Categoria: Tributação Internacional

OECD Taxation Working Papers N. 41- Taxation and the future of work

Recent policy discussion has highlighted the variety of ways in which the world of work is changing. One development prevalent in some countries has been an increase certain forms of non-standard work. Is this beneficial, representing increased flexibility in the workforce, or detrimental, representing a deterioration in job quality driven by automation, globalisation and the market power of large employers? These changes also raise crucial issues for tax systems. Differences  in tax treatment across employment forms may create tax arbitrage opportunities. This paper investigates the potential for such opportunities for eight countries. It models the labour income taxation, inclusive of social contributions, of standard employees and then of self-employed workers (with applicable tax rules detailed in the paper’s annex). The aim is to understand whether countries’ tax systems treat different employment forms differently, before approaching the broader question of whether differential treatment has merit when evaluated against tax design principles.

OECD – Tax and digitalisation – Policy Note

The digital transformation of the economy calls into question whether the international tax rules, which have largely been in place for most of the past 100 years, remain fit for purpose in the modern global economy. While good progress has been made in tackling base erosion and profit shifting (BEPS) through the BEPS Project, some of the more fundamental tax challenges posed by digitalisation have remained unaddressed. Through the BEPS Project and more recently, through the Inclusive Framework on BEPS, discussions on how to address the tax challenges that arise from digitalisation have been ongoing. Recent international efforts to address these issues have highlighted the divergent positions of many jurisdictions. While the introduction of unilateral measures in a number of countries has underscored the urgency of the issue and the need to re-assess some of the key international tax principles, these divergent positions have made a consensusbased solution difficult to achieve. In a significant advance, the 128 members of the Inclusive Framework have recently agreed a policy note – “Addressing the Tax Challenges Arising from Digitalisation” (OECD, 2019a) – that identifies concrete proposals in two pillars to explore and which could form the basis of a global, consensus-based solution. These pillars involve the re-allocation of taxing rights among jurisdictions and the need to address remaining BEPS issues. This policy note will be the basis for detailed analysis over the next 18 months as the Inclusive Framework works towards delivering a solution to the G20 by the end of 2020. In November 2015, two years after the G20 Leaders endorsed the ambitious Action Plan on BEPS, the BEPS package of 15 Actions to tackle tax avoidance was agreed by all OECD and G20 countries and endorsed by G20 Leaders. It was designed to stop countries and companies from competing on the basis of a lack of transparency, artificially locating profit where there is little or no economic activity, or the exploitation of loopholes or differences in countries’ tax systems. The work on tax and digitalisation has been a key aspect of the BEPS Project since its inception. Published as part of the BEPS package in October 2015, the Action 1 Report found that, as a result of the pervasive nature of digitalisation, it would be difficult, if not impossible, to ring-fence the “digital economy” from the rest of the economy for tax purposes. In other words, countries agreed that there was no such thing as a “digital economy”, but rather that the economy itself had become digitalised and that this trend was likely to continue. Following a mandate by G20 Finance Ministers in March 2017, the Inclusive Framework, working through its Task Force on the Digital Economy (TFDE) published Tax Challenges Arising from Digitalisation – Interim Report 2018: Inclusive Framework on BEPS (the Interim Report). The Interim Report provided an in-depth analysis of value creation across new and changing business models in the context of digitalisation and the tax challenges they presented. These challenges included risks remaining after BEPS for highly mobile income -producing factors which still can be shifted into low-tax environments. While members of the Inclusive Framework did not converge on the conclusions to be drawn from this analysis, they committed to continue working together towards a final report in 2020 aimed at providing a consensus-based long-term solution, with an update in 2019. Conscious of the significance and urgency of the issue, the TFDE has intensified its work since the delivery of the Interim Report. Drawing on the analysis included in the Action 1 Report as well as the Interim Report, and informed by recent discussions of the TFDE on a “without prejudice” basis, a number of concrete proposals have been outlined in “Addressing the Tax Challenges Arising from Digitalisation” (OECD, 2019a). The Inclusive Framework will continue to explore these proposals, including through a public consultation process, with the aim of developing a detailed work programme to guide the Inclusive Framework’s efforts to agree a global, long-term solution by the end of 2020.

