## 1. Losses by Barki Tojik and other SOEs

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### Introduction
- The SOE sector in Tajikistan:
  - Employs around 24 percent of the labor force.
  - Accounts for approximately 17 percent of GDP.
  - Assets of this sector are estimated around 48 percent of GDP (EU, 2017).
- Three largest SOEs by assets — Barki Tojik (BT), Tajik Railways, and the Tajik Aluminum Company (TALCO) — hold over 80 percent of all SOE assets.
- As of 2017, 931 SOEs were active; remainder listed in the Tax Committee’s register as under re-registration or liquidation.

### Losses and fiscal risks from the largest SOEs
- The SOE sector is inefficient and loss-making; cumulative losses amounted to 3.7 percent of GDP in 2018.
- BT accounts for almost all sector losses owing to:
  - Below cost recovery tariffs.
  - Revaluation of its FX denominated borrowing from the government and commercial banks.
- TALCO is also loss-making; most other SOEs show only modest profitability.
- Data coverage and quality:
  - Results based on data from the SOE Monitoring Department of the Ministry of Finance covering the 24 largest SOEs.
  - Consistency and reliability of the data may be questionable.

### Barki Tojik (BT): financial position and exposures
- Government loans to BT:
  - At end-2018, the outstanding amount of government loans to BT was 17 percent of GDP.
  - The government has continued to service the external debt.
- Arrears to domestic banks and suppliers:
  - Cumulative liabilities of BT to banks and suppliers were 6½ percent of GDP at end-2018.
- Operational measures and tariff policy:
  - Authorities have implemented annual electricity tariff increases of about 17 percent since 2016.
  - A new tariff methodology approved would allow setting tariffs in line with full cost recovery.
  - Further annual tariff increases planned: 17 percent till 2022, 8 percent between 2023- 2025.
- Ongoing reform program:
  - Program designed with WB and ADB assistance envisages clearance of arrears to suppliers and commercial banks and restructuring of the debt to government.
  - Expected improvements: inventory management, collections, and rising export revenues to strengthen BT’s financial position over the medium-term.

### Non-guaranteed borrowing by other SOEs and contingent liabilities
- Tajiktransgaz signed a loan agreement for $300 million (3½ percent of 2019 GDP) to finance construction of a gas pipeline (Line D of the Central Asia-China Gas Pipeline).
- TALCO signed an MOU to borrow $545 million (6½ percent of 2019 GDP) from Chinese companies to finance modernization of its plant; agreement expected to be finalized in 2020.
- Given SOEs’ financial situations, such loans may become contingent liabilities for the government.

### SOE reform efforts in Tajikistan (progress and measures)
- Institutional improvements and transparency:
  - SOE Monitoring Department (SOEMD) established at the Ministry of Finance in 2010.
  - Gradual expansion of monitoring powers from 10 to the 24 largest SOEs; list recently updated and awaiting approval.
  - Inclusion of the Statement of Fiscal Risks (SFR) in the state budget document for 2016 and 2017; preparation of 2018 and subsequent SFRs facing delays.
  - Approval of a Strategy to Manage Fiscal Risks from SOEs (September 2016) and adoption of an Action Plan (July 2017); implementation has been slow.
  - Preparation of a new SOE law to promote profitability, financial sustainability, transparency and accountability; draft passed internal coordination and is awaiting final approval.
  - Government decree (May 2019) to establish a Fiscal Risks Coordination Council on the management of SOE fiscal risks.
- BT-specific reforms:
  - Decree issued to unbundle operations into generation, transmission and distribution.
  - Electricity Regulatory Department established under the Antimonopoly Agency.
  - Progress in improving collection rates.

