International Development CommitteeWritten evidence submitted by ActionAid

About Us

Founded as a British charity in 1972, ActionAid is an international NGO working in 45 countries worldwide, and our positions and recommendations reflect the experiences of our staff and partners in Africa, Asia, the Americas and Europe. Our vision is a world without poverty and injustice in which every person enjoys the right to a life with dignity. We work with poor and excluded people to eradicate poverty and injustice. In 2003 we became ActionAid International and moved our global headquarters from the UK to South Africa. Our rights based approach, which looks at the systemic causes of poverty, forms the foundation for our work on development. We continue to play a leading role in the debate in the UK and globally around tax justice, aid effectiveness and accountability for developing countries.

For more information on our work on tax justice, and to discuss further written or oral evidence on any of the subjects covered in this submission, please contact Sebastian Dance, ActionAid’s government relations adviser, [email protected]

Summary

1. We are delighted that the International Development Committee is conducting an inquiry into tax and development. Tax is, as the founding communiqué of the African Tax Administration Forum states, an indispensable condition on the path to “free African countries from their dependence on foreign assistance and indebtedness.”1 The same could be said of developing countries in every part of the world.

2. Tax is crucial to developing countries’ long-term capacity to alleviate poverty, build effective and accountable states, and foster sustainable, equitable growth. As a recent paper from the OECD underlines, increased tax revenues will be indispensable to achieving the Millennium Development Goals.2 Yet all too often at present, tax systems in developing countries, alongside global tax rules that affect them, fail to deliver these outcomes. In too many instances, foreign investors and top earners are not taxed sufficiently, and the payments they make to governments are misused; as a result, countries are looking to the poor, in particular the informal economy, to expand tax revenues.

3. We are encouraged by the growing resolve in many developing countries, particularly in Africa, to mobilise more domestic resources, and to tax multinational companies more effectively. There is much more that the UK government can and should be doing to assist these efforts, including:

developing a cross-Whitehall tax and development strategy, which will ensure coherence between UK tax policy decisions and DFID’s development work;

increasing the financial and human resources within DFID devoted to tax and development; and

requiring tax havens and multinational enterprises to be more transparent, enabling developing countries to identify cross border avoidance and evasion.

4. It appears at present that there is little coordination between tax policy developed at the Treasury, technical assistance delivered by HMRC, and capacity building work supported by DFID via country offices and multilateral bodies. To maximise the value for money gained from UK aid, and the benefits from DFID’s work to promote the private sector in developing countries, it is essential that these three departments work together under a coherent tax and development strategy.

The Importance of Tax for Development

5. Many developing countries already fund the majority of their budget through taxation. For example, taxes constitute 72% of government revenue in Zambia3, and 71% in Ghana.4 So it is concerning that, once oil revenues are factored out, tax revenues for Africa as a whole have been stagnant over the last three decades.5

6. Trade liberalisation during that period caused falling tariff revenues in developing countries, resulting in policy advice that focused on pragmatic means of increasing tax revenues as quickly as possible, such as the introduction of VAT, without due consideration for the impact of such reforms on poor people. Few developing countries assess the distributional impact of tax reforms on different parts of the population in the way that the UK does in each budget.

7. Corporate taxation constitutes an important proportion of tax revenues in developing countries. In Zambia, for example, corporate income tax, withholding taxes and mineral royalties, all borne by companies, constitute 31% of tax revenue.6 With this in mind, tax avoidance and evasion by multinational companies significantly reduce the amount of revenues available.

8. The OECD estimates that tax havens cost developing countries three times what they receive in aid.7 South Africa’s finance minister Pravin Gordhan has described aggressive tax avoidance as “a cancer eating into the fiscal base of many countries”8; last year the Treasury noted that “tax avoidance in developing countries deprives governments of the vital income needed to build and maintain their public services.”9 Given the government’s commitment to providing value for money for UK taxpayers, it makes very little economic sense to allow this situation to persist.

The Impact of Tax Dodging by UK-Based Companies on Development

9. Recent ActionAid research showed for the first time the full extent of tax haven use by FTSE 100 companies.10 Ninety-eight of these multinational groups are using tax havens, where 38% of all of their subsidiaries located. High street banks are the heaviest users, with 1,649 companies operating in tax havens shared between Barclays, HSBC, RBS and Lloyds. The data also illustrate the risks for developing countries: the biggest 10 tax haven users have a total of 3,833 subsidiaries in tax havens, but they also have 1,951 in developing countries.

10. Some 40% of all world trade takes place between companies that are part of the same multinational group.11 These “transfer pricing” transactions play an important role, not just in distributing goods and services between group companies, but also in distributing profits and tax liabilities. Yet the system by which they are regulated provides ample room for companies to shift their profits away from countries in which the economic activity occurs, which have higher tax rates, and towards those in which the liability is much lower, all without breaking the law.

