HOW DO ARMENIA S TAX REVENUES COMPARE TO ITS PEERS? A. Introduction

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1 HOW DO ARMENIA S TAX REVENUES COMPARE TO ITS PEERS? A. Introduction Armenia s revenue-to-gdp ratio is among the lowest relative to other CIS countries and selected Eastern European countries 1 (Figure 1). At less than 23 Figure 1: General Government in Selected percent of GDP in Transition Countries, 2008, Armenia (Percent of GDP) 60 ranked second lowest after Tajikistan in terms of its total revenue collection. Belarus recorded the highest revenueto-gdp ratio of 52 percent in 2008, followed by Azerbaijan and Russia 0 (48 percent), which are major oil produces, and thus rely more on nontax revenue, Ukraine (43 percent), and Moldova (40 percent). Georgia Tax Social Contribution Non Tax collected about 31 percent of its GDP in revenues, with slightly higher share of non-tax revenue relative to Armenia. Since 2003, the increase in the ratio of total revenue-to-gdp has not been significant. Despite double digit growth over six consecutive years ( ), the revenue-to-gdp ratio increased only by 1 ½ percentage points of GDP over the period with the tax-to- 25 GDP ratio increasing by less than ½ 20 percentage points of GDP between and However, tax collection, including social 10 contributions, gained momentum in and 2008, contributing to a 0 sizeable rise in the tax-to-gdp ratio by more than 2 percentage points of GDP, from 17.8 percent in 2006 to 20 percent in 2008 (partly associated with the build-up of tax credits). Figure 2: Armenia: General Government, (Percent of GDP) TAX Social Contribution Non Tax 1 The broader set of comparator countries include Azerbaijan, Belarus, Estonia, Georgia, Kazakhstan, Latvia, Lithuania, Moldova, Mongolia, Romania, Russia, Tajikistan, Ukraine, and Uzbekistan. However, lack of data in some cases, may limit the comparison to a subset of these countries. 2 Given the exceptional fall in revenues in 2009, on the back of the global economic crisis, the discussion in this note is largely based on comparison of 2008 revenue ratios.

2 - 2 - The relatively weak revenue performance is largely attributed to low tax collection, while non-tax revenue plays only a secondary role. Armenia s tax-to-gdp ratio is low when compared with that of other countries that have much smaller bases to tax (Figure 3). This suggests that there is large revenue potential that remains to be tapped. In 2008, Armenia s tax ratio, excluding social contributions, was 17.1 percent of GDP, which was less than that of most of its regional comparators, including those with lower per capita income (Georgia 3, Kyrgyz, Moldova, Mongolia, Ukraine, and Uzbekistan). Indeed, Armenia ranked the fourth from bottom among CIS and other selected Eastern European countries, with only Azerbaijan, Tajikistan, and Kazakhstan to a much lesser extent performing worse. Moreover, and while recognizing the structural differences between Armenia and other countries with lower income across the globe, for illustration, it is notable that Armenia s tax ratio in 2008 was lower than that of Bolivia, Guyana, Kenya, Nicaragua, Senegal, and Vietnam. Figure 3: Tax-to-GDP ratio and Per capita income¹ in Armenia and Selected Countries, BOL Regional Comparators Others MNG 27.0 RUS 25.0 VNM GEO MDA Tax-to-GDP ratio KGZ ZMB KEN SEN UZB NIC GUY UKR ARM CPV ROM TJK TGO TZA CIV AZE KAZ MOZ 13.0 UGA Per Capita Income ¹Size of the ball refers to GDP per capita in constant 2000 $US Source: IMF Government Finance Statistics and World Development Indicators of the World Bank 3 In 2008, Georgia collected about 24.9 percent of GDP in tax revenues, including social contributions which was unified with the income tax starting 2008.

