Thesis (MPA)--University of Stellenbosch, 2003. / ENGLISH ABSTRACT: This paper that is composed of six chapters discusses the basic issues of modem tax administration and the extent to which Eritrean tax administration adheres to the requirements contained in these issues. The first chapter includes a general introduction, brief historical background of Eritrea, premise, problem definition, objective, design and methods, scope and limitation of the study. The second chapter deals with the literature review on the theoretical perspective of tax system and administration. There are detailed discussions about the types, characteristics, and functions, ethics of taxes and efficiency and effectiveness of tax administration. This theoretical aspect discusses the basic issues of modem tax administration trends and their development and reforms. The reforms are mainly concerned with prevention of tax evasion, avoidance, corruption and measures taken for making tax administration more efficient and reducing the complexity of taxation laws. Chapter three explores international success stories in dealing with major tax issues, thereby using the solutions as benchmarks. Experiences in Singapore, Bolivia, Croatia, Jamaica, Guatemala and Spain are used as standards to examine the level of efficiency and effectiveness of tax administration in Eritrea. This chapter also shows that modem tax administrations are concerned with a stronger focus on taxpayers, employees and their development, usage of technology, financial independence and privatisation of those areas that could be better performed by the private sector. To accomplish the above mentioned goals, the abovementioned countries have set in motion to reform tax administrations with the aim of solving key problems such as low salaries and the connected problems of attracting and retaining high quality personnel and curbing corruption. The fourth chapter presents the actual situation of tax administration in Eritrea. It deals with missions, objectives, functions, human resource condition, facilities, the level of application of modem technology and the weaknesses and strength of the Inland Revenue Department (lRD). It also describes the measures, which have been taken by IRD administration to motivate its employees and to enhance the voluntary compliance of taxpayers. The fifth chapter provides a consolidated assessment of the present situation of tax administration in Eritrea based on international experiences of tax administration and on theoretical aspects of taxation. This chapter also scrutinizes the amendments of Proclamation No. 62/1994 and 64/1994 and their effect on tax administration, saving, consumption and investment in Eritrea. The sixth chapter provides a conclusion and recommendations that could be used by tax authorities in Eritrea to implement the best practices of tax administration used in the abovementioned countries. This study provides an overview on IRD's present situation and how it could successfully manage organisational transformation to achieve significantly increased customer satisfaction, enhanced organisational flexibility, employee motivation and increase in tax collection by following the recommendations based on theory and the experiences of other countries. / AFRIKAANSE OPSOMMING: In hierdie studie wat bestaan uit ses hoofstukke, word die basiese kwessies om moderne belasting administrasie bespreek en die mate waartoe die belasting administrasie van Eritrië daaraan voldoen. Die eerste hoofstuk sluit die volgende in: 'n algemene inleiding, 'n kort historiese agtergrond oor Eritrië, 'n voorafgaande stelling, 'n probleem definisie, asook die doelwitte, metodes, omvang en delimitasies van die studie. Die tweede hoofstuk bevat 'n literatuur oorsig oor die teoretiese perspektief op belastingsisteme en administrasie. Daar is gedetailleerde besprekings van die tipes, kenmerke en funksies van belasting asook die etiek daarvan en die doeltreffendheid en effektiwiteit van die belasting administrasie. Hierdie hoofstuk bespreek die basiese kwessies i.v.m. die tendense in belasting administrasie, hoe hulle ontwikkel en hoe hulle hervorm kan word. Die hervormings het meestal betrekking op die voorkoming van belasting ontduiking en vermyding, korrupsie, en metodes om die belasting administrasie meer effektief te maak en om die wette minder ingewikkeld te maak. Hoofstuk drie gaan in op internasionale suksesverhale i.v.m. belasting en die oplossings word as bakens gebruik. Die effektiwiteit van Eritrië se belastingstelsel word gemeet aan wat gebeur het in ander lande soos Singapore, Boliwië, Kroatië, Jamaika, Guatemala en Spanje. Hierdie hoofstuk toon ook dat moderne belasting administrasie meer fokus op belastingbetalers, werknemers, die gebruik van tegnologie, finansiële onafhanklikheid en die privatisering van areas wat beter deur die privaatsektor bedryf kan word. Om die bostaande te bereik, het die genoemde lande maatreëls ingestelom die belasting administrasie te hervorm en om die volgende sleutelprobleme op te los: lae salarisse, die lok en behou van hoë kwaliteit personeel en die voorkoming van korrupsie. In die vierde hoofstuk word die eintlike werklikheid van belasting administrasie in Eritrië bespreek. Dit behandel die doelwitte en funksies van die belasting department (IRD) asook die sterktes en swakhede daarvan en tot hoe 'n mate moderne tegnologie gebruik word. Dit beskryf ook wat die belasting departement gedoen het om sy wernemers te motiveer en om die samewerking van belasting betalers te verseker. Die vyfde hoofstuk is 'n waardebepaling van die eintlike huidige situasie van belasting administrasie in Eritrië gemeet teen internasionale ondervindings en die teoretiese aspekte van belasting. In hierdie hoofstuk word ook gekyk na die amendemente tot Proklamasie No 62/1994 en 64/1994 en hulle uitwerking op belasting administrasie, spaar, verbruik en belegging 10 Eritrië. In die sesde hoofstuk is daar gevolgtrekkings en aanbevelings wat die outoriteite in Eritrië kan gebruik. Hulle kan die praktyke wat die beste in ander lande gewerk het, implementeer. Hierdie studie verskaf 'n oorsig oor die huidige situasie in die Binnelandse Inkomste Departement in Eritrië en oor hoe organisatoriese hervorming kan plaasvind wat sal lei tot beter belasting betalers tevredenheid, meer organisatoriese vlugheid, werknemers motivering en 'n dramatiese vermeerdering in belasting invordering. Hierdie hervorming moet gegrond wees op die aanbevelings soos geformuleer uit die ondervindings van ander lande.