Example: SABMiller

11. ActionAid’s report Calling Time; Why SABMiller should stop dodging taxes in Africa,12 showed how one major FTSE100 company uses transfer pricing payments to shift an estimated £100 million of taxable profit from developing country subsidiaries where genuine economic activity is taking place into tax havens, where it incurs a much lower tax rate. This includes royalty payments for the use of trademarks, management and service fees, procurement payments and interest on loans from sister companies, all of which are treated as tax deductible.

12. The overall impact of the large outflows on developing countries is that their tax receipts are dramatically diminished. For example, the net effect of the outflows from SABMiller’s Ghanaian brewing subsidiary in 2008 and 2009 was an overall pre-tax loss. ActionAid estimates that payments to Switzerland, the Netherlands and Mauritius from SABMiller’s subsidiaries in Africa and India resulted in a total tax loss to governments in those countries of £20 million, enough to put 250,000 children in school, and equivalent in Africa to almost one-fifth of the company’s estimated tax bill.

13. The kinds of tax avoidance employed by multinational companies in developing countries are not available to domestic entrepreneurs. For example Marta Luttgrodt, who works 12-hour days running a small bar in Accra, must pay £47 per year in taxes, part of the government’s scheme to tax informal sector traders. In contrast, the SABMiller brewery from which she purchases supplies paid no income tax at all as a result of its transfer pricing payments. “We small businesses are suffering from the authorities,” Marta told us. “If we don’t pay, they come [to lock our stalls] with a padlock.”

14. The types of payments channelled from developing countries to tax havens in the example of SABMiller are by no means unique: “tax-efficient supply chain management” is a growing part of business restructuring, and the exploitation of royalties on intellectual property to shift profits is challenging for the UK as well as for developing countries. “Your research findings seem to be borne out by the experience that we know in tax practice in this country,” Ghana’s Commissioner General for taxation told ActionAid.13

A Comprehensive Tax and Development Agenda

15. The previous government adopted an international leadership role on tax and development. DFID’s 2009 white paper stated that “effective tax systems are central to effective states” and noted the “increasing concern that tax systems in developing countries are undermined by international banking secrecy, including in tax havens.”14 Gordon Brown ensured that the 2009 London G20 summit committed to “developing proposals…to make it easier for developing countries to secure the benefits of a new cooperative tax environment.”15 Treasury minister Stephen Timms initiated the creation of the OECD’s task force on tax and development, in which ActionAid participates.

16. In contrast, the current government has adopted a more passive approach in international forums such as these. The government’s position is that “the best way to prevent” tax avoidance in developing countries “is by helping these countries develop robust and stable tax systems which enable them to collect the tax they are owed.”16

17. This issue should be receiving much more attention from DFID, but it must also be part of a coherent cross-Whitehall strategy. The dichotomy between international reforms and domestic capacity-building rarely occurs in our discussions with revenue officials and other stakeholders in developing countries, who recognise that both are needed in the long term. Based on these discussions, we believe that the step change in tax collection that is needed cannot be achieved without action in all three of the areas discussed in more detail below.

Recommendation 1: DFID should lead the development of a cross-Whitehall strategy on tax and development that ensures tax policy is made in a way that maximises the value for money delivered from UK taxpayers’ contribution to overseas aid.

(i) Strengthening DFID’s tax and development work

18. When it is done well, tax capacity building generates results: past assistance from DFID and other donors helped Rwanda to quadruple the amount of tax it raised between 1998 and 2006, and Uganda to increase its tax-to-GDP ratio from 7.2% in 1991 to 12.6% in 2003. There is considerable unfulfilled demand from developing countries for tax capacity building work, to which DFID should respond through increased quantity and quality of technical assistance.

Devoting more resources to tax and development

19. In August 2011, ActionAid asked the Treasury, DFID and HMRC for a list of activities supported by each department that build tax capacity in developing countries. We received a comprehensive spreadsheet of information from HMRC.17

20. DFID has taken some time to gather the information because it is not available centrally, and is handled by individual DFID country offices. Given the emphasis placed on tax capacity building in the government’s response to campaigners, the fact that DFID does not maintain an overview highlights the lack of focus on this vital area of policy. Last year, the IMF, World Bank, OECD and UN recommended in a report to the G-20 that donors report specifically on the resources devoted to tax and development.18

21. The information from HMRC shows that staff time equivalent to three or four full time positions is invested in projects that support tax capacity building in developing countries. Tax officials from developing countries speak highly of this assistance, which is delivered by experienced, practising officials. There seems to us considerable room for DFID funding to increase the provision of this technical assistance.