OECD – MODEL MANDATORY DISCLOSURE RULES FOR CRS AVOIDANCE ARRANGEMENTS AND OPAQUE OFFSHORE STRUCTURES

OECD – MODEL MANDATORY DISCLOSURE RULES FOR CRS AVOIDANCE ARRANGEMENTS AND OPAQUE OFFSHORE STRUCTURES. Foreword: On 15 July 2014 the OECD published the Standard for Automatic Exchange of Financial Account Information in Tax Matters, also known as the Common Reporting Standard or CRS. Since then 102 jurisdictions have committed to its implementation in time to commence exchanges in 2017 or 2018. With exchanges under the CRS having now commenced amongst almost 50 jurisdictions there has been a major shift in international tax transparency and the ability of jurisdictions to tackle offshore tax evasion. At the same time, information from academic studies and media leaks, combined with more recent information collected through compliance activities of a number of tax administrations, as well as the results from the OECD’s disclosure initiative demonstrate that professional advisers and other intermediaries continue to design, market or assist in the implementation of offshore structures and arrangements that can be used by non-compliant taxpayers to circumvent the correct reporting of relevant information to the tax administration of their jurisdiction of residence, including under the CRS. It is against this background that the Bari Declaration, issued by the G7 Finance Ministers on 13 May 2017, called on the OECD to start “discussing possible ways to address arrangements designed to circumvent reporting under the Common Reporting Standard or aimed at providing beneficial owners with the shelter of non-transparent structures.” The Declaration states that these discussions should include consideration of “model mandatory disclosure rules inspired by the approach taken for avoidance arrangements outlined within the BEPS Action 12 Report.” The Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures contained in this report were approved by the Committee of Fiscal Affairs (CFA) on 8 March 2018. This approval does not entail endorsement as a minimum standard. The design of the model rules draws extensively on the best practice recommendations in the BEPS Action 12 Report while being specifically targeted at these types of arrangements and structures.

OECD Taxation Working Papers – Taxation and the future of work. How tax systems influence choice of employment form

Recent policy discussion has highlighted the variety of ways in which the world of work is changing. One development prevalent in some countries has been an increase certain forms of non-standard work. Is this beneficial, representing increased flexibility in the workforce, or detrimental, representing a deterioration in job quality driven by automation, globalisation and the market power of large employers? These changes also raise crucial issues for tax systems. Differences in tax treatment across employment forms may create tax arbitrage opportunities. This paper investigates the potential for such opportunities for eight countries. It models the labour income taxation, inclusive of social contributions, of standard employees and then of self-employed workers (with applicable tax rules detailed in the paper’s annex). The aim is to understand whether countries’ tax systems treat different employment forms differently, before approaching the broader question of whether differential treatment has merit when evaluated against tax design principles. This is OECD Tax Policy Working Paper No. 41. The annex to this paper is Tax Policy Working Paper No. 42, accessible here: DOI: https://doi.org/10.1787/6b20cce5-en. Recent policy discussion has highlighted the variety of ways in which the world of work is changing. In this regard, one recent development has been that many countries have seen increases in forms of non-standard work. This raises questions over whether such trends have been beneficial, representing increased flexibility and adaptability in the workforce, or detrimental, representing a deterioration in job quality driven by automation, globalisation, labour market deregulation and the increasing market power of large employers. These changes also raise crucial issues for tax systems. Labour taxes (i.e., personal income tax and social security contributions) are the largest tax category in an overwhelming majority of OECD countries. Tax differentials across employment types therefore have the potential to produce significant labour market effects, along with significant tax revenue consequences. This raises questions of the extent to which increases in some forms of nonstandard work are driven by tax considerations. Moreover, it raises questions of whether tax systems need to adapt to increases in non-standard work in OECD countries and, if so, how. Building on the OECD’s Taxing Wages framework, this paper analyses the labour (and, where relevant, capital) income taxation, inclusive of social contributions and non-tax compulsory payments, of different employment forms for a set of eight countries. The key question of interest is whether the tax treatment of self-employment differs from that of standard employment, as tax treatment differentials between these two groups may create tax arbitrage opportunities. This paper assesses whether differential treatment has merit when evaluated against accepted notions of good tax design. The main results are as follows: • Firms that contract labour from self-employed workers instead of hiring standard employees generally face lower tax burdens on a per-worker basis. In countries where this tax treatment differential is large (e.g., the Netherlands, the United Kingdom), the tax system may be a driver of increased self-employment. • The contract type that minimises the tax cost of labour may vary with the wage and other factors, such as bargaining power. For each country, the paper shows results for individuals earning a low wage through to those earning 250 percent of the average wage. In general, firms that contract labour from self-employed workers face a lower tax burden across the wage spectrum. • Firms may have the ability to further reduce their tax burdens by deducting labourrelated costs and other labour-related corporate income tax provisions from the corporate income tax base. As they can vary by employment form, deductibility rules are an important factor to consider in assessing which contract types tax systems may be incentivising.

