Mary Baine is the Director: Tax Programmes at the African Tax Administration Forum. This is an African inter-governmental organisation leading tax administration reform, that facilitates peer support among tax administrations in mobilising greater domestic resources through improved efficiency and effectiveness in their operations. Her work includes the supervision of multiple technical assistance engagements that include, but are not limited to VAT as a flagship tax, and Multiple Country Programmes featuring Transfer Pricing and Exchange of Information interventions in ATAF’s Technical Assistance Programme.

Prior to this assignment, Ms Baine served as the Permanent Secretary of the Ministry of Foreign Affairs and Co-operation of the Republic of Rwanda, and as Commissioner-General of the Rwanda Revenue Authority, having grown through the ranks of the different tax departments over a 17-year period.

Return to Governing Board

Reflections

Q: How can ATAF and TIWB further partner together, particularly in the domain of South-South co-operation?

A: ATAF and TIWB can partner in multiple areas to support tax administrations. Primarily, the partnership can focus on providing technical assistance in the form of audit support to African countries in the area of transfer pricing, international tax, and general audits, especially in more complex sectors such as extractives, telecommunications, and financial service sectors. Additionally, ATAF has seen an increase in demand for support in some value added tax issues and customs. Thus, these areas could also be covered on a needs basis by ATAF and TIWB.

To deliver TIWB programmes, ATAF and TIWB should seek to make use of the available expertise on the African continent for a range of reasons such as the fact that these experts may have handled similar audits and the operating environment may, more often than not, be akin to their home countries. ATAF, as a matter of policy and for sustainability, continues to identify and support the development of these experts. However, in circumstances where additional or sector-specific skills and experiences are required, a collaborative approach should be applied whereby experts from other regions may be brought on board for effective delivery of the programmes.

From ATAF’s perspective, a South-South model for technical support is more sustainable than one that is heavily dependent on expertise from developed markets. Thus, ATAF shall continue to play its role in supporting this approach by investing in skills development of African experts who, in turn, will be available for delivering the support required through an ATAF/TIWB partnership.

Q: Do you think the tightening of fiscal space will lead to reduced tolerance for tax avoidance and evasion? Or will developing countries have other priorities?

A: As many developing countries continue to have budget deficits, the fiscal space remains extremely limited. Under the circumstances, many of these countries are making every effort to enhance domestic resource mobilisation; hence, tolerance for tax avoidance and evasion will and has indeed reduced in several developing countries. This is witnessed through the fact that several developing countries have introduced or are in process of introducing tax policy measures to address those issues. For instance, some developing countries have already implemented the BEPS remedy package on aspects such as enhanced guidelines on transfer pricing, transfer pricing documentation, limitation of tax treaty benefits, beneficial ownership measures and robust exchange of information measures and networks. However, this implementation is not uniform across countries and some have implemented more BEPS measures than others. In some instances, very little action has been taken. Thus, there is still significant improvement required in developing countries’ legislation in order to substantively address tax avoidance.

Nonetheless, the priority of many developing countries is anticipated to remain the enhancement of domestic resource mobilisation through effective and efficient tax policy and administrative measures. These measures are likely to target tax avoidance and evasion schemes, as well as aggressive transfer pricing schemes that may be used to erode the tax bases of these countries. Even for resource rich countries that have previously relied on such resources to finance government operations including social welfare, these appear to be the priority. In recent years, resource-rich countries have faced significant decline in revenues due to multiple factors, such as the reduction in global prices of some commodities and the exploitation of fiscal regimes by multinational enterprises. Thus, such countries are now focused on enhancing tax revenue collections from these same sectors and from other emerging key areas to support the increasing budgetary needs

Q: As a new member of the TIWB Governing Board, what would success look like for the initiative in the coming years?

A: As a Board member, a key indicator of TIWB’s success will be the increase of tax collection from multinational enterprises (MNEs) operating in developing countries. This should be driven by very specific audit results achieved through this initiative’s activities, and consequently, an increase in voluntary compliance by said MNEs. Many reports indicate that MNEs operating in developing countries engage in aggressive transfer pricing and tax avoidance schemes leading to exploitation of these economies. This exploitation particularly affects the high revenue generating sectors of these countries (i.e. extractives, agriculture, construction and infrastructure projects), as well as other specialised sectors such as the financial sector, e-commerce and telecommunications. Therefore, the TIWB initiative should support auditors in developing countries to handle these complex issues and ensure that MNEs pay their fair share of taxes in these countries. TIWB programmes should also help reduce the time required for issuing assessments, while ensuring that local auditors acquire the necessary technical and soft skills to address similar issues on their own in the future.

Ultimately, the expectation is that the TIWB initiative will help developing countries increase their tax-to-GDP ratios, which are currently very low in comparison to those of developed markets. This should, in turn, help these countries reduce their reliance on aid, scale down public debt and enhance opportunities for economic growth and development.

The Board should therefore increase the number of and closely monitor the programmes in developing countries to ensure that the above expectations are achieved.