United Nations Committee of Experts on International Cooperation in Tax Matters Tenth session Geneva, 31 October 2014 (Enrico Martino –Italy) The problem The world business organization: «….. multinational companies, from all sectors and in every part of the world, face difficulties with respect to the valuation of goods. These difficulties arise because transactions between related parties are subject both customs and fiscal examinations and are thereby bound by differing rules and contradictory interests….» I paesi in via di sviluppo «..in developing countries, particularly those at lower income levels, indirect taxes, such as taxes on import, remain the most important single source of government revenue… whereas developed countries tend to raise more revenue through direct taxes …..» (i.e.Tanzi, Baunsgaard and Keen, IMF, IBFD... ) Revenue Collected by Customs More than 20% of national tax revenue from Customs (20% to 70%): Bahamas ; Bahrain ; Bangladesh ; Benin ; Cambodia ; Cape Verde ; Comoros ; Congo ; Cote d’Ivoire ; Ethiopia ; Gabon ; Ghana ; Grenada ; Iran ; Kuwait; Lesotho; Liberia; Lybia; Madagascar; Maldives; Micronesia; Namibia; Nepal; Niger; Philippines; SaoTome and Principe; Seychelles; Sierra Leone; Swaziland;. Togo (sources: WCO, May 2013) Revenue Collected by Customs Australia 2,16% Brazil 3,67% Canada 0,80% Chile 1,39% China 4,20% European Union 1,55% Japan 1,00% Mexico 1,34% Norway 0,36% South Africa 3,80% Switzerland 1,79% United States 2,11% (sources: WCO, May 2013) Why a discussion in the UN expert group? This group: • Works within the UN terms of reference that has a wide membership • It is focused in particular on the needs of developing countries and countries with economies in transition • The ECOSOC Resolution 2004/69 in d (iii): «[The Committee shall] Consider how new and emerging issues could affect international cooperation in tax matters and develop assessments, commentaries and appropriate recommendations» • The 25 members are drawn from the fields of tax policy and tax administration reprenting differente tax systems (not only experts in double taxation Convention) they cannot ignore problems linked to international trade • There is not another independent working group of tax experts, geographically representing the whole world, that can offer a non‐partisan indication • There is no need for a strong customs expertise to suggest an indication; these topics are already being discussed in many countries and there is time to interview experts and expert organisations • If a shared solution can be found (in 2016), this will be published • If we will not reach a consensus among us, this attempt will not have required great efforts The global problem The international standard is managed by specialized international organizations (UN, WCO, OECD, UE, others) that develop principles that are different from one another and that pursue different objectives The local problem Differentteamsaregenerallyresponsibleforthemanagement of direct taxation and taxes on imports Tax administrations may have an organization : Customs + Tax or Customs separate from Tax In both cases, often, the two structures have a high degree of autonomy, do not have significant exchanges of personnel, pursue different objectives Steps • To set up a small working sub‐group of volunteers working through e‐mail and drawing up a document for the whole group • Tohearatthenextsession(11thin2015)IMF, WCO , OECD members and members of the business community • To draw up, by 12th 2016, a statement to be released at the end of the works • To develop capacity building initiatives on the international trade in goods Possible outcome.