OECD Taxation Working Papers N. 19: Taxation of Dividend, Interest, and Capital Gain Income

OECD Taxation Working Papers N. 19: Taxation of Dividend, Interest, and Capital Gain Income. This paper provides an overview of the differing ways in which capital income is taxed across the OECD. It provides an analytical framework which summarises the statutory tax treatment of dividend income, interest income and capital gains on shares and real property across the OECD, considering where appropriate the interaction of corporate and personal tax systems. It describes the different approaches to the tax treatment of these income types at progressive stages of taxation and concludes the discussion of each income type by summarising the different systems in diagrammatic form. For each income type, the paper presents worked calculations of the maximum combined statutory tax rates in each OECD country, under the tax treatment and rates applying as at 1 July 2012. These treatments and rates may have changed since this date and the paper should not be interpreted as reflecting the current taxation of capital income in OECD countries. (…) Many individuals, especially employees and pensioners, do not generate capital income from their own business activity, but they may have capital income from holding funds in deposit accounts or bonds, or from the ownership of shares or real property. The tax systems applied to these forms of income differ within and across OECD countries according to the nature, timing and source of the revenue, and the income level and characteristics of the income-earner. As a first step toward a comparative, descriptive analysis of the differing regimes for the taxation of capital income in OECD countries, this paper provides an analytical framework which summarises the different types of tax systems applied to three simple types of capital income earned by resident individuals in a domestic setting: · Dividend income from ordinary shares; · Interest income from cash deposits and government bonds; and · Capital gains realised on real property and shares. The paper uses this framework to describe the different types of tax systems that can apply to these types of income, noting those used in each OECD country and considering, where appropriate, the interaction between corporate and personal taxation. It calculates the maximum statutory combined tax burden on each income type: tracing the impact of different tax treatments from pre-tax income, through the relevant corporate and personal tax systems, to the post-tax income received by a representative individual. The descriptions of the different progressions are supplemented with diagrammatic and algebraic presentations and worked examples for each country. The tax rates presented in this paper represent the maximum possible burden on capital income under the relevant tax systems and statutory rates, rather than the effective tax rates on these different income types. At the individual level, the paper assumes the taxpayer to pay the highest marginal rate of tax and does not consider personal circumstances, such as the existence of family tax credits, that may reduce effective income tax rates. At the corporate level, the impact of deductions or tax planning in reducing effective tax rates is also not considered. Two related OECD work streams will calculate effective tax rates on capital income: the first will consider effective tax rates on corporate income, including the impact of tax planning; and the second, effective tax rates on savings income at the individual level for a broader range of tax payers and savings opportunities than this paper. The paper’s descriptions and analysis are somewhat stylised in order to distil the main features of what are often complex tax regimes, but it provides an overview of: · The differing ways in which dividends, interest and capital gains are taxed; · How far the relative taxation of dividends, interest, and capital gains varies in each country and from country to country; and · The differing ways in which so-called double taxation of dividends (and possibly, capital gains) at corporate and individual levels is attenuated. (Michelle Harding)

