This Selected Issues paper on the Republic of Madagascar reports on the several key themes associated with longer-term development issues in Madagascar. As one of the poorest countries in sub-Saharan Africa, Madagascar suffers from low levels of social indicators across all fronts including education, health, water and sanitation, and infrastructure. To make progress toward the Millennium Development Goals, the country will need to scale up substantially both public and private investment while taking actions to increase absorptive and institutional capacity and implementing supportive policies in each of the priority sectors.


This Selected Issues paper on the Republic of Madagascar reports on the several key themes associated with longer-term development issues in Madagascar. As one of the poorest countries in sub-Saharan Africa, Madagascar suffers from low levels of social indicators across all fronts including education, health, water and sanitation, and infrastructure. To make progress toward the Millennium Development Goals, the country will need to scale up substantially both public and private investment while taking actions to increase absorptive and institutional capacity and implementing supportive policies in each of the priority sectors.

III. Madagascar-Tax Policy Reform Priorities to Improve Revenue Performance 1

A. Introduction

1. Domestic revenue mobilization is a core element of the strategy to reach the Millennium Development Goals. At Monterrey in June 2002, heads of states agreed on a two-pronged strategy to achieve these goals: donor countries committed to increase aid and open their markets to low income countries, and aid recipient countries agreed to improve public financial management and increase domestic resource mobilization.

2. Improving tax revenue is particularly relevant in Madagascar where it amounted to only 10.7 percent of GDP in 2006, one of the lowest levels in the world. The 2005 Ex-Post Assessment of longer term program engagement in Madagascar identified the lack of progress in tax performance as a major failure of Fund-supported programs during the past decade (IMF, 2005). In addition, raising tax performance is a core objective of the PRGF-supported program for 2006-08 and Madagascar’s new poverty reduction strategy for 2007–11, the MAP.

3. This paper attributes Madagascar’s poor tax performance to the complexity of its tax system, and the weakness of the tax administration. The next section uses cross-country evidence to estimate the tax revenue potential at about 14 to 15 percent of GDP, which is 30 to 40 percent more than current revenue. The third section analyzes the shortcomings in Madagascar’s tax policy, which explain such low revenue performance. And the last section sums up key tax policy reforms that are needed to meet the tax revenue objective of the MAP.

B. Revenue Under-Performance

4. Madagascar has some characteristics of a relatively modern tax system, with most of the revenue generated by indirect taxes. Custom duties account for a declining share of tax revenue, as the authorities have been liberalizing their trade regime on an unilateral and regional basis. 2 The low share of trade taxes may also reflect the weakness of the customs administration (Montagnat-Rentier et al., 2006). The tax system is characterized by a single VAT rate, a set of corporate and individual income taxes, a four band tariff structure, and various registration duties (which are summarized in Appendix III.1)

Madagascar: Central Governement Tax Revenue

(Percent of GDP)

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Source: Ministry of Finance and Budget; and Fund staff estimates.

VAT and Transaction tax before 2004.

5.Yet, Madagascar’s revenue performance counts among the weakest in the world, in spite of statutory rates, which are close to those observed in the rest of Africa. Revenue performance has stagnated since 2000 in Madagascar while it has on average significantly improved in sub-Saharan Africa. Tax revenue performance collapsed in 2002 as a result of the political crisis. It subsequently seesawed on account of various tax policy measures including a temporary capital goods import tax exoneration scheme during September 2003–August 2005, the elimination of the 50 percent investment deduction in the 2004 Budget, and the increase in excise taxes on petroleum products and imposition of interest payment on public debt instruments in the 2006 Budget. It has not yet recovered to its 2000 level.


Madagascar and Selected Sub-Saharan Countries: Tax Revenue Performance, 2000–2006

(Percent of GDP)

Citation: IMF Staff Country Reports 2007, 239; 10.5089/9781451825435.002.A003

Source: IMF World Economic Outlook and IMF staff estimates.

Madagascar and Africa: Statutory Tax Rates, 2006.


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Source: Price Waterhouse Coopers and The World Bank: ‘Paying Taxes, The Global Picture’, 2006; and Fund staff estimate.