Taxes are major source of public funds to finance government expenditures. Tax authorities impose different kind of taxes and employ many agents to collect taxes effectively. Some dutiful taxpayers will undoubtedly pay their tax liabilities while many others will not. The Internal Revenue Service in the United States reports that the estimate of income tax liability not collected is about 17, which translates into 345 billion for 2001. It is important to make a distinction between tax evasion and tax avoidance. The distinguishing characteristic of evasion is illegality. Whether the reason for not paying tax liability is avoidance or evasion, economic models of taxation need to be changed in the light of these realities. In this study, I analyze some of the economic problems of tax evasion/avoidance. In the first chapter, I discuss the relationship between number of tax audits, tax administration reform and tax compliance in Turkey. In recent years, many developing countries have carried out reforms in their tax administration to increase their efficiency in collecting taxes. In 2005, the tax authority in Turkey established Tax Office Directorates (T.O.D.s) in 29 provinces for the purpose of controlling the underground economy, improving taxpayer assistance, and increasing auditing efficiency. By using the panel data on province level tax returns, my analysis answers two questions. First, I examine the effect of audits on reported income and reported tax liability. By controlling for the detectibility of evasion and other socioeconomic variables, I find that audits have the same effectiveness in increasing reported income and reported tax liability. Second, I investigate the effect of establishing T.O.D.s in 29 provinces on compliance in those provinces. I find that T.O.D.s are effective at the extensive margin rather than the intensive margin. Thus, establishing T.O.D.s had no significant effect on the compliance level of existing taxpayers while it increased the number of tax returns significantly. In the second chapter, I analyze the excess burden on income tax when tax avoidance matters. I present a simple static labor supply model with endogenous asset choice. Then, I examine how tax avoidance through asset trading a ects the labor supply response and the excess burden of income tax. Furthermore, I discuss the implications of the tax policy analysis and show that a failure to account for avoidance responses may lead to errors when estimating how tax reform affects labor supply, tax revenue, and the welfare cost of taxation. Because of tax avoidance through tax arbitrage, the progressivity of a given tax system will be less than what the formal tax system implies. In the third chapter,we study the Marginal Cost of Funds in the existence of tax evasion. We develop a general equilibrium model of tax evasion, including the expected utility of taxpayers and three different revenue-raising government policies. In this rich model environment, we analytically derive the marginal cost of funds (MCF) for the alternative policy instruments. We consider two main fiscal reforms: the revision in the nonlinear tax scheme and the changes in enforcement mechanism (the audit and penalty rates). First, we derive the MCF for the tax reform and find its key determinants. The derived MCF is greater than the previous ones since it includes a "risk-bearing cost" as well as tax distortion. The reform in enforcement mechanism generates MCFs in different forms. Two more MCFs with respect to audit and penalty rates are presented. Finally, we compare these three different MCFs in numerical example and provide some policy implications. / text