OECD/G20 Base Erosion and Profit Shifting Project – PREVENTING THE GRANTING OF TREATY BENEFITS IN INAPPROPRIATE CIRCUMSTANCES

OECD/G20 Base Erosion and Profit Shifting Project – PREVENTING THE GRANTING OF TREATY BENEFITS IN INAPPROPRIATE CIRCUMSTANCES. ACTION 6: 2015 FINAL REPORT. Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax sovereignty by claiming treaty benefits in situations where these benefits were not intended to be granted, thereby depriving countries of tax revenues. Countries have therefore agreed to include anti-abuse provisions in their tax treaties, including a minimum standard to counter treaty shopping. They also agree that some flexibility in the implementation of the minimum standard is required as these provisions need to be adapted to each country’s specificities and to the circumstances of the negotiation of bilateral conventions. Section A of this report includes new treaty anti-abuse rules that provide safeguards against the abuse of treaty provisions and offer a certain degree of flexibility regarding how to do so. These new treaty anti-abuse rules first address treaty shopping, which involves strategies through which a person who is not a resident of a State attempts to obtain benefits that a tax treaty concluded by that State grants to residents of that State, for example by establishing a letterbox company in that State. The following approach is recommended to deal with these strategies: • First, a clear statement that the States that enter into a tax treaty intend to avoid creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements will be included in tax treaties (this recommendation is included in Section B of the report). • Second, a specific anti-abuse rule, the limitation-on-benefits (LOB) rule, that limits the availability of treaty benefits to entities that meet certain conditions will be included in the OECD Model Tax Convention. These conditions, which are based on the legal nature, ownership in, and general activities of the entity, seek to ensure that there is a sufficient link between the entity and its State of residence. Such limitation-on-benefits provisions are currently found in treaties concluded by a few countries and have proven to be effective in preventing many forms of treaty shopping strategies. • Third, in order to address other forms of treaty abuse, including treaty shopping situations that would not be covered by the LOB rule described above, a more general anti-abuse rule based on the principal purposes of transactions or arrangements (the principal purposes test or “PPT” rule) will be included in the OECD Model Tax Convention. Under that rule, if one of the principal purposes of transactions or arrangements is to obtain treaty benefits, these benefits would be denied unless it is established that granting these benefits would be in accordance with the object and purpose of the provisions of the treaty. The report recognises that each of the LOB and PPT rules has strengths and weaknesses and may not be appropriate for, or accord with the treaty policy of, all countries. Also, the domestic law of some countries may include provisions that make it unnecessary to combine these two rules to prevent treaty shopping. Given the risk to revenues posed by treaty shopping, countries have committed to ensure a minimum level of protection against treaty shopping (the “minimum standard”). That commitment will require countries to include in their tax treaties an express statement that their common intention is to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements. Countries will implement this common intention by including in their treaties: (i) the combined approach of an LOB and PPT rule described above, (ii) the PPT rule alone, or (iii) the LOB rule supplemented by a mechanism that would deal with conduit financing arrangements not already dealt with in tax treaties. Section A also includes new rules to be included in tax treaties in order to address other forms of treaty abuse. These targeted rules address (1) certain dividend transfer transactions that are intended to lower artificially withholding taxes payable on dividends; (2) transactions that circumvent the application of the treaty rule that allows source taxation of shares of companies that derive their value primarily from immovable property; (3) situations where an entity is resident of two Contracting States, and (4) situations where the State of residence exempts the income of permanent establishments situated in third States and where shares, debt-claims, rights or property are transferred to permanent establishments set up in countries that do not tax such income or offer preferential treatment to that income. The report recognises that the adoption of anti-abuse rules in tax treaties is not sufficient to address tax avoidance strategies that seek to circumvent provisions of domestic tax laws; these must be addressed through domestic anti-abuse rules, including through rules that will result from the work on other parts of the Action Plan. The report includes changes to the OECD Model Tax Convention aimed at ensuring that treaties do not inadvertently prevent the application of such domestic anti-abuse rules. This is done by expanding the parts of the Commentary of the OECD Model Tax Convention that already deal with this issue and by explaining that the inclusion of the PPT rule in treaties, which will incorporate the principle already included in the Commentary of the OECD Model Tax Convention, will provide a clear statement that the Contracting States intend to deny the application of the provisions of their treaties when transactions or arrangements are entered into in order to obtain the benefits of these provisions in inappropriate circumstances. The report also addresses two specific issues related to the interaction between treaties and domestic anti-abuse rules. The first issue relates to the application of tax treaties to restrict a Contracting State’s right to tax its own residents. A new rule will codify the principle that treaties do not restrict a State’s right to tax its own residents (subject to certain exceptions). The second issue deals with so-called “departure” or “exit” taxes, under which liability to tax on some types of income that has accrued for the benefit of a resident (whether an individual or a legal person) is triggered in the event that the resident ceases to be a resident of that State. Changes to the Commentary of the OECD Model Tax Convention will clarify that treaties do not prevent the application of these taxes. Section B of the report addresses the part of Action 6 that asked for clarification “that tax treaties are not intended to be used to generate double non-taxation”. This clarification is provided through a reformulation of the title and preamble of the Model Tax Convention that will clearly state that the joint intention of the parties to a tax treaty is to eliminate double taxation without creating opportunities for tax evasion and avoidance, in particular through treaty shopping arrangements. Section C of the report addresses the third part of the work mandated by Action 6, which was “to identify the tax policy considerations that, in general, countries should consider before deciding to enter into a tax treaty with another country”. The policy considerations described in that section should help countries explain their decisions not to enter into tax treaties with certain low or no-tax jurisdictions; these policy considerations will also be relevant for countries that need to consider whether they should modify (or, ultimately, terminate) a treaty previously concluded in the event that a change of circumstances (such as changes to the domestic law of a treaty partner) raises BEPS concerns related to that treaty. This final version of the report supersedes the interim version issued in September 2014. A number of changes have been made to the rules proposed in the September 2014 report. As noted at the beginning of the report, however, additional work will be required in order to fully consider proposals recently released by the United States concerning the LOB rule and other provisions included in the report. Since the United States does not anticipate finalising its new model tax treaty until the end of 2015, the relevant provisions included in this report will need to be reviewed afterwards and will therefore be finalised in the first part of 2016. An examination of the issues related to the treaty entitlement of certain types of investment funds will also continue after September 2015 with a similar deadline. The various anti-abuse rules that are included in this report will be among the changes proposed for inclusion in the multilateral instrument that will implement the results of the work on treaty issues mandated by the OECD/G20 BEPS Project.

