Cambodia: Selected Issues

This Selected Issues paper for Cambodia explores the implications for long-term sustainable growth from cross-country analysis of the sources of growth. Cambodia’s low labor productivity, inadequate and expensive infrastructure, and a cumbersome regulatory environment do not bode well for future sustainable growth. Favorable external conditions, including foreign aid flows and trade agreements, have helped propel growth. As with other transition economies, Cambodia lags in institutional and market development. Cambodia has also benefited from large aid inflows, which have boosted economic activity.

Abstract

This Selected Issues paper for Cambodia explores the implications for long-term sustainable growth from cross-country analysis of the sources of growth. Cambodia’s low labor productivity, inadequate and expensive infrastructure, and a cumbersome regulatory environment do not bode well for future sustainable growth. Favorable external conditions, including foreign aid flows and trade agreements, have helped propel growth. As with other transition economies, Cambodia lags in institutional and market development. Cambodia has also benefited from large aid inflows, which have boosted economic activity.

Chapter 10. Cambodia: Taxation of Petroleum Products66

131. This chapter provides an estimate of the potential revenue loss from petroleum smuggling. Section A presents some key facts. Section B provides estimates of domestic demand for gasoline and diesel, on which, in section C, foregone tax revenue from smuggling is estimated—over 1½ percent of GDP in 2003. Section D examines underlying incentives for smuggling.67

A. Imports, Pricing, and Taxation since 1994

Petroleum is an important source of revenue

132. Petroleum taxes account for about one fifth of total revenue. Total government revenue averaged about 11 percent of GDP in the last three years, and petroleum taxes amounted to over 2 percent of GDP. Taxes are collected through import duties, excise, and VAT, as well as an “additional tax”, which was introduced in 2002. The share of petroleum taxes in total revenue has, however, varied over the years. At the lowest points in 1994 and in 1999, petroleum taxes amounted to less than one tenth of total revenue. Fortunately, total revenue collection did not fall proportionately, which seems to indicate that the revenue authorities had substantial leeway in relying on different revenue sources to compensate for those shortfalls.

A10ufig01

Petroleum Taxes and Total Revenue, 1994–2003

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

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Tax Collection on Petroleum Products

(In billion of riel)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

Source: Customs and Excise Departmant

133. Gasoline and diesel are the two main sources of petroleum taxes. Revenue from gasoline and diesel each amounted to 0.8 percent and 1.3 percent of GDP in 2003. Revenue from other petroleum products remains very small. Although the quantities of kerosene and fuel oil imports are quite large, they are subject to considerably lower taxes as discussed further below.

Quantities of imported petroleum products

134. Officially recorded petroleum imports nearly doubled between 1994 and 2003. Their volume increased by an average 9½ percent annually during the period, compared to 6½ percent real GDP growth.68 Diesel imports grew by 13½ percent annually, but have declined from their peak in 2001. Kerosene and fuel oil imports rose by an average of 20 percent annually.

A10ufig03

Petroleum Imports, 1994–20031

(In ’000 tons)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

Source: Customs and Excise Departmant.1 Includes duty-exempt imports.

135. Only gasoline imports declined by 20 percent over the period. Between 1994 and 2003, gasoline imports declined on average by 2 percent a year. This decline is inconsistent with the pace of overall economic growth and the rapid rise in the number of cars as well as substantial increase in road construction and rehabilitation. The National Institute of Statistics (NIS) data report an annual average increase of 5 percent in passenger cars during the same period.

136. The decline in officially reported gasoline imports suggests that growing domestic demand has been met through increased smuggling. Smuggling is alleged to take place through the customs posts via mis-invoicing (declaring gasoline to be kerosene to avoid higher taxes), under-invoicing, and false claims of exemptions. Smuggling is believed to be carried out by both small and large operators. Small operators carry 30 liter “bidon’ containers across the border on bicycles or in carts. According to some reports, some large operators are evading customs officers and selling their gasoline through gas stations alongside tax-paid gasoline.

Several changes to the tax regime

137. Tax rates have been raised or adjusted a number of times since 1994.69 In 1994, an import duty tariff, a consumption tax, and a military tax were levied on petroleum products that cumulatively amounted to 52 percent of the gasoline price (see Annex Table 1). Rates have risen considerably since then: excises were introduced on gasoline in 1995 and a number of changes adopted in subsequent years. For gasoline, the import duty was raised from 45 percent to 50 percent in 1995 and then reduced to 35 percent on July 1, 2001. The 4 percent consumption tax was converted into a VAT at 10 percent in 1999, and was levied on import values inclusive of import duty and excises. The conversion of the consumption tax to a VAT provided relief to exporting firms who were eligible for a refund. The excise on gasoline products was raised in 2001 to compensate for the reduction in the import duty. A similar pattern was followed for diesel on which import duties were reduced in July 2001 and, to compensate, the excise was raised. Only VAT was levied on kerosene until 2004 when an import duty and excise were introduced.70

138. An additional tax burden arises whenever the reference price is higher than the actual import price. Since 1994, taxes are levied on an administrative reference price. Only since 2004 has the market price been higher than the reference price. But most of the times, the reference price was higher than the world price.