46 African countries.

6. Econometric estimates indicate that current tax revenue performance is about 5 percent of GDP lower than tax revenue potential. Lacking a clear prescription from theory, a common approach to assessing whether the level of tax revenue in a developing country is appropriate is to compare it with the tax burden of a representative group of both developing and developed countries, taking into account some of these countries’ characteristics (Tanzi and Zee, 2000). Variables often used include per capita income, the share of agriculture in GDP and the openness of the economy. Using these variables allows explaining a fair proportion of the variation of tax performance in 30 countries. The results of the cross country regression analysis show that the current tax revenue performance in Madagascar is about 5 percent of GDP lower than its tax revenue potential (Annex Table), which is similar to the tax revenue underperformance estimated by Kopits et al. (2003) using the same methodology.

Madagascar and Selected Countries: Tax Performance Determinants

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Standard error in parenthesis. ** denotes statistical significance at the 1% level and * at the 10% level.

Converted using market exchange rates.

See Annex Table.

7. Tax revenue underperformance stems from income taxes, taxes on international trade, and excise taxes. The information in the following table provides some indication of where the pattern of receipts in Madagascar differs from that in comparator countries—and hence some hint as to the areas in which receipts might be enhanced. Three features stand out:

Madagascar and Low Income Countries: Composition of Tax Revenue.

(Percent of GDP) 1

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Source: Ministry of Finance and Budget; and Fund staff.

Figures in parentheses are percentages of total tax revenue.

26 countries, Keen and Simone (2004), Table 3, p. 311.

8. The size of the informal sector does not appear to explain the relatively weak revenue performance: recent estimates put the informal sector in Madagascar at around 39 percent of gross national income, which is large but around the average for developing countries (Schneider, 2005). Rather the combination of about average statutory tax rates and low revenue performance points to the narrowness of the tax base, which stems from generous tax exemptions and low tax compliance because of the complexity of the tax system and weaknesses in tax administration. The next section reviews the main shortcomings of the tax system behind revenue under-performance and proposes priorities for reform.

C. Tax Policy Reform Priorities

Towards a reformed and universal corporate income tax regime

9. The corporate income tax yield has been low because of the complexity of the tax code, exemptions, and weaknesses in tax administration.

  • A first source of complexity is the juxtaposition of a general corporate income tax regime and a special tax regime for Export Processing Zone (EPZ) companies. EPZ companies benefit from exemptions of custom duties and VAT on imports, tax holidays for up to 15 years, a reduced statutory rate of 10 percent, and a 75 percent tax credit for investment. EPZ status is available to enterprises in a wide range of activities, conditional on their exporting at least 95 percent (by value) of their output. Unusually, qualifying enterprises are not agglomerated into a few securitized areas: each qualifying enterprise—around 259 were registered in 2006, of which 184 reported positive turnover—is a zone in itself. Although the fiscal cost of the EPZ regime appears low because most of EPZ companies generate low profit margins, 4 it constitutes a potential source of revenue leakage as it creates incentives to channel transactions subject to the common regime to the more advantageous special regime. The tax and customs administration and EPZ companies need to allocate resources for preventing much abuse.

  • Other sources of complication include the many exemptions in the tax code, the constant changes in the tax legislation, and the intricacy of depreciation provisions. In addition to special regimes applicable to EPZ companies, oil companies and large mining projects (¶20), the tax code includes special treatments applied to leasing and micro-credit activities (Appendix III.1) These special regimes trigger a continuum of requests for special treatment from tax payers subject to the common regime. These requests result in frequent changes to the tax code, which have rendered it more and more complex to administer both for tax officials and tax payers. The system of depreciation allowances identified in the regulations is complex: over 30 asset classes are distinguished in the regulations, with straight line depreciation for each, but with optional accelerated depreciation for some.

  • Tax administration officials are spread too thin at the Directorate of Large Enterprises. The Directorate of Large Enterprises (DFGE) account for about 80 percent of the domestic tax revenue collected but is only staffed by 20 out of the 190 tax inspectors of the Tax Directorate. This allows only very limited fiscal control (100 companies of the 1200 enterprises managed by the DFGE in 2006, World Bank, [2007]), and results in over-allocation of scarce administrative resources to relatively low-yielding activities.