22. The lack of central coordination by DFID—of its own departments and of the strategic direction across government—is concerning. We understand that DFID HQ has only one member of staff focused on the tax and development agenda, working on it part time.

Recommendation 2: Given its central role in reducing aid dependency, tax should be a more important priority for DFID, with more aid resources and dedicated HQ time.

Supporting efforts to hold governments accountable for tax policy

23. Civil society organisations, journalists and parliamentarians all play an important role in driving forward changes in tax policy and administration, and promoting fair, open and transparent policymaking. For example:

As a result of our report on SABMiller, revenue officials from Zambia and several other African countries met under the auspices of the African Tax Administration Forum (ATAF) to discuss its implications. As a result, ATAF is now developing a mutual assistance treaty that will better equip its members to work together to investigate multinational companies’ tax affairs.19

Zambia’s new government introduced measures in its first budget to more effectively tax the extractive sector. This reform was an election commitment resulting from a significant public debate during the election campaign driven by civil society organisations, the media, and parliamentarians.

ActionAid and its partners across developing countries monitor budgeting-processes and help local communities to engage. For example our partner in Ghana, the Integrated Social Development Centre (ISODEC) published a “Taxation Ghana Made Simple” guide for organisations wishing to engage in budget advocacy, holds regional public meetings to raise awareness and solicit opinions on budget proposals, and each year publishes a budget review.

Recommendation 3: DFID should devote more resources to support programmes that engage civil society organisations, journalists and parliamentarians in the tax policymaking process, as well as investigative work that holds governments to account for the taxation of companies and top earners.

Raising the quality of technical assistance

24. While technical assistance has been at the root of many notable successes in the history of development aid, in many instances aid has been wasted on projects that are poorly coordinated between donors, ignorant of the realities of public administration in developing countries, and unlikely to have a lasting impact because it is not based on the priorities identified by developing countries themselves.20 We are already concerned that, in the rush to support stronger tax administrations, bilateral and multilateral donor agencies are offering assistance that fails to learn these lessons.

Recommendation 4: The African Tax Administration Forum (ATAF) is developing a diagnostic toolkit, which will allow developing countries to identify their own needs and priorities for capacity building. DFID should ensure that such approaches are central to the delivery of technical assistance on taxation, including by the multilateral agencies that it funds.

Recommendation 5: Some businesses have suggested that they would be willing to support capacity building in African tax authorities. This suggestion should be treated with caution, as it would be a clear conflict of interest for “capacity building” on tax policy and administration to be provided by taxpayers, many of which are active lobbyists.

(ii) Policy coherence across Whitehall

25. We are concerned that several UK positions on international tax policy risk undermining efforts to help developing countries raise more tax revenues, which represents poor value for money for UK taxpayers. We discuss two here.

Spillover analysis

26. The aforementioned report from the IMF, World Bank, OECD and UN to the G-20 included the following recommendation:

It would be appropriate for G-20 countries to undertake “spillover analyses” of any proposed changes to their tax systems that may have a significant impact on the fiscal circumstances of developing countries…in moving, for instance, from residence to territorial systems.

27. The committee may be aware that the government is currently undertaking a major reform of corporate taxation.21 This is an example of a UK tax policy reform that has the potential to impact on developing countries, because of the extent of UK companies’ operations in both developing countries and tax havens. Particularly noteworthy are plans for Finance Bill 2012 to relax anti-tax haven abuse legislation called Controlled Foreign Companies (CFC) rules. ActionAid is concerned that the proposals will eliminate a significant deterrent that discourages UK-based companies from shifting profits from developing countries to tax havens.

28. We estimate that the reforms may cost developing countries as much as £4 billion, and have urged the Treasury and DFID to conduct their own spillover analysis, as recommended by the international organisations. No such analysis has been undertaken.

Recommendation 6: In line with the government’s commitment to getting value for money from its aid, it is essential that a development spillover analysis for the CFC reforms is conducted immediately, or commissioned from an international organisation such as the IMF or OECD. This should incorporate:

the potential change in companies’ behaviour that may result;

the characteristics of developing countries (for example investment patterns, tax legislation, enforcement capacity) that would be likely to increase exposure to this impact; and

the measures that developing countries or the UK could take to help mitigate any impact.

Appropriate international tax rules

29. At present, the dominant international tax rules in areas such as transfer pricing and information exchange are those set by the OECD. Although the OECD is making commendable efforts to reach out to developing countries in its tax work, standards are ultimately negotiated between its 35 members, and designed with them in mind. Yet it is these standards that donors are encouraging developing countries to adopt.

30. The United Nations tax committee is an efficient, effective body that has developed alternative standards tailored to the circumstances of developing countries. For example, its model tax convention is used by developing countries in tax treaty negotiations, and it is currently developing a practical manual on transfer pricing in developing countries. The committee is constrained by a lack of financing.