3 - 3 - Weaknesses in taxes on incomes, and to a lesser extent on goods and services, explain most of the gap in the tax-to-gdp ratio between Armenia and its comparators (Table 1). Taxes on goods and services (goods tax) and taxes on income, profits, and capital gains (income tax) contribute the main share of tax revenue in all countries. Armenia s performance with respect to both groups of taxes lags behind that of its regional peers, including countries with lower per capita income as well as non-commodity exporters. Moreover, Armenia s weaknesses seem to be more prevalent in collecting income taxes rather than taxes on goods and services, as Armenia collected about 3 percentage points of GDP less in income taxes relative to the average collection of its peers, while it lagged behind its peers by about 1 percentage points of GDP with respect to collection of goods tax (Table 1). Over the period , Armenia ranked fourth from bottom, following Tajikistan, Kyrgyz, and Moldova, with respect to revenues from income taxes; and fourth from bottom, following Kazakhstan and commodity exporters (Azerbaijan, Mongolia, and Russia), with respect to revenues from the goods tax. While the ranking may not be as alarming, it is important to keep in mind that low tax collection in commodity exporters typically reflects the more benign revenue situation, and thus, less pressure to collect more revenues. The performance has been weaker relative to peers in 2008, as Armenia collected less than 4 percent of GDP in income taxes, while Georgia and Azerbaijan collected 9.9 percent and 8.7 percent, respectively. This ranks Armenia second lowest, with only Moldova Table 1: s in Armenia and Selected Regional Countries ( ) 1/ Average Collection ( ) (in percent of GDP) Tax Composition (in percent of tax revenue) Total Total Tax Social Goods Income Trade Other Contributions Other Goods Income Trade Other Armenia Azerbaijan Belarus Estonia Georgia Kazakhstan Kyrgyz Lithuania Moldova Mongolia Russia Tajikistan Ukraine Uzbekistan Regional Comparators 3/ with lower income 4/ with higher income 5/ Non-commodity exporters 6/ Armenia Difference between Armenia in 2008 and the average of selected regional comparators Regional Comparators 3/ with lower income 4/ with higher income 5/ Non-commodity exporter 6/ Source: IMF Government Finance Statistics, and various staff reports 1/ Countries were selected on the basis of (i) similarities to Armenia's level of development and/or economic structures, (ii) geographical proximity, and/or (iii) being landlocked 2/ In percent of total revenues 3/ Azerbaijan, Belarus, Estonia, Georgia, Kazakhstan, Kyrgyz, Lithuania, Moldova, Mongolia, Tajikistan, Russia, Ukraine, and Uzbekistan 4/ Georgia, Kyrgyz, Moldova, Mongolia, Tajikistan, Ukraine, and Uzbekistan 5/ Azerbaijan, Belarus, Estonia, Kazakhstan, Lithuania, and Russia 6/ Belarus, Estonia, Georgia, Kazakhstan, Kyrgyz, Lithuania, Moldova, Tajikistan, Ukraine, and Uzbekistan

4 - 4 - performing worse. An analysis of the weaknesses of Armenia s tax performance will thus have to focus on these two types of taxes that carry most of the potential, with particular emphasis on addressing weaknesses in income tax collection. Gaps in revenue collection are mainly rooted in weak tax administration and shortcomings in tax policy design. The size of the informal economy remains very large 4, pointing to widespread tax evasion, owing largely to weak tax administration an issue that lies at the heart of the problem. Moreover, and while tax rates do not seem to diverge considerably from those in other countries (Tables 3 and 4), weaknesses in tax policy remain, including tax exemptions e.g., agricultural production 5 policy loopholes, and preferential tax regimes for certain sectors. For instance, large businesses in the fuel and tobacco sectors are currently taxed under the presumptive regime, with light tax burden that has been declining over time (Figure 4). B. Tax structure in Armenia and other transition economies Armenia relies heavily on indirect taxes (VAT, excises), which constituted about 9.5 percent of GDP and contributed about 56 percent of total tax revenue in 2008 (Table2). Taxes on value-added contributed about 50 percent to total tax revenue collection in 2008, representing more than 8 percent of GDP, with more than two-thirds of this amount collected at the border. Since it is relatively easier to collect revenues at the border, the relatively small share of domestic VAT in total VAT collection 6 would point to compliance and evasion risks, owing in part to Table 2: Armenia: General Government Tax In percent of GDP In percent of total taxes Total Tax Value-added tax Excises Profit tax Personal income tax Custom duties Land tax Presumptive tax Other taxes Property tax Social contributions (SC) Tax and SC Sources: Ministry of Finance informality and weak tax administration. Moreover, increasing the share of domestic VAT in total VAT collection would shield VAT revenues from large fluctuations. The latter would be 4 No recent estimates are available, but the World Bank quotes estimates by other analysts that it could be as much as percent of GDP. Available at: ml 5 However, the ratio of tax-to-non-agriculture GDP in 2008 was about 20.4 percent, which suggests that even after controlling for some tax policy weaknesses, the tax-to-gdp ratio remains low. 6 In Azerbaijan, about 60 percent of VAT revenues are collected domestically.