10. In order to simplify the corporate income tax system, the priority is to reintegrate EPZ companies into a common and more attractive corporate income tax regime. The EPZ provisions are overly-generous and the common regime is becoming increasingly unattractive as countries have been reducing statutory corporate income tax rates all over the world (Keen and Simone [2004]), including in the SADC and the COMESA where the statutory corporate income tax is now lower on average than in Madagascar (¶5). One option would be to adopt a two-pronged approach of simultaneously phasing out the EPZ regime and increasing the attractiveness of the common regime. First, while no new EPZ firms should be created, it is important that the benefits enjoyed by established EPZ firms be respected, in order to preserve the credibility of government policy announcements. This includes the standard benefits of EPZ (duty relief and VAT zero-rating)—which should in principle apply to all exporters. In addition, firms that have already entered tax holiday periods would continue to enjoy such holidays. However, the reduced rate of corporate income tax rate should not be allowed to continue indefinitely at 10 percent. Second, changing the parameters of the common regime is an essential element of the approach. This would entail a statutory rate that, in combination with a simple regime of accelerated depreciation, is low enough to remain attractive by international standards.

11. Adopting a common, streamlined tax code applicable to all enterprises is the direction in which more and more countries are following, in order to attract investment. It is consistent with current initiatives toward tax coordination within SADC, which recognize—as does for example the Code of conduct on business taxation adopted within the European Union (a non-binding agreement to freeze and roll back tax incentives), and similar initiatives in Central America and other parts of the world—the attractiveness of collective action to address the risk of ruinous competition in offering tax incentives. 5 Such a strategy is one now being followed by several countries eager to establish a strong reputation for their openness to business (Box III.1.) This reflects in part awareness that special treatments have simply not had the beneficial effects on investment, or the spillovers to the domestic economy that had been hoped for. It also reflects an increasing recognition that, as competitive pressures lead to a reduction in statutory tax rates around the world (both import duties and business taxation), it becomes increasingly pointless to award any preferential treatment. It is better to offer companies low tax rates on a broad basis, thus safeguarding tax revenues.

Eliminating Special Treatment and Reducing Rates: Examples of Recent Tax Reforms

Egypt passed a new income tax law in mid-2005 that reduced the top marginal tax rates on income and profits from 32 to 20 percent for individuals and from 40 to 20 percent for corporations and partnerships (rates for petroleum, the Suez Canal authority, and the central bank were left at 40 percent). This reform also increased the exemption threshold, liberalized depreciation, broadened the tax base by eliminating deductions, and provided for the phasing out of tax holidays while grandfathering current beneficiaries. Importantly, these reforms have been accompanied by extensive and continuing reforms of tax administration, including the introduction of self-assessment and a reform of the tax treatment of SMEs.

In Mauritius, the 2006 budget speech announced a package of reforms that included the integration of EPZ and non-EPZ sectors and the removal of all existing provisions relating to tax credits and tax holidays. At the same time, the corporate tax rate was reduced from 25 to 22.5 percent with a view to further reducing it to 15 percent by 2009 (with the intention of also taxing personal income at the same flat rate). Under the reform package, depreciation will be shifted from straight line to declining balance for all assets, except non-hotel buildings, and the ceiling for fully expensed equipment or machinery in the first year will be raised.

The Slovak Republic adopted in 2004 a single rate of 19 percent tax for both corporate and personal income. The reduction in the corporation tax, previously at 25 percent, was combined with more rapid depreciation, more generous carry forward rules, the elimination of tax holidays for new enterprises and tighter rules for provisioning and reserves.

Toward a simplified and fairer personal income tax regime

12. Design flaws have affected the yield of the personal income tax. The most important structural problems are the undervaluation of fringe benefits and the inconsistency between the tax income brackets of the two main personal income taxes. The treatment of fringe benefits in the personal and corporate income tax codes is asymmetric. In particular, the implied valuation of access to a car is extremely low (in the order of US$5 or 8 per month), and only half of the value of housing is actually added to personal income. Moreover, domestic service is valued by reference to the beneficiary’s income rather than its cost. Meanwhile, the employer is able to deduct 100 percent of these costs against the corporate tax. The structures of tax rates under the wage income tax (IRSA) and the nonwage income tax (IRNS) lack any coherence or correspondence between the schedules: the structure of (annual) tax brackets under IRNS and (monthly) tax brackets under IRSA is such that the same earned taxable income attracts less tax under the IRSA than under the IRNS, except for the highest income.