31. Last year, the UN’s Economic and Social Council considered plans to strengthen its tax committee. These were supported by the G77 group of developing countries, with vocal agreement from all developing country members of the G20. Unfortunately, the UK was among countries that opposed the move, citing its preference for work to be undertaken within the OECD.22

Recommendation 7: When this discussion re-emerges, as is likely within the next few years, the government should support a stronger UN tax committee as part of a coherent tax and development strategy.

(iii) Increasing tax transparency

32. Developing countries’ tax administrations require not only improved capacity, but also increased access to tax information. This requires developed countries to agree to and implement changes in their approach to transparency. ActionAid supports two reforms in particular.

Transparency of multinational companies

33. Last year ActionAid participated in a working group commissioned by the OECD and convened by the Oxford University Centre for Business Taxation to consider proposals for greater corporate transparency, in particular country-by-country reporting by multinational companies.23 The report concluded with a list of recommendations for further research, many of which have not been adopted by the OECD.

Recommendation 8: We urge the government to ask the OECD to take forward these recommendations in full.

34. The committee will no doubt take an interest in the corporate transparency measures currently proposed by the European Commission, which include country-by-country reporting of some information. While we support this additional transparency, it is worth being aware of a number of limitations which mean that these reforms are unlikely to help meet the objective of ensuring that tax payments made by multinational companies in developing countries are adequate:

they are limited to the disclosure of payments to governments, but do not include the other financial information needed to interpret this, such as turnover and profits;

they may not cover all countries in which companies have a presence, since they are likely to be limited to “production countries”, therefore excluding offshore jurisdictions to which profits may have been shifted for tax purposes; and

they are restricted to the extractives and forestry sectors.

35. In the absence of an international standard, many businesses have begun to report their “total tax contribution” in developing countries. This is a misleading statistic, which combines taxes borne by the company itself with those borne by consumers and employees, such as VAT and income tax.

Multilateral information exchange initiatives

36. Two problems faced by developing country revenue authorities are the lack of information on individual and corporate taxpayers’ offshore affairs, and legal restrictions that prevent them from discussing a multinational taxpayer with each other.

37. There are a number of encouraging developments in this area, including a commitment made by all G20 members to join a multilateral convention on mutual assistance in taxation, and the establishment of regional conventions, such as those under development by ATAF and the South African Development Community. Many developing countries are also concluding bilateral information exchange agreements.

Recommendation 9: The government should support developing countries with technical assistance to develop and join conventions that they expect to find useful. It is important that this is based on the principles that we outlined earlier: developing countries should not be discouraged from adapting the standards and model conventions developed by OECD countries for their own use.

Recommendation 10: The government should also ensure that the G20 continues to exert pressure on tax havens to improve tax information exchange, and to ensure that developing countries benefit from this, as per its 2009 commitment.

Recommendation 11: We share other organisations’ concerns that the UK’s tax cooperation agreement with Switzerland may undermine global efforts to help tax authorities in developing countries gain the information they need from tax havens, because it is a bilateral deal that leaves banking secrecy intact. We believe that this is another example of a tax reform that warrants a spillover analysis of its impacts on developing countries.

Annex

TECHNICAL ASSISTANCE DELIVERED BY HMRC, 2009–11

INFORMATION SUPPLIED TO ACTIONAID BY HMRC IN DECEMBER 2011

Subject

Aegis

Start date

End date

Total commitment (FTE days)

Event duration (FTE days)

Travel & prep (FTE days)

Number of delegates

Number of countries involved

AFRICA

Low Income Economies

Research and Development

DFID

10/01/2009

21/01/2009

11

7

4

2

1

Tax Education and Customer Service Support

DFID

07/02/2009

22/02/2009

22

16

4

6

1

Auditing Multinational Enterprises

OECD

07/09/2009

11/02/2009

9

4.5

4.5

N/K

1

Oils study

Private Sector

11/08/2010

23/08/2010

16

12

4

1

1

Health & Safety

DFID

01/03/2010

13/03/2010

16

12

4

1

1

HR Management

DFID

25/02/2010

11/03/2010

13.5

9.5

4

1

1

Project Management

DFID

11/02/2010

02/03/2010

19

15

4

2

1

Investigation Techniques

DFID

11/02/2010

23/02/2010

16

12

4

2

1

Intelligence

DFID

01/11/2010

12/11/2010

15

11

4

2

1

HR Management

DFID

28/11/2009

09/12/2009

15

11

4

1

1

Customs Modernisation

WCO

23/10/2009

03/11/2009

15

11

4

1

1

HR Strategy

DFID

29/08/2009

25/09/2009

32

28

4

2

1

HR

DFID

14/09/2009

17/09/2009

7

3

4

1

1

Tax Audit

DFID

06/01/2010

16/01/2010

15

11

4

1

1

HR Management

DFID

28/11/2009

09/12/2009

15

11

4

2

1

Customs Modernisation

WCO

24/07/2009

31/07/2009

11

7

4

2

1

Customs Reform

DFID

31/05/2009

12/06/2009

16

12

4

1

1

Customs Reform

DFID

01/04/2009

14/04/2009

17

13

4

1

1

Taxpayer Charter

DFID

23/08/2010

11/09/2010

24

20

4

2

1

Research and Development

DFID

24/04/2010

18/05/2010

24

20

4

4

 