OECD WORK ON TAX AND DEVELOPMENT – 2018-9

OECD WORK ON TAX AND DEVELOPMENT – The work of the Centre for Tax Policy and Administration (CTPA) has changed dramatically in recent years, including in relation to the role of development and developing countries in our work. I am proud that an increasing number of developing countries are now integrated into our work, as equal members of the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) and the OECD/G20 Inclusive Framework on BEPS (the Inclusive Framework), with a voice on the creation and implementation of new international tax standards. This has been an evolving process. As globalisation increased, the challenges of cross-border taxation have extended beyond the OECD membership, and the CTPA accelerated our dialogue with developing countries accordingly. This started with our Global Relations Programme (GRP) in the early 90’s which has provided training and capacity building for over 25 000 tax officials from the developing world. Since then, we have created a Task Force on Tax and Development, we have expanded our Global Revenue Statistics database to cover more than 90 countries by the end of 2018, we have established audit programmes through our Tax Inspectors Without Borders (TIWB) initiative and we have set up tax crime investigation academies throughout the world. Of greatest significance however has been the establishment of the Global Forum and the Inclusive Framework, which have brought dozens of developing countries into the heart of the work of the CTPA. This has fundamentally changed the nature of how we operate, ensuring development is an integral concern across all of our work. It has also raised expectations as the CTPA is now seen as a key actor in the Domestic Resource Mobilisation (DRM) agenda. This process has been inspired by the wider development landscape, most recently with the Addis Ababa Action Agenda (AAAA) and the Sustainable Development Goals (SDGs). These agreements provide both a framework and a vision for how we can continue to develop international co-operaton in taxation to benefit development. The CTPA has been, and will continue to be, inspired by that vision that sees development as a universal agenda, and we will continue to mainstream development across all of our work. This booklet sets out how we have been doing this, and how we intend to do more in the future. (Preface by Pascal Saint-Amans). 2018-9.