Madagascar: Personal Income Tax Brackets

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Source: Ministry of finance and budget.

13. Priorities to improve revenue performance of the personal income tax system, and streamline it, include taxing fringe benefits at market value and harmonizing the income brackets of the taxes on wage and non-wage income. Fringe benefits should be taxed at their market value. This may in some cases be difficult to observe, but not in those most important in Madagascar: the costs of company cars, housing costs and domestic service are all being deducted by employers. A first step toward modernizing the personal tax system is to establish a common rate structure between the IRSA and IRNS. In order to simplify the administration of the system, the number of rates should be reduced, with a higher minimum rate than at present, and an increase in the exempt amount (relative to that under the current IRSA) to protect the poorest tax payers. In order to strengthen the fairness of the tax system, tax enforcement on the self-employed should be improved. In the medium term, salary and nonsalary income should be taxed in aggregate rather than separately.

Further streamlining taxes on consumption


14. Although the VAT generates about half of tax revenue, its productivity is comparatively low. The VAT in Madagascar has many features of a modern system. It has only a single rate. There is only one single threshold for VAT registration valid for both individuals and corporations. The list of exemptions is fairly limited but was expanded in the 2007 Budget. The strong performance of VAT revenue owes more to a relatively high rate than to the productivity of the tax, i.e., the amount of revenue collected per percentage of the tax rate, which is relatively low. The threshold for VAT registration is low by international standards, however, which is burdensome both for the administration and in terms of compliance: it forces the tax administration to manage an excessively large number of VAT tax payers, with relatively low liability, and to divert its scarce resources from the timely handling of the largest tax payers’ VAT credits, which hurts the credibility of the VAT. Moreover, the high and consistent level of accumulated VAT credits in the trade sector, which mainly consists of selling imported goods at a profit (and hence with positive value added), is suspicious, and indicates that insufficient attention is paid to controlling VAT filings.

Madagascar and Selected African Countries: VAT Revenue Productivity 1

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Sources: IMF, Country documents ; World Economic Outlook (IMF); African Tax System (IBFD);Corporate Taxes 2003-2004, Worldwide Summaries (PricewaterhouseCoopers); and Fund staff estimates.

Central government.

Revenue productivity = Total VAT revenue as percentage of consumption or GDP, divided by the VAT standard rate.

The data reported as Fiscal Year in the country documents, however, for comparison purposes, the data was converted into Calendar Year.

Budgetary central government.

Madagascar: Accumulated VAT Credits, 2006.

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Source: Ministry of finance and budget.

15.Priorities to increase VAT productivity include raising the VAT registration threshold, clearing the backlog of VAT credits and submitting agricultural inputs to VAT. Raising the VAT threshold will allow the tax administration to concentrate its efforts on tax payers who represent the highest revenue potential (Montagnat-Rentier et al., 2006). In addition, the government should clear the backlog of accumulated VAT credits to be reimbursed to exporters prior to 2006 (MGA 12.7 billion) and refund, within 60 days, VAT credit to exporters and to oil distributors for oil supplied to international carriers. In the medium term, the tax administration should implement a risk-based VAT repayment system, giving prompt refunds to tax payers with a good tax compliance track record and limiting comprehensive controls to those with a poor or unknown profile. Moreover, the government should also pay in a timely fashion its counterpart VAT on externally financed capital expenditure in order to allow construction companies to reduce their stock of accumulated VAT credits. Only if the government undertakes to fulfill its responsibilities by paying VAT and reimbursing valid VAT credits on time, can the VAT be truly neutral for producers. Another priority to increase VAT productivity is submitting agricultural inputs to VAT. This would allow taxing an important part of the informal sector with limited adverse distributional impact, as the farmers purchasing tractors or other agricultural inputs such as fertilizers are most likely to count among the better off.


