2. Emerging Challenges for the Asia-Pacific Region in the COVID-19 Era

The coronavirus (COVID-19) pandemic has caused a multidimensional health and economic crisis, and adversely affected businesses and households everywhere. To support businesses and households, fiscal policy has played a big role in the immediate response to the crisis and will continue to play an important role in the economic recovery from COVID-19. In Asia and the Pacific, developing countries’ governments committed close to USD 3.7 trillion (ADB, 2021[1]) to respond to the pandemic as of March 2021 but even with this eye-wateringly large sum, economic losses for the region are estimated by the Asian Development Bank (ADB) at between USD 1.4 trillion to USD 2.2 trillion for 2020 alone (ADB, 2020[2]).  ADB also estimates the region will lose up to 167 million jobs with 78 million more people falling into extreme poverty, undoing several years of progress in poverty reduction (ADB, 2021[3]). Income inequality, already a significant problem in the region, has become even more marked as the vulnerable, including women and informal workers, have suffered job losses and slumping incomes at a faster rate than other groups (ADB, 2021[4]). Policies have varied depending on the challenges each country faces, with measures ranging from increased public spending on health to enhanced unemployment benefits, business investment incentives, and direct cash transfers to the most vulnerable.Tax administration measures have also been widespread across the world, including Asia.

The COVID-19 crisis has adversely impacted tax revenue collections in countries in the Asia and Pacific region because of the economic slowdown and fiscal stimulus packages that included tax stimulus measures (ADB, 2021[4]). Growth of Asia-Pacific developing countries’ gross domestic product (GDP) is projected to rebound to 7.3% in 2021 (ADB, 2021[5]), and to an extent, economic growth will recover revenue collection (Figure 2.1). However, the pandemic has exacerbated existing structural challenges in public finance. Unanticipated increases in public debt as a result of large fiscal measures to mitigate the impact of COVID-19, and shrinking tax revenues during the pandemic have worsened fiscal balances and created debt sustainability challenges in many developing countries in Asia and the Pacific (Figure 2.2). These facts imply that there is little room left for these countries to further increase external borrowing and vividly remind us of the importance of enhancing domestic resources to address debt sustainability.

While tax revenue serves as the major domestic revenue source among most countries, tax yields across developing countries in Asia and the Pacific have not increased concomitantly with the strong and steady GDP growth seen over the last decades.1 Even prior to the COVID-19 pandemic, many countries had recorded weak revenue performance.

Tax yields across Asia-Pacific developing countries are still on average substantially lower than in OECD countries, and have also been comparatively volatile in recent years. (Figure 2.3). The tax-to-GDP ratio in several developing Asia-Pacific countries remains below 15% (Bhutan, Indonesia, Lao PDR, Malaysia, Papua New Guinea) (Figure 2.4), undermining governments’ ability to provide a minimum level of public services to their citizens and to achieve development goals.

Overall, weaknesses are found in most tax types including personal income tax (PIT), corporate income tax (CIT) and tax on goods and services (Figure 2.4). In terms of PIT, many jurisdictions have numerous tax exemptions and concessions with overall low statutory tax rates on salary, wages and personal business income. Tax revenues from PIT in developing economies in Asia are lower than in advanced economies. Taxes on goods and services (e.g. value-added tax and excise tax) tend to dominate in some developing economies.

Aging populations will increase pressure on social security systems. However, financing for social security systems could be improved, as social security contributions are yet to be introduced in many countries or, even when in place, are often underutilised across the region. Similarly, the comparatively low use of recurrent taxes on immovable property may result in significant gaps in the revenue of subnational governments.

These examples demonstrate the importance of careful revenue management and attention to underlying vulnerabilities. These issues require strong attention now because governments need to secure sufficient financial resources to contain the spread of COVID-19, procure safe and effective vaccines and healthcare, and get the economy back on a sustainable recovery track without losing market confidence.

