OECD – TAX ADMINISTRATION RESPONSES TO COVID-19: ASSISTING WIDER GOVERNMENT. 1. In response to the COVID-19 crisis, many tax administrations have taken on new roles to assist in the provision of wider government support. In many cases these have entailed responsibilities not normally provided by tax administrations, such as making support payments to citizens or providing new forms of analytical assistance to other parts of government. The speed with which such measures have to be implemented presents a number of challenges but also offers opportunities for learning lessons and for improving processes going forward, including as regards resilience and agility as well as closer working with other government agencies. 2. This document captures some of the new responsibilities taken on by tax administrations and suggests some considerations that administrations may wish to take into account. These new roles are described in the following categories: •Financial assistance, providing support to citizens and businesses, whether closely targeted or on a more blanket basis; •Providing services, using tax administration staff or services to support wider government COVID-19 responses; and•Information assistance, supporting government by sharing information or using the administration’s data analytics capabilities.3. Following the description of the challenges and potential mitigation strategies, the document also briefly describes the opportunities that may arise from taking on these new responsibilities including the use of swift development and implementation processes. Finally, an overview of some of the new responsibilities introduced by Forum on Tax member administrations is contained in Annex A. These examples are not intended to be comprehensive but rather to assist administrations in their domestic considerations, including where discussions with peers might be helpful. 4. In taking on these new roles, there are a number of common issues that tax administrations are likely to face, including the:•Rapid development of IT solutions.The need to provide large-scale support quickly in a time of crisis will often require an equally rapid development of new IT tools. Compared to previous IT development, this may also require more agile forms of decision-making in the developmentphase. Such agile methodologies are generally based on co-creation between business and IT departments with joint decision making, adaptation and testing to a tight timetable. The main downside is that the compressed timescales may limit consultation and evaluation prior to launch with potential implications for functionality. Compressed timetables may also reduce the time available for testing during the different phases of implementation, carrying risks for stability. It will be important to understand and document the risks involved and to maintain focus on the “must-haves”.•Fraud risks. It is likely that a trade-off will need to be made as regards the speed with which support is to be provided to large numbers of people and the risks of fraud. Outside of system vulnerabilities (e.g. to hacking or internal fraud), this essentially depends on two factors: what level of verification of entitlement is required prior to payment and what information is available. to allow for cost-effective post-payment compliance checks. These issues need to be considered together in both the design and implementation of the policy.As regards verification, there are two ends of the spectrum. At one end is verification which can be done based on robust information already held by the tax administration (or other government agency) for processes which are already subject to high levels of verification, such as payments of certain benefits and refunds as well as regulatory processes. At the other end, is a process with a high degree of self-verification and limited ability for the administration toperform cross-checks prior to making payments. The more that self-verification is used, the more administrations may wish to focus on risk assessment prior to payment as well as the development of a post-payment compliance strategy. A post-payment compliance strategy might, for example, require the provision of qualifying evidence after the event, the provision of robust identity and contact details of the person or business, the use of electronic and traceable payments, etc. In any event, the risks of fraud and the acceptance of risk levels should be well documented and signed off at appropriate levels of seniority. •Data protection. Providing support at speed may require the use of data held by the administration, provided by other government departments or received from third parties, for reasons other than those for which the data was originally provided. This can create data and privacy protection risks and administrations would be well advised to carry out a data protection impact assessment and to consult with the relevant data protection authorities. In some cases, it may require some changes to the legal framework or the assumption of some degree of legal risk. In some circumstances, it may be possible to obtain advanced consent for the use of data from recipients of support. For example, there might be a requirement for consent by the applicant to use specified data for verification purposes as a condition of being able to receive the support. •Cooperation on policy design and implementation. Decisions by policymakers on some forms of fiscal support through the tax administration may also fall short of desired outcomes unless administrability issues, effective targeting and fraud risks are fully taken into account. It may, therefore, be sensible for tax administrations to be involved in the design of policy from as early a stage as possible, including advising on possible alternative approaches. Ideally policy design and implementation discussions should involve other agencies that have responsibility for making large scale payments to citizens, such as social security and pension benefits, since they will have extensive experience on application processes, evidence requirements and fraud risks. Co-design will also allow policy makers to be involved in decisions about the risks involved, including those related to the delivery of projects to time and to budget, as well as operational risks and fraud risks. Additionally, it will allow administrations and policy makers to agree on requirements for monitoring and evaluation purposes.•Capturing decisions and lessons learnt.Given the scale and scope of the support programmes, it will be important that there is an effective audit trail for decisions taken, risk identification, mitigation strategies and risk acceptance. In addition, it may be useful to begincapturing lessons learnt while everything remains relatively fresh and relevant personnel are still in place. This may be useful for the future resilience and agility of tax administrations both in general and for future crisis management (including the possibility of future waves of the virus). Administrations may wish to develop a common template looking at learnings in the policy design phase, the implementation phase, the launch and post-launch phase, possibly commissioning a small group of experts to undertake this work. This could cover descriptions of the process and an initial evaluation of the effectiveness of, among other things: different governance arrangements; the operation of project teams; systems resilience and adaptabilityissues; legal issues; budgets; testing; monitoring and evaluation; etc. Version 30 July 2020.
