Follow-Up of IMF Mission Recommendations by the Iranian National Tax Administration

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1 Iranian National Tax Administration (INTA) Follow-Up of IMF Mission s by the Iranian National Tax Administration Tehran, May

2 I. Error! Bookmark not defined.error! Bookmark not defined.2009 IMF Mission Report Title: Islamic Republic of Iran: Review of Income and Trade Taxes GENERAL RECOMMENDATIONS Move towards introducing an administrable tax on aggregate incomes at the individual level, based on a coherent design embodying efficiency and equity goals. TAX ON SALARY INCOME Maintain the basic personal exemption at its present nominal level. Undertake a study of in-kind benefits, for example, housing, vehicles and preferential loans, to ensure that the fair market value of all benefits and all allowances is included in income. In addition, eliminate the exemption for non-cash benefits. Subject incomes of all employees to a uniform tax rate schedule. Apply only one or at most two brackets across the broad range of low-and-middleincome taxpayers. Consider reducing income tax rates as the income tax base is broadened Restructure the employee tax to incorporate at most two or three brackets in a revenue- 2

3 enhancing way. Tax the private sector on an EET basis, with full taxation of pensions (EET: Expenditure tax treatment of pension savings and benefits). Tax the public pensions with gross pensions increased as much as is needed to protect a basic net amount. TAX ON BUSINESSES AND CORPORATIONS Review the procedures and rules for ex officio assessments to ensure that unincorporated businesses are being assessed a reasonable amount of tax. Eliminate exemptions from the tax, including for agriculture and construction. Special tax rates, including for experts, should also be eliminated. Consideration should be given to moving away from tax holidays, to an overall regime reflecting a more level playing field with a lower uniform rate of corporate taxation. If an incentive for investment is considered desirable, it should be general, and in the form of accelerated depreciation or investment tax credits, that are linked to the 3

4 amount of investment. Targeted tax incentives should be used sparingly and mainly to address identified market failures. Tax incentives should not be used to compensate for a poor investment climate. Review the current depreciation schedule to ensure that rates approximate the useful lives of depreciable assets. Allow the pooling of depreciable properties with similar economic lives. 4

5 II IMF Mission Report Title: Strengthening Compliance, Modernizing Tax Administration & A Review of the VAT of IRAN Develop compliance improvement strategies for large and medium taxpayer segments. o Supported by interim data warehouse. Establish a new Audit and Compliance Division at INTA Headquarters. o Clarify roles of other divisions vis-à-vis new division. Consolidate management of all field activities under single INTA executive (vicepresident). Integrate the VAT division within a restructured INTA headquarters that is functionally organized. Develop one or two functionally-structured model Medium Taxpayer Offices. IMPROVING COMPLIANCE Partly completed. Plans for data warehouse commenced and data sources being expanded. Compliance Improvement strategies not commenced. Partly completed. An expanded Tax Assessment and Audit Office operates within the Direct Taxes Department of INTA headquarters with a staff of 30. Though not having status of a full department of INTA, the Office has extended responsibilities for investigation and audit methods, compliance planning, development of risk based compliance strategies and related interpretation issues including reviews of assessments based upon accounting reports prepared by chartered accountants. Implemented. A vice president for field delivery was appointed. Plans for merger of the VAT department are at an early stage of development. The integration is expected to take place in Partly completed. Combined small/medium taxpayer offices are in Isfahan. Establish a consolidated budget to be used Completed. The new consolidated budget is effective for SY

6 according to INTA priorities and strategies. Expand post-assessment audit methods Under development. initially for large taxpayers driven by national audit plan. LARGE TAXPAYER ADMINISTRATION Introduce self-assessment in the LTU with Partly completed. Pilot of self assessment processes commenced in simplified payment and filing procedures. LTU in Update the LTU selection criteria to be Partly completed. Standardized LTU criteria are not applied across based primarily on turnover. all offices. Major revisions to LTU criteria in Tehran LTU introduced o Include all eligible firms regardless of and substantial revision to the Tehran LTU client base achieved in legal form. SY Extension of LTU coverage to natural persons is being o Refresh LTU client list annually trialed in Isfahan. Provincial LTU offices apply separate criteria. Increase the LTU client base: o To secure 50 percent of total revenue o To reach percent of total revenue Expand LTU to provinces only where there is sufficient need. Rebalance LTU workforce with greater emphasis on audit and reduction on processing. Improve LTU audit function: o Introduce comprehensive audit program o Expand to a full suite of audit methodologies. Partly completed. Criteria changes should have increased national LTU collections towards 50 percent of revenues, but changes are too recent and data is unavailable to confirm. Not implemented. All offices have been instructed to closely manage their largest 100 taxpayers. However, this includes taxpayers who do not meet the Tehran LTU criteria. Partly completed. Expansion of audit resources in Tehran to 30 percent of staff numbers in SY Early stage planning for an expanded range of audit types. Implementation to follow legislative reforms expected in SY VAT POST IMPLEMENTATION ISSUES 6