The primary objective of this dissertation was to identify and estimate the relative importance of factors used by the Tax Court in deciding hobby loss cases. This was accomplished in two steps. The first step was to review the Treasury Regulations, cases and literature pertaining to hobby losses to determine the relevant factors used by the Court in deciding this issue. The second step involved using probit analysis to identify which of these factors actually influenced the Court in deciding hobby loss cases and to determine the relative importance of the factors. A secondary purpose was to to explore the probit model's ability to predict decisions likely to be appealed. The probit model was based on the analysis of 219 post-1954 Tax Court cases involving determination of whether activities were or were not engaged in for profit. By application of log-likelihood techniques, it was determined that the model developed was stable over time and across lines of "business," the implication being that cases decided both before and after the passage of Section 183 and involving all types of activity should have precedential value in conflicts between taxpayers and the Internal Revenue Service. Five factors were found to be significant predictors: manner of operation, level of expertise, time expended, history of income and loss, and presence of elements of personal pleasure. It is important to note that the two factors not susceptible to tax planning--success in other activities and financial status of the taxpayer--were insignificant discriminators between business and hobby outcomes. The implication is that with careful tax planning, one can organize and operate a given activity so that it is likely to receive favorable tax treatment. The probit model proved to be unable to predict decisions likely to be appealed. The probability that a particular case would be classified by the Court as a business did not appear to be a significant predictor of whether a taxpayer would appeal an adverse decision.

Cette thèse se donne pour objet d’analyser les rapports entre la conception et l’introduction des nouveaux outils informatiques qui essayent de faire la gestion intégrée de l'information dans une organisation et les transformations simultanées de la structure et des pratiques organisationnelles.Le propos du travail est de comprendre comment les interactions entre la dynamique interne des organisations et les évolutions technologiques contribuent à l’évolution des organisations, à partir de l’hypothèse de que bien qu’essentiels pour faire évoluer l’organisation, les nouveaux outils informatiques sont, eux aussi, lors de leur conception, des produits des rapports sociaux des acteurs qui participent à la vie de l’organisation. Le moment de conception des outils informatiques introduits dans une organisation est, ainsi, l’occasion de la confrontation de visions de l’organisation qui peuvent être sinon opposées au moins diverses, et où des rapports biunivoques s’établissent entre l’élaboration et l’adoption des nouveaux outils techniques et la construction de nouveaux modèles d’organisation des services. L’analyse conjointe des projets de changement technique et organisationnel menés à partir de la fin des années 1990 dans l’administration fiscale française permet de rompre le divorce entre la centralité pratique des changements dans le champ de l’administration liés aux TIC et aux systèmes d’information et la marginalité ou même la complète absence de ces sujets dans la littérature qui analyse les changements du secteur public. Dans ces projets, la nouvelle façon par laquelle l’administration fiscale se propose d’orienter ses rapports avec les contribuables est à l’origine des nouveaux flux d’informations, de la nouvelle logique qui va orienter la gestion de l’information et de la révision des processus internes de l’organisation. / Pas de résumé en anglais

The subject of this thesis is to analyze changes in tax administration, the OECD member countries, which have occurred in relation to the tax reforms undertaken in the period 2005 - 2009. These changes are further examined and analyzed according to the phases of the business to which it relates. The main task of this work is the comparison of statistical methods and analysis of tax reforms in terms of tax administration and complexity of tax administration in member countries of the Organisation for Economic Cooperation and Development. The conclusion is based on the results confirmed or refuted the hypothesis of the development cost of the tax administration and rate of the application and use of information technology.

