Search Google Scholar
    • Export Citation
  • Bovenberg, A. Lans, 1994, “Destination- and Origin-based Taxation Under International Capital Mobility,” International Tax and Public Finance, Vol. 1, pp. 24773.

    • Search Google Scholar
    • Export Citation
  • Brealey, Mark, and C. Quigley, eds., 1992, Completing the Internal Market of the European Community (Luxembourg: Office for Official Publications of the European Communities).

    • Search Google Scholar
    • Export Citation
  • Cecchini, P., with M. Catinat and A. Jacquemin, 1988, The European Challenge, 1992: The Benefits of a Single Market (Brookfield, Vermont: Wildwood House).

    • Search Google Scholar
    • Export Citation
  • Cnossen, Sijbren, 1987, “VAT and RST: A Comparison,” Canadian Tax Journal, Vol. 35 (No. 3), pp. 559615.

  • Cnossen, Sijbren, 1991, “Design of the Value-Added Tax: Lessons from Experience,” in Tax Policy in Developing Countries, d. by J. Khalilzadeh-Shirazi and Anwar Shah (Washington: World Bank), pp. 7285.

    • Search Google Scholar
    • Export Citation
  • Cnossen, Sijbren, 1993, “Issues in Adopting and Designing a Value-Added Tax,” in Key Issues in Tax Reform, ed. by C. Sandford (Bath, U.K.: Fiscal Publications), pp. 73107.

    • Search Google Scholar
    • Export Citation
  • Cnossen, Sijbren, 1994, “Administrative and Compliance Costs of the VAT: A Review of the Evidence,” Tax Notes, Vol. 63, pp. 160926.

    • Search Google Scholar
    • Export Citation
  • Cnossen, Sijbren, 1995, “VAT Treatment of Immovable Property,” Tax Notes International, Vol. 10, pp. 103742.

  • Cnossen, Sijbren, 1998, “Global Trends and Issues in Value-Added Taxation,” International Tax and Public Finance, Vol. 5, pp. 399428.

    • Search Google Scholar
    • Export Citation
  • Cnossen, Sijbren, and Carl S. Shoup, 1987, “Coordination of Value-Added Taxes,” in Tax Coordination in the European Community, ed. by Sijbren Cnossen (Deventer, Netherlands: Kluwer Law and Taxation), pp. 5984.

    • Search Google Scholar
    • Export Citation
  • Cockfield, Roger, 1997, “A VAT Suspension Regime,” International VAT Monitor, Vol. 8 (No. 3), pp. 11119.

  • Conrad, Robert F., 1990, “Real estate and the VAT” in Value Added Taxation in Developing Countries, ed. by Malcolm Gillis, Carl S. Shoup, and Gerardo Sicat (Washington: World Bank), pp. 95103.

    • Search Google Scholar
    • Export Citation
  • Das-Gupta, Arindam, and Ira N. Gang, 1996, “A Comparison of Sales Taxes,” Public Finance, Vol. 51, pp. 21725.

  • De Wit, Guido, 1995, “The European VAT Experience,” Tax Notes International, Vol. 10, 4954.

  • Deaton, Angus, and Nicholas H. Stern, 1986, “Optimally Uniform Commodity Taxes, Taste Difference, and Lump-Sum Grants,” Economics Letters, Vol. 20 (No. 3), pp. 26366.

    • Search Google Scholar
    • Export Citation
  • Diamond, Peter, and James Mirrlees, 1971, “Optimal Taxation and Public Production I: Production Efficiency,” American Economic Review, Vol. 61 (No. 1), pp. 827.

    • Search Google Scholar
    • Export Citation
  • Due, John F., 1957, Sales Taxation (Urbana, Illinois: University of Illinois Press).

  • Due, John F., 1990, “VAT Treatment of Farmers and Small Firms,” in Value-Added Taxation in Developing Countries, ed. by M. Gillis, C. C. Shoup, and G. Sicat (Washington: World Bank), pp. 5869.