Banking, Telecommunications, Construction and Transfer Pricing

International Revenue Authority

28/09/2011

30/09/2011

30

7.5

18.5

4

4

Enforcement and Border Management

DFID

31/10/2011

10/11/2011

14

10

4

1

1

Tax Audit

DFID

03/10/2011

13/10/2011

14

10

4

2

1

Tax Audit

DFID

06/06/2011

16/06/2011

14

10

4

2

1

Customer Services: Complaint Handling

DFID

09/05/2011

19/05/2011

14

10

4

1

 

Compliance Management

DFID

07/02/2011

17/02/2011

14

10

4

1

 

Auditing Multinational Enterprises

OECD

07/02/2009

11/02/2009

9

4.5

4.5

1

1

Transfer Pricing

International Revenue Authority

16/05/2011

16/05/2011

3

1

2

3

1

Finance

International Revenue Authority

01/07/2009

01/07/2009

n/k

1

n/k

3

1

Tax Modernisation

International Revenue Authority

01/10/2009

01/10/2009

n/k

1

n/k

4

1

Finance

International Revenue Authority

01/07/2010

01/07/2010

n/k

0.5

n/k

n/k

1

Public Sector Reform

DFID

01/10/2010

01/10/2010

n/k

0.5

n/k

n/k

1

Revenue Forecasting

International Revenue Authority

06/09/2011

06/09/2011

n/k

3

n/k

25

1

Lower Middle Income Economies 

Border Security

MoD

02/03/2009

05/03/2009

8

4

4

1

 

Customs Modernisation

World Bank

13/10/2010

13/10/2010

5

1

4

1

1

Customs Modernisation

WCO

25/07/2011

30/07/2011

9

5

4

1

 

IT

International Revenue Authority

15/02/2010

25/02/2010

14

10

4

1

 

