Domestic resources are the largest and most important source of financing for development. They are country-owned and are more stable than external sources of finance. Domestic resources are the best way to support long-term economic growth and poverty reduction. Over recent years, many developing countries have managed to mobilise more domestic resources for development, however progress varies and low-income countries collect tax revenues of only 15% (on average) of GDP. One limiting factor in the ability of governments to raise tax revenues is lack of capacity. This means less money for education and health-care, and fewer resources for investment in essential infrastructure, such as energy and transport.
Tax administrations are on the frontline in the battle against tax avoidance. Estimates vary and are contested, but cross border tax avoidance impacting developing countries is likely to exceed Official Development Aid (ODA) by a considerable margin. Tackling complex international tax arrangements, which divert profits that are otherwise liable for corporate tax, calls for skilled tax auditors. A well-trained tax audit team can identify high-risk cases and uncover arrangements that strip much-needed tax revenue from governments.
The objective of the TIWB Initiative is to enable sharing of tax audit knowledge and skills with tax administrations in developing countries through a targeted, real time "learning by doing" approach. Selected experts will work with local tax officials directly on current audits and audit-related issues concerning international tax matters and general audit practices relevant for specific cases. This is a specialized area of tax audit assistance, given its focus on providing assistance on real, current cases.
For each TIWB audit assistance programme, the goal will be to enhance capacity in the tax audit practice of the developing country tax administration (Host Administration). Through TIWB Programmes, the Host Administration benefits by improving the quality and consistency of its audits, which in turn brings greater certainty and potentially more revenues for the Host Administration. Over the longer term, the overall investment climate is likely to improve and a culture of taxpayer compliance can be built through more effective enforcement. More broadly, the state-society relationship can also be enhanced through greater engagement and confidence by taxpayers in the taxation process. This may lead ultimately to more effective and accountable governance. TIWB Programmes can complement existing tax-focused assistance programmes, to bring a practical approach to applying new knowledge.
Areas and forms of assistance
TIWB is focused on promoting hands-on assistance by sending Experts to build audit and audit-related skills pertaining to specific international tax matters and the development of general audit skills within developing tax administrations. Experts will work together with tax auditors from the Host Administration on actual audit cases.
TIWB facilitates expert audit assistance in areas such as transfer pricing; thin capitalisation; advance pricing agreements; anti-avoidance rules; consumption taxes (e.g. VAT, GST); high net-worth individuals; pre-audit risk assessment and case selection; audit investigatory techniques; and industry-specific or sector-specific issues. TIWB does not cover assistance relating to customs matters nor is concerned with providing policy support, advice on legislative changes, issues related to (re)negotiations or other aspects of international tax treaties, or litigation, as existing organisations and programmes already offer support to developing country tax administrations on these matters.
In addition to tax audit assistance, the TIWB Governing Board fully supports the extension of the TIWB niche approach into new technical areas. Criminal tax investigation and effective use of data shared through informational exchange mechanisms will be priorities that strike at stemming illicit financial flows. Work is proposed to explore tax and natural resource contracts and environmentally related taxation.
The form and duration of audit assistance can vary, depending on the needs of the Host Administration as well as the types of tax matters involved, the availability of appropriate experts, and funding. For example, it may require eight weeks of assistance over three visits in the course of a six-month period.
The Role of the TIWB Secretariat
The role of the TIWB Secretariat is to facilitate the involvement of all parties in the realisation of targeted audit assistance programmes. The Secretariat acts as a clearing house and interface for requests to participate in the TIWB Programme by proposing Experts to Host Administrations (responsible for Expert selection).
The Secretariat provides information to all parties about TIWB audit assistance and offers guidance on practical steps for establishing a framework for a TIWB Programme.