    • Search Google Scholar
    • Export Citation
  • Edwards, Jeremy S.S., Michael J. Keen, and Matti Tuomala, 1994, “Income Tax, Commodity Taxes, and Public Good Provision: A Brief Guide,” Finanzarchiv, Vol. 51 (No. 4), pp. 47287.

    • Search Google Scholar
    • Export Citation
  • European Commission, 1985, Completing the Internal Market (Luxembourg: Office for Official Publications of the European Communities).

  • European Commission, 1996, A Common System of VAT: A Programme for the Single Market, COM 328(96), Final (Brussels).

  • European Commission, 1998, “Proposal for a Council Directive Amending Directive 77/388/EEC as Regards the Rules Governing the Right to Deduct Value-Added Tax,” COM (98) 377, Final (Brussels).

    • Search Google Scholar
    • Export Citation
  • European Commission, 1999, “Indirect Taxes and e-commerce,” Working Paper, DGXII (Brussels).

  • European Commission, undated, Value-Added Tax: A Study of the Methods of Taxing Financial Institutions (Brussels).

  • Fitzgerald, J.D., T. Quinn, B. Whelan, and J. Williams, 1988, An Analysis of Cross-Border Shopping, Paper 137 (Dublin: Economic and Social Research Institute).

    • Search Google Scholar
    • Export Citation
  • Fratianni, Michele, and Herbert Christie, 1981, “Abolishing Fiscal Frontiers Within the EEC,” Public Finance, Vol. 36, pp. 41129.

    • Search Google Scholar
    • Export Citation
  • Gale, William G., and Janet Holtzblatt, 2000, “The Role of Administrative Issues in Tax Reform: Simplicity, Compliance, and Administration,” forthcoming in George R. Zodrow and Peter Mieszkowski, eds., United States Tax Reform in the Twenty-First Century (Cambridge: Cambridge University Press).

    • Search Google Scholar
    • Export Citation
  • Genser, Bernd, 1996, “A Generalized Equivalence Property of Mixed International VAT Regimes,” Scandinavian Journal of Economics, Vol. 98, pp. 25362.

    • Search Google Scholar
    • Export Citation
  • Genser, Bernd, and Günter Schultze, 1997, “Transfer Pricing Under an Origin-Based VAT System,” Finanzarchiv, Vol. 54, pp. 5167.

  • Ghura, Dhaneshwar, 1998, “Determinants of Tax Revenue in Sub-Saharan Africa” (unpublished; Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Gillis, Malcolm, Carl S. Shoup, and Gerardo Sicat, 1990, Value-Added Taxation in Developing Countries (Washington: World Bank).

  • Godwin, Michael, 1998, “The VAT Registration Threshold,” British Tax Review, No. 6, pp. 54145.

  • Gottfried, Peter, and Wolfgang Wiegard, 1991, “Exemption Versus Zero Rating: A Hidden Problem of VAT,” Journal of Public Economics, Vol. 46, pp. 30728.

    • Search Google Scholar
    • Export Citation
  • Guerard, Michèle, 1973, “The Brazilian State Value-Added Tax,” Staff Papers, International Monetary Fund, Vol. 20, pp. 11869.

  • Hall, Robert E., and Alvin Rabushka, 1995, The Flat Tax (California: Hoover Institution Press, 2nd ed.).

  • Hemming, Richard, and John A. Kay, 1981, “The United Kingdom,” in The Value-Added Tax: Lessons from Europe, ed. by Henry J. Aaron (Washington: Brookings Institution), pp. 7589.

    • Search Google Scholar
    • Export Citation
  • Hossain, Shahabuddin M., 1995, “The Equity Impact of the Value-Added Tax in Bangladesh,” Staff Papers, International Monetary Fund, Vol. 42, pp. 41130.