Compliance Techniques

International Revenue Authority

30/03/2009

04/04/2009

9

5

4

2

1

IT

International Revenue Authority

13/03/2010

20/03/2010

11

7

4

2

1

Advanced Transfer Pricing

OECD

14/11/2011

19/11/2011

10

6

4

1

1

Transfer Pricing

OECD

29/11/2010

03/12/2000

10

5

5

n/k

1

Intellectual Property Rights

European Commission

04/05/2009

09/05/2009

9

5

2

1

1

Air Freight

International Revenue Authority

21/04/2009

23/04/2009

n/f

2

n/k

2

1

Budget and Climate change

International Revenue Authority

23/06/2009

23/06/2009

nk

1

n/k

6

1

Thin Capitalisation

International Revenue Authority

07/09/2009

09/09/2009

n/k

3

n/k

21

1

Customs Modernisation

Private sector

21/04/2010

23/04/2010

n/k

3

n/k

n/k

1

HMRC Merger

International Revenue Authority

23/06/2010

23/06/2010

n/k

1

n/k

n/k

1

Oil and Gas

International Revenue Authority

10/10/2011

14/10/2011

n/k

5

n/k

n/k

29

Tax Policy

International Revenue Authority

31/10/2011

04/11/2011

n/k

5

n/k

n/k

11

Upper Middle Income Economies

Valuation of Intangibles

OECD

16/10/2011

20/02/2011

8

4

4

1

1

Procurement and Deployment of Scanners

WCO

22/09/2009

24/09/2009

6

2

4

1

1

Tax Policy

International Revenue Authority

03/04/2011

04/04/201

n/k

2

n/k

n/k

11

Risk Operations

International Revenue Authority

09/06/2011

10/06/2011

n/k

2

n/k

n/k

11

Tax Policy

International Revenue Authority

10/06/2011

10/06/2011

n/k

1

n/k

n/k

6

ASIA

Low Income Economies

Auditing Multinational Enterprises

OECD

09/02/2009

13/02/2009

9

4.5

4.5

n/k

1

Customs Modernisation

OSCE

07/02/2010

06/05/2010

117

113

4

1

1

UK Tax System

International Revenue Authority

06/04/2009

06/04/2009

n/k

1

n/k

2

1

Tax Reform

International Revenue Authority

12/10/2009

12/10/2009

n/k

1

n/k

1

1

VAT

International Revenue Authority

16/11/2009

16/11/2009

n/k

1

n/k

4

1

Memorandum of Understanding

International Revenue Authority

09/11/2009

09/11/2009

n/k

1

n/k

2

1

Tax Reform

International Revenue Authority

26/04/2010

26/04/2010

n/k

0.5

n/k

n/k

1

Student loans

International Revenue Authority

01/05/2010

01/05/2010

n/k

0.5

n/k

n/k

1

Lower Middle Income Economies

Drafting of Excise Legislation

Ministry of Finance

14/07/2010

16/07/2010

6

2

4

2

1

Transfer Pricing

OECD

29/11/2010

04/12/2010

9

5

4

1

1

Transfer Pricing

OECD

02/03/2009

06/03/2009

10

5

5

1

1

Customs Modernisation

WCO

07/12/2009

11/12/2009

8

4

4

1

1

Customs Modernisation

WCO

20/05/2009

03/06/2006

16

12

4

1

11

Advance Pricing Agreements

International Revenue Authority

14/07/2011

15/07/2011

5

2

3

4

1

Oil & Gas

IMF

05/08/2010

23/08/2010

23

19

4

1

1

E-commerce

International Revenue Authority

21/09/2011

21/09/2011

1

0.5

0.5

n/k

1

Transfer Pricing

OECD

14/11/2011

18/11/2011

20

5

15

n/k

1

Customs Risk Management

International Revenue Authority

03/07/2009

03/07/2009

n/k

1

n/k

8

1

Customs Modernisation

International Revenue Authority

02/07/2009

03/07/2009

n/k

1

n/k

6

1

Tax Policy

International Revenue Authority

17/07/2010

17/07/2010

n/k

0.5

n/k

n/k

1

International Trade

International Revenue Authority

28/06/2011

30/06/2011

n/k

3

n/k

n/k

12

HR

International Revenue Authority

25/01/2011

26/01/2011

n/k

2

n/k

n/k

3

Tax Investigation

International Revenue Authority

23/03/2011

25/03/2011

n/k

3

n/k

n/k

14

Tax Investigation

International Revenue Authority

28/03/2011

30/03/2011

n/k

3

n/k

n/k

16

VAT Compliance

International Revenue Authority

25/07/2011

25/07/2011

n/k

1

n/k

n/k

4

Process Improvement

International Revenue Authority

11/11/201

11/11/201

n/k

1

n/k

n/k

3

VAT & Debt Management

International Revenue Authority

03/011/2011

04/11/2011

n/k

2

n/k

n/k

6

Upper Middle Income Economies

Transfer Pricing

OECD

14/09/2009

18/09/2009

10

5

5

1

1

Taxation of Financial Markets

OEDC

02/11/2009

07/11/2009

9

5

4

1

1

Taxation of Financial Markets

OECD

04/04/2010

09/04/2010

9

5

4

1

1

Taxation of Financial Markets

OECD

25/04/2011

30/04/2011

9

5

4

1

1

Interviewing Techniques

Private Sector

14/04/2010

17/04/2010

7

3

4

3

 