5 - 5 - the case when over-relying on import VAT that tend to fluctuate in line with import volatility as was indeed the case during Excises contributed about 7 ½ percent to total tax collection in 2008.The overall share of indirect taxes, nevertheless, declined from 63 percent in 2003 to 56 percent in 2008, driven by a decline in the share of excises 7 particularly domestic excise while the share of VAT increased slightly. VAT revenue productivity 8 improved but remains below potential (Table 3). VAT productivity in Armenia increased from 0.35 percent in 2003 to 0.5 percent in However, it still remains low compared to most other selected transition economies, which may in part reflect policy gaps due to differences with respect to exemptions, as well as compliance gaps owing to differences regarding tax administration capacity. In 2008, Armenia ranked third from bottom in terms of VAT productivity, with only Russia and Lithuania performing worse. Although, Armenia s VAT rate is relatively high, it is on par with that of Belarus, Moldova, and Ukraine, all of which have higher VAT revenue-to-gdp ratio. Thus, if revenue Table 3: VAT Tax Rates, and Productivity in Selected Transition Countries, 2008 VAT 2008 Tax Rate 1/ (Percent of GDP) Productivity Armenia Azerbaijan Belarus Estonia Georgia Kazakhstan Lithuania Moldova Romania Russia Ukraine Sources: Country authorities and fund staff. 1/ VAT tax rate as end of productivity was 0.64 percent the highest efficiency recorded in the region Armenia s VAT revenue-to-gdp ratio would have been 10.5 percent, which would be among the highest in the region. The share of direct taxes (income, profits, and capital gains), which tend to grow with income and enhance revenue buoyancy, increased from 15 percent of total tax revenue in 2003 to 23 percent in Table 2 suggests that profit taxes are the second largest tax category following VAT. It contributed about 14 percent of total tax collection in 2008 and about 2 ½ percent of GDP. Personal income tax (PIT) is the third largest tax category with 9 percent contribution to total tax revenue in Presumptive taxes collected from specific activities (excluding presumptive payments on tobacco and fuel) contributed about In 2008, the nominal amount of excises was 10 percent less than that of 2003, and as such, the share of domestic excises in total tax revenue in 2008 was about one-third that of VAT revenue productivity reflects on the effectiveness or efficiency of revenue collection given the prevailing standard VAT rate, i.e., it measures measure of how much revenue relative to the tax base (i.e., consumption) each percentage point of the VAT rate provides. It is calculated by taking the actual revenue collected as percent of consumption, divided by the standard VAT rate. 9 The estimated VAT revenue productivity includes VAT tax credits, and thus overstates the actual productivity. VAT revenue productivity, excluding VAT tax credits in 2008 is 0.33 percent, up from 0.27 in 2006.

6 - 6 - percent of total tax revenue. The share of simplified taxes have been steadily declining owing to some policy changes that took place in 2008, as the government limited access to the simplified tax regime to only the retail trade sector and the household services, and in 2009 the system was abolished. Despite the increasing share of direct taxes, their revenue productivity remains below that of other transition economies (Table 4). In Corporate Income Tax Personal Income Tax 2008, taxes on income contributed the largest share Tax Rate 1/ (Percent of Tax Rate 1/ (Percent of to total tax revenue in Productivity 2/ GDP) GDP) Azerbaijan (53 percent), and the second largest share in Georgia (40 percent). While in Azerbaijan, this could be partly explained by the higher corporate income tax (CIT) rate (22 percent), the CIT rate in Georgia is the same as that 1/ Corporate and income tax rates based on a summary report 2007/08. of Armenia, and yet it generated more than ½ percentage points of GDP more in revenue relative to Table 4: Income Tax Rates, s, and Productivity in Armenia and Selected Transition Countries, 2008 Productivity 2/ Armenia Azerbaijan Belarus Estonia Georgia Kazakhstan Latvia Lithuania Moldova Romania Russia Ukraine Sources: Country authorities and Fund staff estimates. 2/ Corporate (personal) income tax revenue productivity reflects the effectiveness or efficiency of revenue collection. It is calculated by taking the actual revenue collected as a percentage of GDP (=tax yield), divided by the corporate (personal) income tax rate. When the corporate (personal) income tax applies at different rates, an average of the lowest and highest marginal corporate (personal) income tax rate is used as an approximation Armenia. With respect to PIT, Armenia s tax rate (two-bracket rates of percent) is slightly smaller than that of Georgia (flat rate of 20 percent, including social contributions). Yet, the stronger performance of PIT in Georgia (6.8 percent of GDP, including social contributions) relative to Armenia s performance (4.4 percent of GDP, including social contributions) would not be sufficiently explained by the slightly higher tax rate. A comparison of CIT productivity and PIT productivity across selected transition economies (Table 4) suggests that Armenia ranks second from bottom with respect to both taxes, with only Estonia and Azerbaijan performing worse with respect to CIT and PIT productivity, respectively 10. Weaknesses in income tax collection are explained by weak tax administration and tax evasion, including through under-declaration of wages, and tax policy shortcomings that grant tax exemptions to the agriculture sector, and tax incentives to large companies The estimated revenue productivity for income taxes includes profit and income tax credits, and thus overstates the actual productivity. CIT revenue productivity, excluding CIT tax credits in 2008 is 0.08 percent, down from 0.10 percent in PIT revenue productivity, excluding PIT tax credits in 2008 is 0.07 percent, up from 0.06 percent in In order to encourage development of Armenian capital market, parliament enacted a law in June 2009 that will reduce the profit tax burden of listed companies by 50 percent (up to AMD 300 million, approximately USD 750,000) per year from 2009 to 2012 (Source: Armenia Pocket Tax Book, PriceWaterHouseCoopers)