Achieving the Sustainable Development Goals (SDGs) is also important for Asia and the Pacific as the region is falling short on all of them (Figure 2.5). The Economic and Social Survey of the United Nations Economic and Social Commission for Asia and the Pacific found that developing countries in Asia and the Pacific would need USD 1.5 trillion annually to end extreme poverty and ambitiously move toward universal health coverage, quality education, and infrastructure, while staying on track to limit climate change (UNESCAP, 2019[8]). However, this amount will likely increase because of the impact of COVID-19. In this regard, while the role of external finance is crucial in filling fiscal gaps, domestic resource mobilisation (DRM) will be a crucial pillar as SDG 17, which includes targets to strengthen DRM, is the foundation for achieving all of the other SDGs. Raising domestic resources is not only pivotal in providing a source of direct financing to contain the spread of COVID-19, procure safe and effective vaccines, and get the economy back to a sustainable recovery track without losing market confidence, but tax policy also offers governments the tools to achieve other specific goals under the SDGs.

Thus, DRM will continue to be a major strategic priority in the aftermath of COVID-19 for developing countries in Asia and the Pacific to address debt sustainability and to achieve the SDGs. In this regard, ADB considers DRM to be one of five strategic agendas to develop a prosperous, inclusive, resilient and sustainable Asia and the Pacific (ADB, 2021[10]).

While the timing of actual tax reform will vary among each economy, it is an appropriate time for developing countries in the region to begin their preparatory work through knowledge sharing and capacity building. To this end, consideration needs to be given to challenges emerging from the COVID-19 crisis, which include (i) removal of tax stimulus measures; (ii) growing income and social inequality; (iii) expansion of the informal economy (iv) addressing the tax challenges arising from the digitalisation of the economy. Other challenges include the need to finance well-functioning systems of social protection and measures that stimulate economic growth that is labour intensive, and the need to tackle climate change as well as measures to improve healthy behaviours of people.

In the context of the pandemic, the optimal timing for the removal of the fiscal stimulus in place across countries including tax relief measures is never easy. Fiscal normalisation should be carefully calibrated and implemented in a phased manner. While many of developing countries in Asia and the Pacific may be considering reducing fiscal stimulus this year, they should bear in mind the lessons from premature fiscal consolidation after the global financial crisis. Such lessons have underscored the importance of looking closely at some of the leading, high frequency indicators to ascertain whether there are clear signs of recovery. Once visible signs of recovery and greater traction of economic growth are confirmed, governments can begin to consider easing or eliminating tax stimulus measures and strengthening DRM by restructuring tax policy to regain a balanced budget over the medium term.

According to the OECD database on country tax measures during the COVID-19 pandemic (OECD, 2021[11]), which provides a compilation of measures taken by governments of the countries covered, extension of time limits on the payment of taxes and tax deferrals have been the most widely adopted measures in the Asia and Pacific region. In the direct tax category, tax payment deferrals and tax waivers were the most used measures, whereas tax waivers and tax refunds were the most popular indirect tax measures. Available information suggests that tax support measures were primarily for the benefit of business enterprises and the production side of the economy.

Three issues need to be considered when exiting from tax stimulus. These are the what, when, and how of the exit. First, a decision must be taken as to whether an exit from various tax concessions can be put into effect simultaneously or if a withdrawal can be broken up into components of a package and implemented separately. Emphasis should be placed on the importance of avoiding the premature withdrawal of relief but of increasingly targeting it to severely affected businesses and households (OECD, 2021[12]).

Second, the government must carefully choose the timing of any withdrawal. Thus, it is necessary to monitor continuously the health of the economy with high-frequency leading/concurrent indicators, particularly for specific groups and sectors important to their economy.These indicators must fulfill two requirements: theyshould be available weekly or at least monthly and they should reflect broad macroeconomic trends. GDP estimates are the most comprehensive and obvious choice, and for fine-tuning policy responses, sectorial indices, employment trends, and consumer spending can also be tracked. It should also be kept in mind that it is not because economic activity has increased in a particular sector that businesses will be immediately viable again. It is expected that some firms will go bankrupt once their lifeline is cut. Measures like tax deferrals can be maintained for businesses that explicitly request them. Tax administrations also can be asked to develop payment plans for firms that have a large amount of deferred tax liabilities, or that are having problems surviving the crisis.

Third, the government has a choice of gradually winding down special concessions, or withdrawing them in full and going back to the normal tax structure (ADB, 2021[13]). Not withdrawing some of the tax deferral measures also creates a risk of “cliff-edge” effects (i.e., the deferred tax burden is so high that businesses decide to go bankrupt). More generally, there will be a need for policy flexibility, as continued restrictions are making conventional stimulus policies somewhat less effective and the timing of policy implementation more difficult.