139. As a result, the statutory tax rate has been high, particularly for gasoline. The statutory tax rate, including the impact of the higher reference price, has been as high as 189 percent in 1998 when world prices were at a low point. In the case of diesel, the highest tax rate was 62 percent in 2002 and kerosene, currently at 19 percent, is at the highest point (Table 2). Currently, the statutory tax rate for gasoline is about double that of diesel.

A10ufig04

Comparison of Gasoline Reference Price Used by CED and World Average Price

(US$ per ton)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

Tax collections compared to taxes due

140. Tax collections have fallen short even of taxes due based on reported imports prior to 2000.71 During 2001–03, tax collections had become more in line with taxes due suggesting improved tax effort that reduced tax evasion.72 However, the difference was large in 1998–99 when nearly two thirds of taxes due on reported imports were not collected. The difference between taxes due and taxes collected also matters when estimating the distributor’s margin, as seen below.

Table 1.

Total Statutory Taxes

(as percent of reference/market price)

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Table 2.

Effective Tax Rate and Revenue Shortfall

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Fuel Oil Imports

141. Fuel oil imports have increased on average by 22 percent annually since 1995, but they do not contribute much to taxes. In 2003, fuel oil imports amounted to 72,000 tons, or one fifth of total petroleum imports. However, its contribution to tax collection has been negligible as the statutory tax rate is about 10 percent of world market price (see Annex Table 1). Moreover, more than one half of the imported quantity was not subject to duty and it is also the only petroleum product whose reference price has remained relatively low compared to world market prices. The sharp increase in fuel oil imports may also reflect some mis-invoicing of gasoline imports to take advantage of the lower tax rate.

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Fuel Oil Imports

(’000 tons)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

Table 3.

Reference prices for dutiable valuation

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B. Estimated Amount of Smuggling and Foregone Revenue

Estimated demand for gasoline and diesel

142. The demand for gasoline is estimated at 237,000 tons in 2003, compared to the officially reported imports of 102,000 tons (Table 4). This estimate was derived from the following assumptions:

  • no smuggling in 1995; and

  • the growth of gasoline demand is derived from (i) the 5 percent growth of the number of cars in Cambodia based on the NIS Statistical Yearbook combined with information on automobile imports in the last two years, and (ii) a 2 percent growth of gasoline consumption per car since 1994, reflecting larger vehicles and engine sizes, and more extensive road network.

Table 4.

Potential Imports of Major Petroleum Products

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Hence, gasoline demand is estimated to have grown by about 7 percent per annum since 1995.

143. The demand for diesel is estimated at 618,000 tons in 2003, compared to dutiable imports of 413,000 tons. This was based on the following assumptions:

  • no smuggling in 1995 nor in 2001; and

  • demand for diesel is stable and can be derived by a linear trend from 1995 and 2001.

Hence, diesel imports are estimated to have grown by 22 percent between 1995 and 1999 and by 12 percent thereafter.

Smuggled products and foregone revenue

144. Foregone revenue due to smuggling is estimated to be about 1.6 percent of GDP. Foregone tax revenue for gasoline alone is about 0.9 percent of GDP based on an estimated smuggled amount of 152 thousand tons in 2003 or about 60 percent of total demand (Table 5). For diesel, estimated foregone revenue is 0.7 percent of GDP based on an estimated 135 thousand tons of smuggled diesel or 33 percent of total demand in 2003.

Table 5.

Potential Tax Revenue

(in billion riel)

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145. Foregone revenue from smuggled petroleum products could be even higher. First, these estimates assume that there was no smuggling in the base year, 1995. Also, foregone revenue from smuggling of kerosene, fuel oil, and other products nor from mis-invoicing is not included.73 Therefore, these amounts could be considered a lower bound for foregone revenue.

C. Incentives for Smuggling

146. Although retail prices in Cambodia were comparable to those in neighboring countries around 1994, the situation has since changed. Part of the reason lies in the differences in tax regimes, both the tax rates as well as the tax structure and how they are affected by changes in international import prices. Moreover, distributor’s margin is estimated to be high in Cambodia.

Comparison of retail prices to neighboring countries

147. The growing gap in retail prices has provided impetus for increased smuggling of gasoline. The retail price of gasoline is 50 percent higher in Cambodia than in Thailand and nearly 60 percent higher than in Vietnam. Moreover, the gap has likely widened recently in the last month as Vietnam has reduced taxes in 2004 in view of the sharp increase in world prices.

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Gasoline Retail Price Comparison

(US $ per liter)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

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Diesel Retail Price Comparison

(US $ per liter)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

148. The retail price of diesel is also higher in Cambodia but by a smaller margin. The retail price of diesel is nearly 20 percent higher in Cambodia than in Thailand. Diesel retail prices are not available for Vietnam but are likely lower than in Cambodia.

149. However, in the case of kerosene the price gap is large only relative to Vietnam, by 36 percent. There is only a small gap between kerosene prices in Cambodia and Thailand. But the price of kerosene is still 36 percent higher than in Cambodia.