7 Expand the VAT taxpayer base: o Analyzing business turnover to identify qualifying unregistered businesses. o Enforce recordkeeping for all voluntary registrants regardless of legal form. o Reduce mandatory and voluntary thresholds. Provide stronger sanctions to prosecute and imprison for serious VAT non-compliance. Introduce flat non-filing penalty applied and managed automatically for each late/unfiled period. Introduce monthly filing for largest taxpayers. Move to integrated compliance management across all tax types. o Research score-based risk management systems. Legalize electronic filing to eliminate the need to additionally file paper returns. Streamline payment and filing procedures, moving liberated resources from service to compliance units. Implemented. VAT taxpayer base now exceeds 245,000. Mandatory turnover threshold has been progressively reduced to current level of RI 1 billion over five phases. In the fourth phase, all businesses in specified sectors (e.g. restaurants, gold merchants) were obliged to register irrespective of turnover. A minimum voluntary registration threshold for VAT participation is under consideration. While voluntary registrations (below RI 1 billion) are permitted, very few have occurred. Partly completed. New penal sanctions are proposed for income tax and VAT where there is serious non-compliance. Draft legislation has been put forward for legislature s consideration and final government approval. Not implemented. Existing law permits monthly filing. Under consideration but further technical assistance requested. Being implemented. Draft legislation has been put forward for legislature s consideration and final government approval. Partly implemented. TARA project has developed integrated work processes to support the integrated tax system. Pilot self assessment work processes in LTU and medium taxpayer offices. 7

8 Monitor closely refund and credit positions. Implemented. Credit levels are monitored and appear stable. Refund levels remain low excepting regular exporters. Deny concessional VAT payment Implemented. arrangements other than in exceptional circumstances. Move to direct deposit of refunds. Progressed. Implementation expected in SY 1391 following legislative approval. TAX REFORM AND AUTOMATION ISSUES Review TARA program and create new Implemented. Plans revised substantially in SY baseline plan. o Identify and address TARA project gaps. o Structure IT deliverables into small and regular releases. Develop a set of taxpayer services channel Being progressed. TARA program examining future channel options. strategies. Expedite enterprise data warehouse in Implemented. alignment with TARA to support compliance improvement. Create a to be vision of business processes Implemented to minimize ITS customization. o Implement best practices before ITS. Migrate to TARA with controlled movement Partly completed. Migration plan under development. to functions. o Ensure single governance of interim IT changes and TARA projects. SELECTED OPERATIONAL ISSUES 8

9 Phase out the Tax File Number (TFN). o Adopt the national ID number for individuals and unincorporated businesses. Debt management recommendations: o Profile and validate INTA s debt stock. o Develop strategies for late payments. o Manage closely provincial payment arrangements o Cease automatic payment arrangements for large taxpayers. o Ensure systems apply interest to all delayed payments. Legislation recommendations: o Simplify Article 95 & 96 business definitions o Introduce penalty for misleading statements. o Introduce severe sanctions for fraud. o Reform Article 156. o Legally accommodate electronic filing. In progress as new TIN is being rolled out. The new TIN structure includes embedded identifiers of location and tax type contrary to prior FAD advice and bets practice. Unknown - outside mission scope to review. Implemented. Implemented. Implemented. Not implemented. Implemented. 9

10 III IMF Mission Report Title: ISLAMIC REPUBLIC OF IRAN : AN EMERGING MODERN TAX ADMINISTRATION MAINTAINING A REFORM FOCUS Develop a whole of agency reform plan that includes all reform activities. Develop an integrated workforce plan and organization. Re-prioritize less critical compliance initiatives. Remove all restrictions impeding INTA from managing taxpayers independent of their location by delivering services and functions from any place that INTA chooses. Begin integration planning for VAT and direct tax. LARGE TAXPAYER ADMINISTRATION Identify all qualifying large taxpayers anywhere in Iran with turnover above RI 50 billion. Map the qualifying large taxpayer population by location and sector. Identify likely LTU locations with sufficient critical mass. 10

11 Adjust allocations where a sound business case exists and taxpayer numbers justify LTU centers of industry specialization. Implement the new LTU model with accountability to a new Large Taxpayer INTA Deputy President. MEDIUM & SMALL TAXPAYER ADMINISTRATION Define the medium taxpayer segment as all non-ltu businesses: (i) registered for VAT; and (ii) non-registered VAT taxpayers with turnover above the VAT threshold Implement a pilot Medium Taxpayer Office (MTO) in Tehran and develop a plan for national rollout of MTOs Develop a simplified regime for small taxpayers (those under the VAT threshold). Consolidate the network of remaining INTA offices that will be dedicated to small taxpayer administration and providing services to any taxpayer. SELF ASSESSMENT Develop a detailed plan to introduce self assessment Withdraw authority for taxpayers to elect tax audit certification by an accountant Withdraw the option for INTA to outsource 11

12 the audit function VAT REGIME AND ADMINISTRATION Strictly apply a turnover rule for compulsory VAT registration and eliminate mandatory sector participation regardless of turnover Permit greater voluntary registration above a possible lower threshold Maintain a single threshold for all taxpayers regardless of profitability Consider cash accounting for small VAT taxpayers, possibly just for voluntary registrants Implement monthly filing and payment for large taxpayers Review need for controls over invoice stationery or allocation of invoice numbers Ensure refund mechanisms are working effectively Strengthen filing penalties 12

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