    • Search Google Scholar
    • Export Citation
  • Jenkins, Glenn P., and Rup Khadka, 1997, “Value-Added Tax Policy and Implementation in Singapore,” International VAT Monitor, Vol. 9, pp. 3547.

    • Search Google Scholar
    • Export Citation
  • Kay, John A., 1980, “The Deadweight Loss from a Tax System,” Journal of Public Economics, Vol. 13, pp. 11119.

  • Kay, John A., and Evan Davis, 1985, “Extending the VAT Base: Problems and Possibilities,” Fiscal Studies, Vol. 6 (No. 1), pp. 116.

    • Search Google Scholar
    • Export Citation
  • Kay, John A., and Evan Davis, 1990, “The VAT and Services,” in Value Added Taxation in Developing Countries, ed. by Malcolm Gillis, Carl S. Shoup, and Gerardo C. Sicat (Washington: The World Bank), pp. 7081.

    • Search Google Scholar
    • Export Citation
  • Kay, John A., and Neil Warren, 1980, “Effective Rates of Value-Added Tax,” Working Paper 16 (London: Institute for Fiscal Studies).

  • Keen, Michael, 2000, “CVAT, VIVAT, and All That: New Forms of VAT for Federal Systems,” Canadian Tax Journal, Vol. 48 (No.2), pp. 40924.

    • Search Google Scholar
    • Export Citation
  • Keen, Michael, and Sajal Lahiri, 1998, “The Comparison Between Destination and Origin Principles Under Imperfect Competition,” Journal of International Economics, Vol. 45 (No. 2), pp. 32350.

    • Search Google Scholar
    • Export Citation
  • Keen, Michael, and Jenny Ligthart, 1999, “Coordinating Tariff Reduction and Domestic Tax Reform,” IMF Working Paper 99/93 (Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Keen, Michael, and Jack Mintz, 1998, “The Optimal Threshold for a Value-Added Tax” forthcoming in the Journal of Public Economics.

  • Keen, Michael, and Stephen Smith, 1996, The Future of Value Added Tax in the European Union,” Economic Policy (October 23), pp. 375411 and 41920.

    • Search Google Scholar
    • Export Citation
  • Keen, Michael, and Stephen Smith, 2000, “Viva VIVAT!”, International Tax and Public Finance, Vol. 7, (No. 6), pp. 74151.

  • Keen, Michael, and David Wildasin, 2000, “Pareto Efficiency in International Taxation” (unpublished; Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Kenyon, Daphne A., 1996, “A New State VAT? Lessons from New Hampshire,” National Tax Journal, Vol. 49, pp. 38199.

  • Kortenaar, G., and Chr. Spanjersberg, 1999, “Taxation and e-Commerce: Dutch Tax Policy Implications,” Intertax, Vol. 27, pp. 18087.

    • Search Google Scholar
    • Export Citation
  • Kotlikoff, Laurence J., and Lawrence H. Summers, 1985, “Tax Incidence,” in Handbook of Public Economics, ed. by M.S. Feldstein and A. Auerbach (Amsterdam: North-Holland), pp. 104392.

    • Search Google Scholar
    • Export Citation
  • Lahiri, S., and Y. Ono, 1988, “Helping Minor Firms Reduce Welfare,” Economic Journal, Vol. 98, pp. 11991202.

  • Lauré, Maurice, 1953, La Taxe à la Valeur Ajoutée (Paris: Librairie du Receuil Sirey, 2nd ed.).

  • Lauré, Maurice, 1957, Au Secours de la TVA (Paris, Presses Universitaires de France).

  • Lee, Catherine, Mark Pearson, and Stephen Smith, 1988, Fiscal Harmonization: An Analysis of the Commission’s Proposals, IFS Report Series, No. 28 (London: Institute for Fiscal Studies).

    • Search Google Scholar
    • Export Citation
  • Lent, George E., Milka Casanegra, and Michèle Guerard, 1973, “The Value-Added Tax in Developing Countries,” Staff Papers, International Monetary Fund, Vol. 20, pp. 31878.