The crisis could reverse years of progress toward eliminating poverty in developing countries in Asia and the Pacific. There are reasons to believe that the COVID-19 pandemic could worsen income inequality (Sawada and Sumulong, 2021[14]) and that efforts are needed to make tax systems more progressive to address the widening income gaps. To this end, governments could consider enhancing the progressivity of PIT systems, including through broadening the PIT base and abolishing the most regressive PIT tax expenditures, and could also consider other options to increase progressivity such as taxes on property.

Taxes on immoveable property, if well designed, are regarded as a good form of taxation for contributing to social equity because of their progressive nature. From an administrative perspective, taxes on immoveable property are also advantageous because they are difficult to avoid given the high visibility and immobility of land and buildings. Property tax can help the governments raise a more stable and predictable revenue stream. Moreover, property tax is often considered an appropriate tax to provide subnational governments with meaningful revenue autonomy in fiscally decentralised systems, and are an important revenue source to improve local service delivery. Hence, property tax can be a catalyst of local autonomy.

The revenue performance of property taxes not only remains low in developing countries in the region but also is further aggravated by rapid urbanisation in Asia-Pacific, which drives up residential property prices dramatically and will result in an increasing disparity between the actual market value of property and the assessed value captured under current property tax systems. This distorts revenue collection, which is already hampered by political capture, low-level fiscal decentralisation, institutional constraints, weak enforcement, and taxpayers’ attitude to tax compliance. In combination, these factors constrain the stability and predictability of revenues for national and subnational governments.

Improving property tax management will also significantly impact the aspirations of many developing countries in Asia and the Pacific to honour the global commitments contained in the 2030 targets of the SDGs, particularly SDG 16.3 on a legal framework to ensure property rights, 16.10 on public access to information, and 17.1 on DRM. SDG localisation—described as the process of defining, implementing, and monitoring strategies locally to achieve global, national, and subnational SDGs—is required to accelerate the implementation of the SDGs and sustain it beyond 2030. It can be a key driver in addressing the critical challenges faced by countries and communities in Asia and the Pacific, which include rapid urbanisation, growing inequalities, and the impact of climate change and disasters. In this regard, improved real property valuations, poverty value and transaction databases, and land value capture policies are required.

Informal economic activity is significant in the Asia and Pacific region. Most Asian revenue bodies reported in the 2018 International Survey of Revenue Administrations that the shadow economy is a concern and is rated among the higher compliance risks, with all but Viet Nam reporting a medium or higher risk rating (Figure 2.6). An examination of these ratings against the independent estimates of the size of the shadow economy would suggest that some revenue bodies may have underestimated the shadow economy risk as almost half of economies reported it as low or medium risk, while Indonesia clearly reported a focus on the shadow economy as part of its medium-term revenue strategy.

To address this risk, countries would need to define the shadow or informal economy as a first step. Often, tax administrations focus on whether firms are registrated or not, but other more subtle forms of informality such as only partly declaring income and the use of envelope wages, for instance, also fall under the informal economy and should be considered.

Although dealing with the shadow economy has in the past been especially vexed, emerging technologies enable new approaches that may support better management of unreported transactions and identification of unregistered businesses as well as under reporting or registration of workers. Maximising the use of these new capabilities, together with steps to accelerate trends away from the use of cash can be exploited to support more cost-effective monitoring and control of this risk. Strengthening system design features such as improving the revenue body’s access to bulk data on financial and business transactions, facilitating information sharing (e.g., checking tax declarations with information given to the social security funds), increasing mandatory withholding and reporting, and enhanced data management capabilities, all have the potential to reduce opportunities to operate in the shadow economy.

Addressing the tax challenges arising from digitalisation of the economy stands firmly at the top of the international tax policy and administration agenda. The existing international tax rules generally attach a taxing right to profits deriving from a physical presence in a jurisdiction. However, given globalisation and the digitalisation of the economy, businesses can, with or without the benefit of local physical operations, participate in an active and sustained manner in the economic life of a market jurisdiction. Weaknesses in the current rules create opportunities for base erosion and profit shifting (BEPS) and lead to under-taxation of certain highlight digitalised business models. This is particularly relevant to Asian and Pacific Economies where over the last decade, the digital economy is rapidly developing. According to a recent ADB study, the region accounted for about 48% of the world-wide digital economy (ADB, 2021[15]).