Customs Modernisation

WCO

05/07/2010

09/07/2010

8

4

4

1

1

Trade Facilitation

WTO

28/09/2009

03/10/2009

9

5

4

1

1

Tax Treaty’s

OECD

09/10/2009

14/10/2009

9

5

4

1

1

Customs Modernisation

WCO

06/07/2009

11/07/2009

9

5

4

2

1

Intellectual Property Rights

European Commission

24/11/2009

27/11/2009

7

3

4

1

1

Tax Capacity Estimates & Gap Analysis

IMF

31/05/2009

12/06/2009

16

12

4

1

1

Customs Management

CCLEC

05/02/2010

21/02/2010

20

16

4

1

1

Transfer Pricing

OECD

02/08/2010

06/08/2010

10

5

5

n/k

1

Transfer Pricing

International Revenue Authority

04/02/2010

04/02/2010

1

0.5

0.5

6

1

Customs Modernisation

International Customs Authority

10/10/2011

13/10/2011

7

3

4

2

1

Tax Avoidance

OECD

05/12/2011

09/12/2011

10

5

5

n/k

1

Valuation of Intangibles

OECD

17/10/2011

21/05/2010

10

5

5

n/k

1

Transfer Pricing

ITIC

24/02/2009

26/02/2009

12

6

6

1

1

Exchange of Information

OECD

08/11/2010

13/11/2010

9

5

4

1

1

Customs Modernisation

WCO

19/10/2010

22/10/2010

7

3

4

1

1

Tax Policy

International Revenue Authority

03/12/2009

03/12/2009

n/k

1

n/k

7

1

Tax Policy

International Revenue Authority

08/12/2009

08/12/2009

n/k

1

n/k

2

1

IT Systems

International Revenue Authority

03/03/2011

04/03/2011

n/k

2

n/k

4

1

Excise

International Revenue Authority

07/03/2011

07/03/2011

n/k

1

n/k

5

1

Tax Policy

International Revenue Authority

03/10/2011

03/10/2011

n/k

1

n/k

3

1

Excise and Tobacco Smuggling

International Revenue Authority

18/05/2011

18/05/2011

n/k

1

n/k

2

1

Customs Coorporation

International Revenue Authority

23/09/2011

23/09/2011

n/k

1

n/k

4

1

EU Trade Statistics

International Revenue Authority

16/11/2011

16/11/2011

n/k

1

n/k

14

1

Environmental Tax

International Revenue Authority

21/11/2011

22/11/2011

n/k

2

n/k

10

1

EUROPE

Low Income Economies

Customs Modernisation

OSCE

07/02/2010

06/05/2010

117

113

4

1

1

Lower Middle Income Economies

Customs Modernisation

WCO

15/11/2009

 

9

5

4

2

1

Customs Strategy

WCO

19/02/2009

24/02/2009

9

5

4

1

1

E-commerce

International Revenue Authority

21/09/2011

21/09/2011

1

0.5

0.5

n/k

1

Tax Reform

International Revenue Authority

15/06/2009

18/06/2009

n/k

4

n/k

12

1

Tax Policy

World Bank

01/05/2010

01/05/2010

n/k

5

n/k

5

1

Process Improvement

Ministry of Finance

15/06/2010

18/06/2010

n/k

4

n/k

n/k

1

Excise

International Revenue Authority

24/10/2011

25/10/2011

n/k

2

n/k

n/k

9

Risk Analysis

International Revenue Authority

08/11/2011

08/11/2011

n/k

1

n/k

n/k

3

Upper Middle Income Economies

Tax Treaty’s

OECD

12/04/2010

17/04/2010

9

5

4

1

1

VAT Assurance

CARTAC

26/04/2010

30/04/2010

9

5

4

1

1

Customs Modernisation

WCO

07/08/2011

14/08/2011

9

5

4

1

1

Risk Management

WCO

18/07/2011

25/07/2011

9

5

4

1

1

Trade Facilitation

WTO

22/06/2009

27/06/2009

9

5

4

1

1

Customs Modernisation

European Commission

21/11/2011

01/12/2011

14

10

4

1

1

Transfer Pricing

OECD

02/08/2010

06/08/2010

10

5

5

n/k

1

Transfer Pricing

International Revenue Authority

27/01/2011

28/01/2011

8

2

6

5

1

International Tax Avoidance

OECD

05/12/2011

09/12/2011

10

5

5

n/k

1

Transfer Pricing

OECD

11/10/2009

15/10/2009

10

5

5

n/k

1

Customs Modernisation

Eiropean Commission

25/06/2009

27/06/2009

6

2

4

2

1

VAT Risk Management

IMF

21/06/2009

03/07/2009

14

10

4

2

1

Risk Intelligence

International Revenue Authority

09/09/2009

09/09/2009

n/k

1

n/k

10

1

Intelligence

International Revenue Authority

15/03/2011

15/03/2011

n/k

1

n/k

5

1

EU Law

International Revenue Authority

05/09/2011

05/09/2011

n/k

1

n/k

4

1

Tax Investigation & Excise

International Revenue Authority

23/03/2011

24/03/2011

n/k

2

n/k

7

1

Excise

International Revenue Authority

27/05/2011

27/05/2011

n/k

1

n/k

2

1

Tax Investigation

International Revenue Authority

28/09/2011

28/09/2011

n/k

1

n/k

10

1

Internal Governance

International Revenue Authority

17/11/2011

18/11/2011

n/k

2

n/k

9

1

Caribbean

Upper Middle Income Economies

Trade Facilitation

WTO

22/06/2009

27/06/2009

9

5

4

1

1

Customs Management

CCLEC

05/02/201–0

21/02/2010

14

10

4

1

1

VAT Assurance

CARTAC

26/04/2010

30/04/2010

9

5

4

1

1

South America

Upper Middle Income Economies

Procurement and Deployment of Scanners

WCO

22/09/2009

24/09/2009

6

2

4

1

1

Corporate Governance

FCO

11/03/2009

14/032009

7

3

4

1

1

Capital Trust & Corporate Venturing Schemes

International Revenue Authority

10/11/2011

10/11/2011

n/k

1

n/k

2

1

Commonwealth

Advancing Management Potential & Commonwealth Tax Inspector Programmes 2009

Commonwealth Association of Tax Administrators (CATA)