Masters in Public Administration - MPA / This research focuses on the challenges of tax administration in Somaliland Ministry of Finance (MOF). The study analyses existing challenges in the MOF-Tax Administration, causes of these challenges, the impact of these challenges on domestic revenue collection as well as the country’s economic growth and development. In order to obtain a desirable, comprehensive, and in-depth understanding of the research problem, the researcher applied a mixed method approach, thereby limiting the weaknesses of using the quantitative or qualitative research approach alone. The sample size consisted of 63 staff members. The research included 57 questionnaires for 57 employees and lower level managers as well as 6 interviews for top and middle-level managers in Somaliland Inland Revenue Department. The data was analyzed using Statistical Package for Social Science (SPSS), Ms. Excel, and conceptual analysis, where themes were developed and analyzed. The key findings of the research were that Somaliland tax administration faces immense challenges that can be broadly grouped into three categories: institutional challenges, attitudinal challenges as well as political and economic challenges. These challenges are mainly due to the absence of professional staff, the lack of taxpayers’ education, outdated tax laws, non-compliance behavior of taxpayers, rigidity of the tax system, and poor public trust amongst others. These challenges restrained tax revenue collection, public service provision, investments, and economic growth issues. Therefore, the recommendations, accordingly made in this thesis, include, amongst others, the need to establishing a professional training center for staff, automating tax procedure, implementing effective performance appraisal system, and the regular updating of tax policies to establish a transparent, accountable and equitable tax system in Somaliland.

A research report submitted to the Faculty of Commerce, Law and Management in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation) 13 April 2017 / ‘The Organisation for Economic Co-operation and Development (OECD) Action Plan on Base Erosion and Profit Shifting (BEPS), is designed to prevent multinational businesses achieving nontaxation on profits or artificially shifting profits across borders to exploit lower corporate income tax rates’ (KPMG, 2014, p 5). ‘The OECD’s BEPS Action Plan, launched in July of 2013 and endorsed by the G20, included 15 key areas for identifying and curbing aggressive tax planning and practices and modernizing the international tax system’ (KPMG, 2013). It can be argued that the aim of the ‘OECD Action Plan on BEPS’ is to make provision for G20 countries, OECD countries and all other interested stakeholders to come together on an equal footing to inter alia develop new international tax rules. One of the key focus areas of the ‘OECD Action Plan on BEPS’, is ‘Preventing the Artificial Avoidance of Permanent Establishment Status - Action 7'. ‘The aim of Action 7 is to develop changes to the definition of a permanent establishment (PE) to prevent abuses of that threshold, including through the use of commissionaire arrangements and the specific activity exemptions to avoid PE status where core activities are involved’ (KPMG, 2015, p 14). The technical arguments to be argued for the purposes of this research report will inter alia involve commenting on commissionaire arrangements and how such arrangements have been problematic for international tax rules in their current form. In addressing the problems inherent in the definition of a PE, ‘Preventing the Artificial Avoidance of Permanent Establishment Status - Action 7' specifically proposes changes to Articles 5(5) and 5(6) of the ‘OECD Model Tax Convention’ which seek to revamp the dependent agent rule. The specific activity exceptions in Article 5(4) have also been further clarified in the OECD commentary on the ‘OECD Model Tax Convention’ through the inclusion of an explanation of the activities that will be considered as being preparatory or auxiliary in nature, as well as supporting examples which help illustrate the meaning of the said terms. ii In addition, the PE rule for construction projects set out in Article 5(3) will now include a principal purposes test, as well the addition of an example illustrating the application of the principal purposes test in the OECD commentary on the ‘OECD Model Tax Convention’ dealing with Article 5(3). ‘On 5 October 2015, the OECD issued a final package of reports in connection with its Action Plan to address BEPS, as well as a plan for follow-up work and a timetable for implementation. Many countries have already adopted or are poised to adopt changes to their international tax systems based on the OECD recommendations. While implementation and timing will vary across borders, this final OECD release marks a crucial shift from the recommendation and consultation phase of BEPS to legislation and implementation’ (KPMG, 2015, p 2). Key Words: ‘Action 7’, Article 5, ‘BEPS Action Plan’, Commissionaire Arrangements, Dependent Agent, Multinational Enterprises, ‘OECD Model Tax Convention’, PE. / GR2018