These challenges have been exacerbated by the increased digitalisation of the economy due to prolonged restrictions on physical movement of goods and people as a result of the COVID-19 pandemic. The OECD has been developing proposals to tackle the tax challenges of a digitalised economy based on a two-pillar approach: Pillar One proposes a new taxing right for market jurisdictions that would go beyond reference to physical presence and Pillar Two aims at creating a global minimum tax for Multinational Enterprises in order to address “remaining BEPS issues”.

To tackle these challenges, exploring and reaching a multilateral, consensus-based solution will be required, so as to avoid increasing the use of uncoordinated unilateral measures, the occurrence of double taxation and undermining cross border trade and investments across Asia and the Pacific region as well as the world.

VAT is an important source of tax revenue for Asian and Pacific economies. The integrity and performance of these VAT regimes is therefore crucial for DRM in the region. The growth of e-commerce, which is expected to continue accelerating, may have significant implications for VAT policy and administration. These may notably include potentially significant threats for VAT revenues where online sales by offshore sellers remain untaxed under existing VAT systems as well as distortion of competition for compliant domestic suppliers. Economies in the region are therefore encouraged to assess the potential need for policy action to ensure that their VAT systems are adequately equipped to address the implications of e-commerce growth.

In this context, the internationally agreed standards and guidance for addressing the VAT challenges of digital trade developed by the OECD may provide the appropriate basis for VAT policy reform, as appropriate. This guidance includes rules and mechanisms to collect VAT from foreign online sellers, which have already been implemented with considerable success in more than 70 economies that have implemented them, including in developing economies. It also points in particular to the considerable opportunities created by the role of e-commerce platforms in enhancing the efficiency of VAT collection and of big data for greater visibility and traceability of economic activity and for formalisation of previously informal economic activity. It therefore holds considerable “quick-win” opportunities for DRM in Asia and the Pacific.

Economies in the region are encouraged to further consider these opportunities in light of their national circumstances, administrative capacities and policy priorities towards identifying tailored solutions that will allow them to enhance the efficiency and effectiveness of their VAT systems. To assist economies with their policy efforts in this area, the OECD is currently developing a VAT Digital Toolkit for Asia Pacific in close partnership with the World Bank Group and with the ADB as regional partner. This will provide guidance on the implementation of VAT reform to address the challenges of digital trade with a focus on the specific circumstances and design features of VAT systems in the region. It will be released by the end of the 2021.

Enhancing DRM is not straightforward. It requires long-standing efforts from countries, along with support from development partners. To achieve this ambitious agenda, governments need to implement tax policy and administration reforms that are specific to their circumstances and level of development. The following approach and tools will be of help in this regard.

A Medium-Term Revenue Strategy (MTRS) is a comprehensive approach to effective tax system reform to boost tax revenues over the medium-term through a country-led and whole-of-government approach (PCT, 2020[16]). The approach was developed in 2016 by the Platform for Collaboration on Tax, a partnership of the IMF, OECD, United Nations and World Bank.

An MTRS can help developing countries attain sustainable and effective tax system reforms. Such reforms often require a medium-term timeframe (5-10 years) to progressively reach the revenue objectives needed to achieve the 2030 deadline for full implementation of the SDGs. MTRSs require governments’ commitment to lead the effort in reforming the tax systems, as it requires a wide range of government agencies and stakeholders beyond Ministry of Finance and Revenue Administrations. MTRSs can also serve as foundations for development coordination. In developing countries in Asia and the Pacific, the capacity to formulate and implement is limited. It is thus essential to bear in mind that external capacity development support can assist the government in establishing the MTRS (PCT, 2017[17]).

As mentioned above, Asian developing counties, like other regions, are addressing emerging challenges from the COVID-19 pandemic. The pandemic is changing the role of taxation in public policy, as tax measures are deployed to relieve the vulnerable in the immediate response to the pandemic and to ensure burden-sharing. Therefore, it is a particularly opportune time for developing countries in Asia and the Pacific to consider MTRSs.

As present, 25 countries are engaged in discussing, formulating or implementing an MTRS, of which 11 countries are from the Asia and Pacific region.