OECD – TAX AND DEVELOPMENT: WHAT DRIVES TAX MORALE?

OECD – TAX AND DEVELOPMENT: WHAT DRIVES TAX MORALE? WHAT DO CITIZENS, PARTICULARLY THOSE IN DEVELOPING COUNTRIES, THINK ABOUT PAYING TAX? DOES IT MATTER? THIS STUDY PROVIDES FRESH ANALYSIS OF PUBLIC OPINION SURVEYS TO EXAMINE WHAT LIES BEHIND CITIZENS’ “TAX MORALE” – THEIR MOTIVATION TO PAY THEIR TAXES – OTHER THAN THEIR LEGAL OBLIGATION TO DO SO. Tax revenues provide governments with the funds they need to invest in development, relieve poverty, deliver public services and build the physical and social infrastructure for long-term growth. However, many developing countries face challenges in increasing their revenue from domestic sources. These challenges include a small tax base, a large informal sector, weak governance and administrative capacity, low levels of per capita income, domestic savings and investment and possibly tax avoidance by elites. Some countries, including half of those in sub-Saharan Africa, raise less than 17% of their gross domestic product (GDP) in tax revenues. This is the minimum level considered by the UN as necessary to achieve the Millennium Development Goals. By way of comparison, OECD countries raise on average close to 35% of GDP in tax revenues. Developing countries and development partners alike increasingly realise the importance of mobilising domestic financial resources for development (Box 1.1). For example, the Doha Declaration on Financing for Development (2008) and the Busan Partnership for Effective Development Cooperation (2011) both encourage a greater role for domestic resources, taxation in particular, in funding development Although there is a strong correlation between the level of a country’s development and its tax revenues, there are significant differences across countries at similar stages of development (see Annex A). For example, why is it that while Jordan and Guatemala have very similar levels of GDP per capita, tax revenues in Jordan are around 33% of GDP, while in Guatemala revenues only amount to around 13% of GDP (almost half of the expected level given its GDP per capita)? And why is it that the citizens of some countries are happy to pay their taxes (e.g. practically all Ghana’s citizens), while others are not (e.g. most of Serbia’s)? Research shows a significant correlation between tax morale and tax compliance in both developing and developed countries. For example, tax morale is an important determinant of the “shadow economy” and therefore has an impact on tax evasion (Torgler, 2011). Thus, understanding better what drives differences in tax morale across countries is a key element in understanding differences in tax compliance. It also offers a more “grassroots” perspective on tax systems than administrative and quantitative measures, such as tax to GDP ratio.

OECD Taxation Working Papers N. 2 – What is a “Competitive” Tax System?