A10ufig09

Kerosene Retail Price Comparison

(US$ per liter)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

Comparison with tax regimes in neighboring countries

150. The widening retail price gap can be partly explained by the different tax rates and tax structures between Cambodia, Thailand and Vietnam. In 2002, the tax rate on gasoline in Cambodia was 140 percent, compared to 53 percent in Thailand and 57 percent in Vietnam (Table 6). In Cambodia, the tax/duties are ad valorem and compounded. In Thailand, however, taxes are specific, in baht per liter. Thus, the difference widens during price increases and vise versa. Moreover, petroleum products are exempt of VAT in Thailand.

Table 6.

Comparison of Tax Regimes in 2002

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Sources: Summary of Tax System in each country’s Statistical Appendix, Howell Zee (2003), and staff estimates.

151. The distributor’s margin in Cambodia is also larger. The margin, calculated as the difference between the retail price and after-tax cost (market import price plus all taxes), is about 10 cents per liter in Cambodia. As calculated, it does not include operating and fixed costs of distributors and retailers. The margin in Thailand and Vietnam is about 8 and 6 cents per liter, respectively. For diesel, the distributor’s margin has ranged between 5 and 12 cents per gallon. Part of the reason for the higher margin in Cambodia may be higher import and transport costs.

152. When tax evasion is taken into account, the margins in Cambodia are even larger although they have narrowed in the past two years.74 When collections fall significantly below the taxes due, this provides a much wider distributor’s margin for those not paying the taxes. For both diesel and gasoline, the effective margin was significantly higher in 1998 and 1999, due to significant tax evasion.

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Distributor’s Margin for Gasoline

($/liter)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

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Distributor’s Margin for Diesel

($/liter)

Citation: IMF Staff Country Reports 2004, 331; 10.5089/9781451821789.002.A010

D. Conclusions

153. The problem of gasoline smuggling must be tackled in order to safeguard fiscal revenue. In spite of efforts by the Customs and Excise Department to strengthen antismuggling efforts, smuggling has increased due to increasing world prices since 1998 and the widening gap between the pump prices in Cambodia and those in neighboring countries. Neighboring countries with a broader revenue base can deal more effectively with rising world prices through changes in taxes and duties. However, the exceptionally narrow revenue base and the low revenue yield in Cambodia, obviously place a constraint on the government’s ability to moderate rising petroleum import costs by altering taxes on those products. Only when tax collections are significantly improved through lower smuggling, however, could consideration be given to lowering the tax burden on Cambodian consumers through lower petroleum tax rates.

154. To substantially reduce the incentives for smuggling, Cambodia will need to more than half its total compounded tax rate on petroleum products. This would initially reduce revenue by about 1 percent of GDP. Even if all of the estimated smuggled products were then to be imported legally and taxes on them collected in full, this would only generate ¾ percent of GDP. However, if some smuggling continues, or if the price elasticity of demand is low, there would be a sharp decline in revenue in the short term. Accordingly, substantially greater efforts are needed to combat petroleum smuggling before any reduction of tax rates can be envisaged.

Annex Table 1.

Official Tax Rates

(In percent of reference price)

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Source: Excise Office, Customs and Excise Department of Cambodia.

Import duty and excise tax for gasoline and diesel were changed on July 1, 2001.

Tax rates in 2001 are calculated as the average of tax rates before and after the change.

Tax used for military operation was levied at 3 riel per liter from 1994 to 2001.

Per unit taxes have been levied since 2002: Gasoline: 2 cents per liter, Diesel: 4 cents per liter

VAT is levied on after-tax-value. The effective VAT is = VAT rate times (1+ Excise + Import duty + Additional tax).

Ad valorem tax rates in the above table are calculated based on the actual import values of gasoline and diesel.

Annex Table 2.

Official Tax Rates

(In percent of market price)

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Source: Excise Office, Customs and Excise Department of Cambodia.
66

Prepared by Wafa Fahmi Abdelati (APD) and Koji Nakamura (PDR).

67

The Customs and Excise Department has been strengthening its anti-smuggling efforts in the past five years in what is an extremely challenging environment and with very limited staff. In spite of progress in this area, it has been difficult to clamp down on smuggling in a country with 400 km of shore line and 300 km of land borders that are staffed by only 1200 Customs officials. This chapter does not review the success of recent anti-smuggling efforts.

68

Import volumes and values are based on data obtained from the Department of Customs and Excises (CED) which are still tentative and subject to revision, especially those prior to 1999. Estimates reported here may change after taking reconciling reported amounts of commodity aid and duty-exempt imports.

69

There are no available data on import volume and tax collections for earlier years.

70

The VAT is applied to a “reference price” per ton inclusive of all other taxes. Taxes are compounded in sequence; first the import duty, then the excise, followed by the VAT.

71

Some of the differences between taxes due and collected could be related to timing differences, especially for commodity aid, but this does not change the basic trend.

72

In later years, the taxes due based on reported import quantities is equal to the amount actually collected. This could also reflect improved data gathering.

73

There may have been some substitution toward using more kerosene recently.

74

The larger margins accrue to tax evaders and smugglers, but not to all distributors.

Cambodia: Selected Issues
Author: International Monetary Fund