    • Search Google Scholar
    • Export Citation
  • Leuthold, Jane H., 1991, “Tax Shares in Developing Economies: A Panel Study,” Journal of Development Economics, Vol. 35, pp. 17385.

    • Search Google Scholar
    • Export Citation
  • Liberati, Paolo, 2001, “The Distributional Effects of Indirect Tax Changes in Italy,” International Tax and Public Finance, Vol. 8, (No. 1), pp. 2751.

    • Search Google Scholar
    • Export Citation
  • Lockwood, Ben, 1993, “Commodity Tax Competition Under Destination and Origin Principles,” Journal of Public Economics, Vol. 52, pp. 14162.

    • Search Google Scholar
    • Export Citation
  • Lockwood, Ben, David de Meza, and Gareth Myles, 1994, “When Are Destination and Origin Regimes Equivalent?” International Tax and Public Finance, Vol. 1, pp. 524.

    • Search Google Scholar
    • Export Citation
  • Longo, Carlos, 1991, “The VAT in Brazil,” in Tax Policy in Developing Countries, ed. by J. Khalilzadeh-Shirazi and A. Shah (Washington: World Bank), pp. 12128.

    • Search Google Scholar
    • Export Citation
  • Marchand, Maurice, Mario Nava, and Fred Schroyen, 1996, “Optimal Fiscal and Public Expenditure Policy in a Two-Class Economy,” Journal of Public Economics, Vol. 61 (No. 1), pp. 11937.

    • Search Google Scholar
    • Export Citation
  • McLure, Charles E., Jr., 1987, The Value-Added Tax: Key to Deficit Reduction? (Washington: American Enterprise Institute).

  • McLure, Charles E., Jr., 1999, “Electronic Commerce and the State Retail Sales Tax: A Challenge to American Federalism,” International Tax and Public Finance, Vol. 6, pp. 193224.

    • Search Google Scholar
    • Export Citation
  • McLure, Charles E., Jr., 2000, “Implementing Sub-National Value-Added Taxes on Internal Trade: The Compensating VAT (CVAT), International Tax and Public Finance, Vol. 7 (No. 6), pp. 72340.

    • Search Google Scholar
    • Export Citation
  • Messere, Ken, 1994, “Consumption Tax Rules,” Bulletin for International Fiscal Documentation, Vol. 48, pp. 66581.

  • Mintz, Jack, 1995, “Business Transfer Tax as a Consumption Tax,” Tax Notes International, Vol. 10, pp. 7586.

  • Nellor, David, 1987, “The Effect of Value-Added Tax on the Tax Ratio,” IMF Working Paper 87/47 (Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Newbery, David, 1986, “On the Desirability of Input Taxes,” Economics Letters, Vol. 20 (No. 3), pp. 26770.

  • New Zealand, Inland Revenue Department, 1999, GST: A Review (Wellington, New Zealand).

  • OECD, 1988, Taxing Consumption (Paris: OECD).

  • OECD, 2001, Taxation and Electronic Commerce: Implementing the Ottawa Taxation Framework Conditions (Paris: OECD).

  • Ogley, Adrian, 1997, “VAT and Telecommunications Services in the European Union,” Tax Notes International, Vol. 14, pp. 115562.

  • Ogley, Adrian, 1998, Principles of Value-Added Tax: A European Perspective (London: Interfisc).

  • Oldman, Oliver, and Alan Schenk, 1995, “The Business Activities Tax: Have Senators Danforth and Boren Discovered a Better Value-Added Tax?” Tax Notes International, Vol. 10, pp. 5574.

    • Search Google Scholar
    • Export Citation
  • Pellechio, Anthony J., and Catherine B. Hill, 1996, “Equivalence of the Production and Consumption Methods of Calculating the Value-Added Tax: Application to Zambia,” IMF Working Paper 96/67 (Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Piggott, John, and John Whalley, 1998, “VAT Base Broadening, Self-Supply, and the Informal Sector,” NBER Working Paper 6349 (Cambridge, Massachusetts: National Bureau of Economic Research).