16. A too wide range of commodities is subject to excises, and the differential rate structure on domestic and imported goods constitute implicit tariff protection. Excises 6—all ad valorem, other than specific 7 taxes on petroleum products (the Taxe sur les produits petroliers, TPP)—are levied on a wide range of commodities. Around 80 percent of all revenue from the non-oil excises comes from alcohol and tobacco, in line with the primary purpose of excise taxes which is raising revenues by taxing at particularly high rates products that have a relatively price inelastic demand and/or generate significant adverse externalities. However, excise taxes are also levied on food products such as sugar and flour, which clearly do not fall in that category. Another peculiarity of excises is that, in many cases, higher rates are applied to imported goods than to domestic goods. This is contrary to rules of the World Trade Organization, 8 which call for protection implicit in the differential excise rate structure to be made explicit in the tariff code. Vehicle license fees were abolished in 2006. The level of oil taxation (including excises and VAT) is about average by international standards, while the level of tobacco taxation is relatively high.

Madagascar and Selected Countries: Oil Price Levels and Taxation

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Source: Malagasy authorities, Fund staff estimates.

Madagascar and Selected Countries: Tax Rates on Cigarettes

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Source: Ministry of finance and budget; and Cnossen (2006), p.65

Excise plus VAT, in percent of retail price.

Madagascar: Excise Tax Rates, 2006


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Source: Ministry of finance and budget.

17. Priorities for raising excise revenue performance include scaling down the number of products subject to excises, equalizing the rates on domestic and imported goods, and taxing vehicles. All excises other than those on alcoholic drink, tobacco products, oil and mobile phones9 should be eliminated. The hidden protection still provided in the excise structure should be suppressed by raising the rates applied to local products towards those levied on imports. Vehicle license fees should be reintroduced.

Reforming other taxes

18. There is scope to eliminate nuisance taxes. Some taxes are very complex but yield very little revenue. Such is the case of the Professional Tax (Taxe professionnelle, TP). The TP is a tax collected by the tax administration and the revenue is transferred to sub national authorities. Its revenue amounted to MGA 13 billion (0.1 percent of GDP) in 2006. It is levied on each entity of a corporation and varies according to the activity of the entity, the size of the town where it is located, and the rental value of the its fixed assets. Calculation of the TP is extremely complex: its description fills 45 pages of the Tax Code (compared to 10 pages for the VAT, which accounted for MGA 574 billion, or 4.9 percent of GDP) in 2006. If the TP were eliminated, it would need to be replaced by a budgetary transfer from the central government to sub national authorities. Madagascar also imposes a wide range of stamp duties, registration duties and taxes on insurance, which on aggregate raise no more than 0.1 percent of GDP. The review with a view to wholesale deletion of these taxes after careful review would clearly free administrative resources in corporations and the tax administration for more productive uses.

19. In the medium term, there is scope to simplify the tax regime for small and medium sized enterprises (SMEs). Despite its simplification in the 2007 Budget, the tax system for SMEs remains complex (Appendix III.1). Below a turnover of MGA 20 million, individual persons are subject to the Synthetic Tax (IS), which is charged at 6 percent of turnover. Between MGA 20 million and 50 million, they have to pay the IRNS, the TP and the Transaction Tax (TST, 5 percent on turnover). Below a turnover of MGA 20 million, corporations are subject to the IBS and the TP, and, between MGA 20 million and 50 million, to the IBS plus the TST. Moreover, because most of the SMEs do not have reliable accounts, the TST, and most likely also the IS, are in practice not determined on the basis of the turnover but, instead, are negotiated with the tax administration, and thus are prone to abuses. To simplify the tax system for SMEs, the use of patent fees for the smallest traders could be explored. This would ease pressures on the tax administration and free resources for improving the treatment of large tax payers.

Reviewing the mining and petroleum codes

20. Arrangements for the tax treatment of large mining and oil operations should be reviewed. There is considerable interest in the mining and oil exploration possibilities available in Madagascar. This is one of the few areas in which, over the coming years, substantial additional revenues are evidently possible. Two large mining projects, of which the construction costs amount to about 60 percent of GDP, are underway: one to mine ilmenite, and the other to extract nickel and cobalt, starting in 2009/10. Oil projects are still in the exploration phase. The general framework for the tax treatment of mining is provided by the 1999 Mining Code, supplemented by the 2001 Law establishing a special regime for large mining projects. This law was amended in 2005. The fiscal regime of oil exploration is governed by the 1996 Petroleum Code. Since the main provisions of these tax regimes were adopted some time ago, the authorities should review whether their substance is not overly generous by international standards.