OECD Taxation Working Papers N. 2 – What is a “Competitive” Tax System? 1. Statements about the importance of tax systems being ‘competitive’ are often made by business, politicians, lobbyists and other commentators, but what does this term mean? 2. In everyday usage ‘competitive’ is a relative concept. When applied to a business, it would mean that the firm in question is able to produce its output at the same or lower cost than other firms in the same line of business, or that it has some other advantage over them such as the quality of its product. In most industries a competitive firm would (as a result of its cost or other advantages over its rivals) be able to earn returns in excess of its cost of capital. 3. It is more difficult conceptually to apply the term ‘competitive’ to an economy as a whole rather than a particular business. An economy is made up of many different firms (plus extensive public sector provision of services). Moreover the structure of its production and the pattern of its trade will depend on its comparative advantage relative to other economies.2 Specialisation in line with comparative advantage increases production efficiency and raises living standards. 4. For a typical advanced economy (where natural resources and primary products make up a relatively small part of domestic output) there are likely to be strong links between the competitiveness of its firms and the overall levels of productivity and living standards that the country is able to sustain. Individual firms may then be ‘competitive’ internationally (in the sense of having a cost or other advantage relative to their foreign rivals, given the exchange rate, etc); and if a firm is not competitive, then national output and income are likely to be higher if the resources it would have used are redeployed to another line of business where profit opportunities are better. 5. Most of the drivers of the competitiveness of firms lie within the domestic economy. Thus the World Economic Forum, for instance, in its Global Competitiveness Report defines ‘competitiveness’ as ‘the set of institutions, policies and factors that determine the level of productivity of a country’. The level of productivity in turn sets the sustainable level of living standards. The Global Competitiveness Report weights together data pertinent to 12 ‘pillars of competitiveness’: institutions, infrastructure, macroeconomic environment, health and primary education, higher education and training, goods market efficiency, labour market efficiency, financial market development, technological readiness, market size, business sophistication and innovation. 6. There are likely to be significant overlaps and interactions between these ‘pillars’ and views may differ on precisely how they translate into increased production efficiency and growth potential. However, one approach to examining the impact of tax on ‘competitiveness’ is to consider how tax policy and administration impact on the various ‘pillars’ and hence productivity, etc. In practice, most taxes (not just the corporate income tax) can have an impact on competitiveness, as section B below indicates.

EUROsociAL – Buenas prácticas para el desarrollo de los Núcleos de Apoyo Contable y Fiscal (NAF).

EUROsociAL – Buenas prácticas para el desarrollo de los Núcleos de Apoyo Contable y Fiscal (NAF). Comprender que el pago de los impuestos constituye una parte esencial de nuestro papel como ciudadanos democráticos, y no una mera obligación dictada por el Estado, requiere de un profundo cambio cultural que no ha sido aun plenamente asumido por el conjunto de la sociedad. A esa falta de compromiso fiscal por parte de ciertos contribuyentes se añaden problemas en el empleo de los recursos públicos recaudados, como la ausencia de transparencia en las instituciones encargadas de gestionarlos o, incluso, el uso inapropiado de dichos fondos. Este conjunto de factores limita la capacidad y el alcance de las políticas públicas para la cohesión social, constituyendo un círculo vicioso que es preciso superar. América Latina pone de manifiesto la situación descrita. A pesar de los avances registrados en los últimos años, la presión fiscal promedio en la región (24,4% del PIB) sigue lejos de la media de la OCDE (31,2%)1 . A esto se añaden el fraude fiscal2 y la corrupción3 , problemas que erosionan los recursos disponibles para el desarrollo y generan desequilibrios en el contrato entre el Estado y los ciudadanos. El sistema tributario de los países de la zona muestra además un marcado carácter regresivo, con énfasis en los impuestos indirectos. Los Estados latinoamericanos necesitan ser eficaces en la detección y corrección del fraude, teniendo en cuenta que el único mecanismo de actuación no puede ser el coercitivo, sino que es imprescindible mostrar una ‘cara amable’ al contribuyente y facilitarle, en la medida de lo posible, el cumplimiento de sus obligaciones tributarias. Las administraciones fiscales son conscientes de que se requiere la colaboración ciudadana y mucha pedagogía. En este contexto, es importante considerar que el acceso a la información y a unos servicios públicos de calidad, fundamental en el perfeccionamiento de la democracia, aún encuentra barreras en Latinoamérica. Barreras que no se restringen a la cuestión económica, sino que también están vinculadas a dificultades sociales, culturales y educativas. En el ámbito fiscal, dichas barreras son más acentuadas, especialmente en razón de la complejidad que es inherente a los sistemas tributarios. Sin embargo, la complejidad afecta de forma diferente a los distintos grupos sociales. Mientras que una parcela de la sociedad tiene acceso a la información y a la contratación de profesionales especializados, los menos favorecidos encuentran dificultades para costear los servicios de las oficinas contables o aclarar sus dudas a través de los canales oficiales de las Administraciones tributarias, lo que acaba por generar una desigualdad real en la obtención de sus derechos y en el cumplimiento de sus deberes fiscales. (JAUME BLASCO).