Many tax administrations start the digitisation process by automating basic functions: electronic registration and filing. However, more countries, especially in Asia, are moving to the next stage in digital transformation: enabling real-time transaction data to flow into the tax administration directly (for example through a cash register function or an online-accounting system which is linked to the tax administration data collection system).2 This element in the digital journey, once in operation, represents a large step towards seamless, continuous data flow which would raise compliance rates and significantly lower compliance and administrative costs.

Digital transformation and adoption in Asia and the Pacific tax administrations is as diverse as the level of capacity in each economy. Some of the globe’s most technologically advanced economies are in the region (Australia, Japan, People’s Republic of China, Republic of Korea, Singapore), which have integrated the use of artificial intelligence and predictive technologies and the audit and risk functions. The Republic of Korea, for example, is expanding the application of forensic and electronic audit schemes and use of big data analytics to examine potential tax avoidance by multinational enterprises and high net worth individuals. Eventually, most tax administration will embed integrated, digitised solutions and functions which can collect data from various sources, clean and filter it, and store it for risk and audit.

Tax administrations in this region are focusing on promoting e-filing and collection of digital financial statement information. In particular, economies in the Association of Southeast Asian Nations (ASEAN) are actively promoting or mandating e-filing. Many tax authorities in Asia and the Pacific are using digital solutions to improve taxpayer services, including the provision of a single platform or application for taxpayers to manage their tax compliance matters.

In an increasingly integrated and globalised world, international tax cooperation is particularly relevant for developing countries in Asia and the Pacific; being able to access information from other jurisdictions is often vital for effective enforcement, while coordination on rules to regulate cross-border activities, especially of multinational enterprises (MNEs), is needed to limit opportunities for tax avoidance. While globally there has been a dramatic increase in international cooperation on tax issues since the global financial crisis in 2008,. progress in this region is still lagging. Many Asia-Pacific developing countries are still not participating in the Inclusive Framework on Base Erosion and Profit Shifting (BEPS). The rate of participation in the Global Forum on Transparency and Exchange of Information for Tax Purposes also shows room for improvement. These tendencies are also applicable to Multilateral Convention on Mutual Administrative Assistance in Tax Matters and Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS.

Since taxation is traditionally seen as a uniquely sovereign matter, governments may be reluctant to enter into international agreements that could potentially restrict that sovereignty. Cognisant of these tensions, many of the new tools and standards have sought to preserve sovereignty, while facilitating vital cooperation; for example the multilateral convention on mutual administrative assistance in tax matters enables exchange of information between all signatories, without any requirements to negotiate on withholding tax rates. Even where international cooperation could appear to impinge upon traditional concepts of sovereignty this is a false choice, because stepping away from international tax cooperation for the sake of protecting sovereignty will serve to erode sovereign powers by making BEPS and tax evasion easier. A failure to engage in international tax cooperation will also give rise to more unilateral tax measures, increasing the occurrence of double taxation and undermining cross-border trade and investments.

Alongside the expansion of membership of multilateral forums on tax, there has also been an increase in international capacity building initiatives, enabling Asian and Pacific countries to access expertise from both international organisations and other tax administrations (e.g. through Tax Inspectors Without Borders). Such initiatives can have a significant impact, as shown by recent results in Mongolia (see Box  2.1)

With the objective of promoting those key approaches and tools across developing countries in Asia and the Pacific, ADB officially launched an Asia Pacific Tax Hub as an effective regional hub on DRM and international tax cooperation (ITC) at the 54th Annual Meeting of the ADB Board of Governors in May 2021, following the announcement of the establishment of the Hub in September 2020. The Tax Hub is envisioned to serve as an open and inclusive platform for strategic policy dialogue, knowledge sharing, and development coordination between and among the ADB, ADB member countries, and development partners.

The Tax Hub will assist each ADB developing member country to define differentiated DRM and ITC goals, including three foundation blocks: an MTRS in collaboration with the Platform for Collaboration on Tax, a roadmap for digital transformation of tax administrations which facilitates the introduction of digital tools, and proactive participation in international tax initiatives such as the Inclusive Framework on BEPS and the Global Forum on Transparency and Exchange of Information for Tax Purposes (Figure 2.8). In this regard, through the Hub, ADB will deepen the collaboration with the OECD to support developing countries in Asia and the Pacific to address those emerging challenges and to stimulate proactive participation of those countries in international tax initiatives.