    • Search Google Scholar
    • Export Citation
  • Poddar, Satya, and Morley English, 1997, “Taxation of Financial Services Under a Value-Added Tax: Applying the Cash-Flow Method,” National Tax Journal, Vol. 50, pp. 89111.

    • Search Google Scholar
    • Export Citation
  • Poterba, James, 1989, “Lifetime Incidence and the Distributional Burden of Excise Taxes,” American Economic Review, Vol. 79 (No. 2) pp. 32530.

    • Search Google Scholar
    • Export Citation
  • Rainer, Anno, and Danny Claeys, 1997, “European Commission Proposes VAT Regime for Telecommunication Services,” Tax Notes International, Vol. 14, pp. 54750.

    • Search Google Scholar
    • Export Citation
  • Ring, Raymond J., Jr., 1989, “Proportion of Consumers’ and Producers’ Goods in the General Sales Tax,” National Tax Journal, Vol. 42, pp. 16779.

    • Search Google Scholar
    • Export Citation
  • Rodrik, Dani, 1998, “Why Do More Open Economies Have Bigger Governments?” Journal of Political Economy, Vol. 106, pp. 9971032.

  • Sah, Raaj K., 1983, “How Much Redistribution Is Possible through Commodity Taxes?” Journal of Public Economics, Vol. 20 (No. 1), pp. 89101.

    • Search Google Scholar
    • Export Citation
  • Schenk, Alan, and Howell H. Zee, 2001, “Treating Financial Services Under a Value-Added Tax: Conceptual Issues and Country Practices,” Tax Notes International, pp. 330916.

    • Search Google Scholar
    • Export Citation
  • Shoup, Carl S., 1973, The Value-Added Tax (Athens, Greece: Center of Planning and Economic Research).

  • Shoup, Carl S., 1990, “Choosing Among Types of VAT,” in Value-Added Taxation in Developing Countries, ed. by Malcolm Gillis, Carl S. Shoup, and Gerardo P. Sicat (Washington: World Bank), pp. 316.

    • Search Google Scholar
    • Export Citation
  • Silvani, Carlos, and Katherine Baer, 1997, “Designing a Tax Administration Reform Strategy: Experiences and Guidelines,” IMF Working Paper 97/30 (Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Silvani, Carlos, and Katherine Baer, 1993, “An Analysis of VAT Compliance” (unpublished; Washington: International Monetary Fund).

  • Silvani, Carlos, and Katherine Baer, 1996, “Selected Issues in Administering the VAT: Cross-Checking Invoices and Controlling Refunds to Exporters” (unpublished; Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Silvani, Carlos, Katherine Baer, and John Brondolo, 1996, “Selected Issues in Administering the VAT: Cross-Checking Invoices and Controlling Refunds to Exporters” (mimeo; Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Silvani, Carlos, and Richard Fulford, 1995, “Administration of the VAT in the Russian Federation—Self-Assessment of Tax Liabilities” (Vienna: Joint Vienna Institute).

    • Search Google Scholar
    • Export Citation
  • Södersten, Jan, 1999, “Why Europe Adopted the Value-Added Tax” (unpublished; Uppsala, Sweden: Uppsala University).

  • Stockfisch, J.A., 1985, “Value-Added Taxes and the Size of Government: Some Evidence,” National Tax Journal, Vol. 38 (No. 4), pp. 54752.

    • Search Google Scholar
    • Export Citation
  • Stotsky, Janet, and Asegedech WoldeMariam, 1997, “Tax Effort in Sub-Saharan Africa,” IMF Working Paper 97/107 (Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Strachan, Valerie, 1998, “Twenty-Five Years of VAT,” British Tax Review, No. 6, pp. 54751.