03/08/2009

11/09/2009

450

30

420

31

10

Advancing Management Potential & Commonwealth Tax Inspector Programmes 2010

CATA

02/08/2010

10/09/2010

450

30

420

30

9

Advancing Management Potential & Commonwealth Tax Inspector Programmes 2011

CATA

01/08/2011

09/09/2011

450

30

420

28

6

Taxation of International Transactions 2009

CATA

08/05/2009

12/05/2009

10

5

5

n/k

1

Taxation of International Transactions 2010

CATA

03/05/2010

07/05/2010

10

5

5

n/k

1

Taxation of International Transactions 2011

CATA

06/06/2011

10/06/2011

10

5

5

n/k

1

Notes

HMRC did not include country names in order to preserve the confidentiality of requesting authorities.

“International Revenue Authority” under “Aegis” refers to direct requests made to HMRC by revenue authorities in developing countries.

The Commonwealth AMP and CTI events are principally attended by low income and low middle income African countries.

February 2012

1 International Conference on Taxation, State Building and Capacity Development in Africa, “Pretoria Communique”, August 2008. Available at:
http://www.ataftax.net/SiteResources/documents/Development%20Partners/52589_52471_080829ATC2008PretoriaCommuniquefinal16h3011.pdf

2 OECD Development Centre, “Revisiting MDG Cost Estimates from a Domestic Resource Mobilisation Perspective”, December 2011. Available at
http://www.oecd.org/document/27/0,3746,en_2649_33731_49302043_1_1_1_1,00.html

3 Chikwanda, A, 2012 budget address, November 2011. Available at
http://theglobenewspaper.blogspot.com/p/2012-budget-presented-on-friday-11-11.html

4 Ministry of Finance, 2010 fiscal data. Available at
http://www.mofep.gov.gh/documents/2010_FISCAL%20DATA_FINAL.xls

5 African Development Bank et al, ‘African Economic Outlook 2010’. Available at
http://www.africaneconomicoutlook.org/en/in-depth/public-resource-mobilisation-and-aid-2010/the-state-of-public-resource-mobilisation-in-africa/

6 Chikwanda, A op cit.

7 Gurria, A, “The Global Dodgers”, The Guardian, 27 November 2008

8 Cited in Houlder, V “Tax officials on trail of wealth hidden offshore”, Financial Times, 30 May 2009

9 Grice, A “British firms attacked for routine use of tax havens”, The Independent, 11 October 2011

10 ActionAid, “Addicted to Tax Havens: the secret life of the FTSE100”, October 2011. Available at
http://www.actionaid.org.uk/doc_lib/addicted_to_tax_havens.pdf

11 U.S. Department of Commerce, “US Goods Trade: Imports & Exports by Related-Parties 2009” US Census Bureau News,
12 May 2010.
Available at http://www.census.gov/foreign-trade/Press-Release/2009pr/aip/related_party/rp09.pdf

12 ActionAid, “Calling Time: Why SABMiller should stop dodging taxes in Africa”, November 2010. Available at
http://www.actionaid.org.uk/doc_lib/calling_time_on_tax_avoidance.pdf

13 ActionAid interview, 23 September 2010. This comment, although made in response to our evidence related to Accra Brewery, was general and not in relation to a specific company.

14 DFID, 2009, “Eliminating World Poverty: Building our common future”.

15 Annex to G-20 communiqué, November 2011. Available at
http://www.g20.org/Documents/Fin_Deps_Fin_Reg_Annex_020409_-_1615_final.pdf

16 Grice, A op cit.

17 We have attached the HMRC spreadsheet in annex

18 IMF, OECD, UN & World Bank. Supporting the Development of More Effective Tax Systems, November 2012. Available at
http://www.oecd.org/dataoecd/54/29/48993634.pdf

19 Temkin, S “Multinational profit shifting ‘erodes taxes’’’, Business Day, 30 June 2011. Available at
http://www.businessday.co.za/articles/Content.aspx?id=147195

20 See ActionAid’s Real Aid series of reports, in particular Real Aid 2, published in 2006, at
http://www.actionaid.org.uk/doc_lib/real_aid2.pdf

21 The core of these reforms is to move from a residence tax system, under which UK-based companies are liable for tax on their worldwide earnings with credits for taxes paid overseas, to a more territorial system, under which overseas earnings are exempt from UK tax.

22 Individual countries’ written positions can be viewed at http://www.un.org/esa/ffd/tax/2011SGReport/RepliesMS.htm

23 Devereux et al, “Transparency in reporting financial data by multinational corporations”, Oxford Centre for Business Taxation, June 2011. Available at http://www.sbs.ox.ac.uk/centres/tax/Documents/reports/Transparency_reporting_multinationals_july2011.pdf

Prepared 20th August 2012