7 - 7 - Taxes collected under the presumptive regime on tobacco and fuel declined over the period both as a share of Figure 4: Presumptive Payments on GDP and of total tax revenue Cigarette and Fuel in Armenia ( ) (Figure 4). In fact, presumptive payments on tobacco products (both imported and domestically-produced) and on imported petrol both halved from 1.4 percent of GDP in 2003 to of GDP in The contribution of Tax on Cigarette as % of GDP these sectors to total tax revenue has Tax on Petrol as % of GDP also declined, as the share of Tax on Diesel as % of GDP presumptive payments on cigarettes Tax on Imported Fuel as Perecent of Value of Imports (right scale) fell from 10 percent in 2003 to only 4 percent in 2008, and that of fuel from about 12 percent in 2003 to less than 5 percent in Presumptive payments on imported fuel also declined from 50 percent of total value of imported petroleum in 2003 to 28 percent in The IMF has advised to move these products from the presumptive taxation regime to the regular taxation regime in order to enhance both the efficiency and equity functions of the tax system, while increasing the tax burden on these sectors. In a welcome step, the government submitted to parliament legislation to abolish the presumptive taxation regime for tobacco and petroleum products. The new legislation is a mix of VAT ad valorem and specific excise regime. While under the proposed tax regime, the risk of underreporting of the actual value of import and domestic production exists, with a developed tax administration system this would be less of a concern. While the share of tax arrears in total domestic revenues has declined between 2006 and 2008, the outstanding debt as a proportion of domestic tax revenue remains high relative to other selected transition countries 12 (Table 5). Moreover, and despite the drop in this ratio, the absolute amount of outstanding debt continues to increase (Table 6). The accelerating growth of tax arrears would point to heightened compliance and evasion risks. While it is not uncommon that tax compliance deteriorates during economic slowdowns, as was the case in 2009, the upward trend in the absolute value of Armenia s tax arrears continued to accumulate even during periods of economic boom (Table 6). Table 5: Tax Arrears in Selected Transition Countries, (Percent of Domestic Tax Collection) Armenia 1/ Kyrgyz 2/ 19.5 Latvia 2/ Lithuania 2/ Moldova 2/ Ukraine 2/ / Source: Armenian Authorities and Fund staff estimates 2/ Source: Various FAD TA reports 12 In OECD countries, tax arrears commonly range from about 5-10 percent of current tax collections

8 - 8 - Table 6: Armenia: Trends in Tax Arrears ( ) Domestic collection (In billions of drams) Tax arrears (In billions of drams) Share of Tax arrears in domestic revenues Growth rate of tax arrears Source: Armenian Authorities and Fund staff estimates C. RECENT ACHIEVEMENTS AND KEY REFORMS GOING FORWARD The government has made tax administration and policy reforms key priority. Several reforms have been implemented and others are in the pipeline. Just to mention a few, the introduction and expansion of e-filling as part of the introduction of a comprehensive electronic management system, the restructuring of the SRC by adopting a function-based organizational structure, the introduction of a VAT registration threshold, the abolishment of the simplified tax regime, the improvement in the timeliness of VAT refund processing, the on-going progress on setting an independent tax appeals committee to enhance taxpayers confidence and hence compliance, and the on-going progress on adopting the tax code. Tax administration reforms should focus, among other measures, on: Improving tax audits and enhancing tax compliance in line with modern tax administration based on self-assessment, by moving to risk-based selection mechanism and cross-checking Improving the interpretation of tax laws and regulations Addressing the systemic weaknesses underlying tax credits Enhancing the capacity of large taxpayer inspectorate to increase the share of revenues collected from large taxpayers in total domestic revenue collection Limiting the growth in tax arrears and intensifying efforts to recover existing stock of tax arrears Tax policy reforms should focus, among other measures, on: Eliminating preferential tax regimes for certain sectors, e.g., moving tobacco and fuel products from the current presumptive regime to the regular regime, with a view to increasing the contribution of these sectors to revenues. Minimizing tax exemptions and other tax expenditures and incentives, including those granted for the agricultural sector.

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