  • Sullivan, Clara K., 1965, The Tax on Value-Added (New York: Columbia University Press).

  • Summers, Victoria P., and Emil M. Sunley, 1995, “An Analysis of Value-Added Taxes in Russia and Other Countries of the Former Soviet Union,” Tax Notes International, Vol. 10, pp. 204972.

    • Search Google Scholar
    • Export Citation
  • Tait, Alan A., 1988, The Value-Added Tax: International Practice and Problems (Washington: International Monetary Fund).

  • Tait, Alan A., ed., 1991, Value-Added Tax: Administrative and Policy Issues, IMF Occasional Paper No. 88 (Washington: International Monetary Fund).

    • Search Google Scholar
    • Export Citation
  • Tanzi, Vito, 1987, “Quantitative Characteristics of the Tax Systems of Developing Countries,” in The Theory of Taxation for Developing Countries, ed. by D. Newbery and N. Stern (Oxford: Oxford University Press), pp. 20541.

    • Search Google Scholar
    • Export Citation
  • Tanzi, Vito, 1992, “Structural Factors and Tax Revenue in Developing Countries: A Decade of Evidence,” in Open Economies: Structural Adjustment and Agriculture, ed. by I. Goldin and A.L. Winters (Cambridge, U.K., and New York: Cambridge University Press), pp. 20541.

    • Search Google Scholar
    • Export Citation
  • Tanzi, Vito, 1995, Taxation in an Integrating World (Washington: Brookings Institution).

  • Terkper, Seth A., 1995, “Defending the VAT in Africa,” Tax Notes International, Vol. 11, pp. 131319.

  • Terkper, Seth A., 1996, “VAT in Ghana: Why It Failed,” Tax Notes International, Vol. 12, pp. 180116.

  • United Kingdom, National Audit Office, 1994, “H.M. Customs and Excise: Cost to Business of Complying with VAT Requirements” (London: Her Majesty’s Stationery Office).

    • Search Google Scholar
    • Export Citation
  • Varsano, Ricardo, 1999, “Subnational Taxation and the Treatment of Interstate Trade in Brazil: Problems and a Proposed Solution.” forthcoming in S. J. Burki and G. Peary, eds., Decentralization and Accountability of the Public Sector, Proceedings of the Annual Bank Conference on Development in Latin America and the Caribbean (Washington: World Bank).

    • Search Google Scholar
    • Export Citation
  • Wildasin, David, 1977, “Production Efficiency in Tax-Distorted Economies with Multiple Revenue Constraints” (unpublished; University of Illinois).

    • Search Google Scholar
    • Export Citation
  • Williams, David, 1996, “Value-Added Tax,” in Tax Law Design and Drafting, ed. by Victor Thuronyi (Washington: International Monetary Fund), pp. 164230.

    • Search Google Scholar
    • Export Citation
  • Younger, Stephen D., and David E. Sahn, 1998, “Fiscal Incidence in Africa: Microeconomic Evidence,” Cornell Food and Nutrition Policy Program Working Paper 91 (Ithaca, New York: Cornell University).

    • Search Google Scholar
    • Export Citation
  • Younger, Stephen D., David E. Sahn, David Sahn, Steven Haggblade, and Paul A. Dorosh, 1999, “Tax Incidence in Madagascar: An Analysis Using Household Data,” World Bank Economic Review, Vol. 13, pp. 30331.

    • Search Google Scholar
    • Export Citation
  • Zee, Howell, 1995, “Value-Added Tax,” in Tax Policy Handbook, ed. by Parthasarathi Shome (Washington: International Monetary Fund), pp. 8699.

    • Search Google Scholar
    • Export Citation
  • Zodrow, George R., 1999, “The Sales Tax, the VAT, and Taxes in Between—Or, Is the Only Good NRST a ‘VAT in Drag’?” National Tax Journal, Vol. 52, pp. 42942.

    • Search Google Scholar
    • Export Citation