References

[3] ADB (2021), ADB Annual Report 2020, http://www.adb.org/ar2020/digital.

[1] ADB (2021), ADB COVID-19 Policy Database, https://covid19policy.adb.org/.

[5] ADB (2021), Asian Development Outlook 2021: Financing a Green and Inclusive Recovery, Asian Development Bank, Manila, Philippines, http://dx.doi.org/10.22617/FLS210163-3.

[15] ADB (2021), Asian Economic Integration Report 2021: Making Digital Platforms Work for Asia and the Pacific, Asian Development Bank, Manila, Philippines, http://dx.doi.org/10.22617/TCS210048-2.

[4] ADB (2021), “COVID-19 pandemic spurs Asia’s focus on tax, resource mobilization reform | Asian Development Bank”, https://www.adb.org/news/features/covid-19-pandemic-spurs-asia-focus-tax-resource-mobilization-reform.

[13] ADB (2021), Exit Strategy to Ease or Eliminate Tax Responses to the COVID-19 Pandemic | Asian Development Bank, https://www.adb.org/publications/exit-strategy-tax-responses-covid-19-pandemic (accessed on 21 June 2021).

[6] ADB (2021), Key Indicators Database - Asian Development Bank, https://kidb.adb.org/kidb/.

[10] ADB (2021), Toward a Lasting and Equitable Recovery: ADB’s Leadership and Country Presence during the COVID-19 Crisis - Masatsugu Asakawa | Asian Development Bank, https://www.adb.org/news/speeches/toward-lasting-equitable-recovery-adbs-leadership-country-presence-covid-masatusugu-asakawa.

[2] ADB (2020), The Impact of COVID-19 on Developing Asia: The Pandemic Extends into 2021 (ADB Brief No. 159), http://dx.doi.org/10.22617/BRF200367-2.

[11] OECD (2021), Country tax measures during the COVID-19 pandemic, https://www.oecd.org/tax/covid-19-tax-policy-and-other-measures.xlsm.

[12] OECD (2021), Tax Policy Reforms 2021: Special Edition on Tax Policy during the COVID-19 Pandemic, OECD Publishing, Paris, https://dx.doi.org/10.1787/427d2616-en.

[7] OECD (2020), Revenue Statistics 2020, OECD Publishing, Paris, https://dx.doi.org/10.1787/8625f8e5-en.

[16] PCT (2020), PCT Progress Report 2020, https://www.tax-platform.org/sites/pct/files/publications/Platform-for-Collaboration-on-Tax-PCT-Progress-Report-2020.pdf.

[17] PCT (2017), Concept Note on the Medium-Term Revenue Strategy (MTRS), https://www.tax-platform.org/sites/pct/files/publications/MTRS%20Concept%20Note%20-%20Feb%206%202017.pdf.

[14] Sawada, Y. and L. Sumulong (2021), ADBI Working Paper Series MACROECONOMIC IMPACT OF COVID-19 IN DEVELOPING ASIA Asian Development Bank Institute, https://www.adb.org/publications/macroeconomic-impact-covid-19-developing-asia.

[9] UNESCAP (2021), Asia and the Pacific SDG Progress Report 2021 | ESCAP, https://www.unescap.org/kp/2021/asia-and-pacific-sdg-progress-report-2021.

[8] UNESCAP (2019), Asia-Pacific SDG Financing Requirements and the Role of Cooperation, https://www.unescap.org/sites/default/files/12_ESCAP-SDG%20Costing%20Cooperation.pdf.

Notes

← 1. According to the latest data available in the ADB Key Indicators Database, 17 out of 30 ADB developing member countries (DMCs) have experienced decrease of the ratio by more than 1% in the past 10 years, or stagnant (between -1% and 1%), while the 13 others have achieved significant progress with increase of the ratio by more than 1%.

← 2. E-invoicing and real-time posting of data is a big step for tax administrations which are used to either paper or electronic filing submissions. In order for e-invoicing to work, taxpayer data—especially the tax id, name, and address must be entered exactly as was done during registration, as the first step within the tax administration system is to match the transaction to the taxpayers.

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