A research report submitted to the Faculty of Commerce, Law and Management in partial fulfilment of the requirements for the degree of Master of Commerce (Specializing in Taxation), Johannesburg, 2016 / The Tax Administration Act 28 of 2011 (TAA) came into effect on the 1 October 2012 and brought with it significant changes to the South African tax administrative regime, extending the powers of South African Revenue Service (SARS) while also indirectly emphasising taxpayers’ rights. This research report examines the impact that this ‘new legislation’ has had on taxpayers, more especially the procedural and administrative rights of taxpayers. This research report evaluates inherent procedural rights of taxpayers as contained in the Constitution of the Republic of South Africa versus the current provisions in TAA and the remedies available to taxpayers should their rights be infringed upon. The research report extends to instances of good tax administrative practices in a few OECD countries and finally concludes with comments on the future of tax administration in South Africa. / MT2017

The tax audit can be defined as one of the practices of the tax authorities modified by Act No. 280/2009 Coll., the Tax Code. The aim of the tax audit corresponds with the basic aim of the tax administration, which is primarily to establish correctly a tax assessment. This dissertation is focused on the tax audit from the perspective of the fundamental tax administration principles. The presented dissertation is divided into nine chapters, most of which are further subdivided. The first chapter is focused on the determination of the tax audit. In the second chapter, the attention is paid to the constitutional principles controlling the tax audit, mainly to selected regulations of the Constitution and the Charter of Fundamental Rights and Freedoms. The following third chapter is focused on the isuue of good governance principles. The fourth chapter deals with the fundamental principles of tax administration, as expressed in the Tax Code in §5 - §9. These principles are specified as a basis for the next part of the work. Chapters five to eight are dedicated to the tax audit, which is divided into the beginning of the tax audit, the tax rights and responsibilities during the tax audit, the progress of the tax audit and the final chapter is focused on completion of the tax audit. The last chapter is...

This study explores the impact of complexity upon unintentional non-compliance behaviour for personal taxpayers in Australia. This area of research did not appear to have been previously studied in an Australian context and in this respect, the study represents an original contribution. While studies have been conducted both in Australia and overseas, they have generally been directed at other types of compliance behaviour and tend to be inconclusive in their findings. According to the compliance literature, there appeared to be little consensus of opinion on the factors that determined behaviour and appropriate research methods. It emerged that more narrowly-defined studies with stronger research methods offered potential for furthering knowledge in this field. Thus the study focused on one behavioural outcome and one type of taxpayer, using a multi-paradigm research method. Unintentional non-compliance, as an outcome, was selected as it appeared to hold promise for improvements in overall compliance to be readily made, provided its causes were understood. Complexity was considered to be the most likely cause of unintentional non-compliance, and those who prepared their own income tax return, the group likely to be most affected. The study used both a quantitative and qualitative component from which a number of convergent results emerged. These included that the major cause of complexity was the ambiguity of tax laws and the volume of explanatory material required. Further, personal taxpayers were committed to compliance even though they regarded the system as less than fair. Together, complexity and commitment to compliance caused taxpayers to experience unnecessary compliance costs. Where taxpayers completed their own return, complexity resulted in a high level of errors that generally resulted in an overstatement of tax liability. In addition, some taxpayers chose to be over-compliant as a means of dealing with complexity and commitment. It was concluded that complexity compromised the integrity of the Australian income tax system by imposing an unfair burden on personal taxpayers in respect of both tax paid and compliance costs incurred. However, there appeared to be little, if any, financial incentive for the tax authority to address the causes of complexity for personal taxpayers.