D. Conclusions

21. Madagascar’s very low revenue level in spite of about average statutory tax rates points to the narrow tax base as the main explanation for the very weak revenue performance. Such narrowness stems from the coexistence of a streamlined and highly preferential tax regime for EPZ companies, along side a complex and uncompetitive tax regime for all other companies. Such a tax system has understandably generated a continuous demand for fiscal exemptions from tax payers subject to the common regime, which in turn has eroded the tax base. Such erosion has hindered the ability of the government to address the issues which are at the top of the list of investors’ concerns, i.e., the lack of macroeconomic stability, the poor quality of the physical and legal infrastructure, and the low skill level of the labor force (Sha et al., 2005). The way out of this vicious circle is to put in place one simple, fair and competitive corporate income tax regime applicable to all companies, eliminate nuisance taxes such as the Taxe Professionnelle for all companies, and provide efficient duty draw back and VAT refunds to all companies. Such a simplification of the tax system would complement ongoing long overdue tax administration reforms for improving the treatment of large tax payers.

22. Other priorities include modernizing the personal income tax regime, streamlining the number of products subject to excise taxes, eliminating the tariff hidden in excises by raising the rates on domestic products to those on imports, and reviewing the mining and petroleum codes. Madagascar’s mining and oil resources constitute both an opportunity and a challenge. The abundant natural resources present in Madagascar have the potential to generate high income for the government, investors and the Malagasy people alike. But very few low income countries have succeeded in transforming such potential into improved living standards for the population at large. One element of success is to ensure a fair deal between the investors that extract the natural resources and the country, such that the national treasury transparently and appropriately shares in the benefits and risks of the extraction and transformation of natural resources. In light of the accelerated growth expected in the MAP from the mining and oil sectors, the authorities should review their mining and petroleum codes to make sure that a good balance is achieved between the interests of investors and those of the Malagasy people, and implement transparent procedures to collect and allocate revenue from natural resources.

Annex Table. Madagascar and Selected Countries: Tax Revenue, Imports, Agriculture, Real GDP per Capita, and Tax Revenue Potential, 2005

(Percent of GDP, unless otherwise indicated) 1

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Sources: National authorities; World Development Indicators, World Bank; and IMF staff estimates.

A * denotes data is as of 2004.

Converted using market exchange rates.

Calculated using results of regression in paragraph 6.

APPENDIX III.1—Madagascar: Summary of the Tax System, 2007

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Tax Regime of Export Processing Zone Companies

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Source : Ministry of Finance and Budget ; and Fund staff.


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Prepared by Christian Josz, with the assistance of Leighton Harris and Asegedech WoldeMariam. Based on the February 2007 Aide-Mémoire of the Tax Policy mission 2007“Madgascar-Towards a Simple, Fair Tax System to Growth” by Michael Keen, Alain Jousten, Christian Josz and Martin Grote.


See Chapter II, The Economic and Fiscal Impact of Joining the SADC FTA.


This is overstated, however, to the extent that the differential excises that persist in Madagascar (¶16) are economically equivalent to tariffs.


Keen et al. (2007) estimated the fiscal cost of the EPZ regime at about 0.1 percent of GDP in 2006


SADC’s Finance and Investment Protocol, which member states began to ratify in October 2006, provides guidelines to address the growing concern that a proliferation of selective, discretionary tax incentives within the region’s member states could trigger an unsustainable race to the bottom with degrading effects on members’ income tax systems. Hence, the Protocol states that “State Parties shall endeavor to achieve a common approach to the treatment and application of tax incentives and will, amongst other things, ensure that tax incentives are provided for only in tax legislation” (Article 4 of Annex 3). While the current language points to only moral suasion through the political process, Article 2 of Annex 3 in fact binds member states to report and record fully all existing tax expenditures.


As recommended by Kopits et al (2003), the redevances have now been fully integrated into the excise system.


An ‘ad valorem’ tax is one specified as a proportion of the selling price, and a ‘specific’ tax one specified as a fixed monetary amount per unit of the product.


Of which Madagascar is a member


Although not generating significant adverse externalities, cell phone use is commonly submitted to excise taxes in cash strapped low income countries.

Republic of Madagascar: Selected Issues
Author: International Monetary Fund