### What more is needed — recommendations and policy actions
- BT-specific actions:
  - Implement the program designed with WB and ADB assistance.
  - Restructure BT’s existing loans and arrears to make them concessional in line with initial donor terms.
  - Repay commercial banks and suppliers to reduce BT’s debt burden.
  - Continue improvements in collection and further tariff increases to ensure full cost-recovery over the medium-term.
  - Provide targeted social safety nets to mitigate the impact of tariff increases on vulnerable populations.
  - Over the longer-term, continue deregulation and improve transparency and management (drawing on Georgia experience).
- Strengthening SOE oversight and fiscal risk management:
  - Full implementation of International Financial Reporting Standards (IFRS) by all large SOEs.
  - Ensure regular audits; address instances of adverse audit opinions and weak internal controls.
  - Comprehensive recording and reporting of all public debt, including non-guaranteed SOE debt.
  - Include SOE borrowing within the government’s overall medium-term debt envelope and strategy.
  - Large infrastructure and public policy investments should be undertaken by the government and financed through government borrowing; commercial borrowing by SOEs should be supported by strong corporate governance and proven commercial viability.
  - Improve staffing and capacity of the SOEMD (currently limited to 8 people) or outsource support for comprehensive monitoring and risk assessment.
  - Prepare and publish accrual-based consolidated financial statements for general government.
- Ambitious structural reforms:
  - Adopt institutional frameworks that grant SOE management more autonomy while strengthening ex-post monitoring and incentive mechanisms.
  - Approve revised list of SOEs to include all economically significant SOEs.
  - Continue preparation and inclusion of the SFR in budget documents.

### Key numeric indicators and fiscal magnitudes cited
- SOE employment: around 24 percent of the labor force.
- SOE share of GDP: approximately 17 percent.
- SOE assets: around 48 percent of GDP.
- Three largest SOEs hold over 80 percent of all SOE assets.
- Active SOEs as of 2017: 931.
- Cumulative SOE losses: 3.7 percent of GDP in 2018.
- Government loans outstanding to BT at end-2018: 17 percent of GDP.
- BT liabilities to banks and suppliers at end-2018: 6½ percent of GDP.
- Annual electricity tariff increases implemented since 2016: about 17 percent.
- Planned annual tariff increases: 17 percent till 2022; 8 percent between 2023- 2025.
- Tajiktransgaz loan: $300 million (3½ percent of 2019 GDP).
- TALCO MOU: $545 million (6½ percent of 2019 GDP).
- SOEMD staffing: 8 people.

### Annex — international experience (selected lessons)
- Reform approaches in comparator countries:
  - Georgia: phased power sector reforms including unbundling, privatization, tariff reform, and market mechanisms; lessons emphasize independent regulator and transparent competition.
  - Malaysia: transformation of Government Linked Companies with KPIs, performance-based contracts, board and management changes; results include improved revenues, profitability, and global expansion.
  - Kazakhstan: establishment of state asset management and sovereign wealth funds, updated corporate governance codes, abolition of price regulation except for “natural monopolies”; results show improved financial reporting and auditing practices but persistent challenges with SOE incentives and cost-recovery.

*Prepared by Nailya Menlasheva and Yuri Sobolev; December 26, 2019.*

### 1. Losses by Barki Tojik and other SOEs ____________________________________________________ 4

### 1. Losses by Barki Tojik and other SOEs

### Introduction
- The SOE sector in Tajikistan:
  - Employs around 24 percent of the labor force.
  - Accounts for approximately 17 percent of GDP.
  - Assets of this sector are estimated around 48 percent of GDP (EU, 2017).
- Three largest SOEs by assets — Barki Tojik (BT), Tajik Railways, and the Tajik Aluminum Company (TALCO) — hold over 80 percent of all SOE assets.
- As of 2017, 931 SOEs were active; remainder listed in the Tax Committee’s register as under re-registration or liquidation.

### Losses and fiscal risks from the largest SOEs
- The SOE sector is inefficient and loss-making; cumulative losses amounted to 3.7 percent of GDP in 2018.
- BT accounts for almost all sector losses owing to:
  - Below cost recovery tariffs.
  - Revaluation of its FX denominated borrowing from the government and commercial banks.
- TALCO is also loss-making; most other SOEs show only modest profitability.
- Data coverage and quality:
  - Results based on data from the SOE Monitoring Department of the Ministry of Finance covering the 24 largest SOEs.
  - Consistency and reliability of the data may be questionable.

### Barki Tojik (BT): financial position and exposures
- Government loans to BT:
  - At end-2018, the outstanding amount of government loans to BT was 17 percent of GDP.
  - The government has continued to service the external debt.
- Arrears to domestic banks and suppliers:
  - Cumulative liabilities of BT to banks and suppliers were 6½ percent of GDP at end-2018.
- Operational measures and tariff policy:
  - Authorities have implemented annual electricity tariff increases of about 17 percent since 2016.
  - A new tariff methodology approved would allow setting tariffs in line with full cost recovery.
  - Further annual tariff increases planned: 17 percent till 2022, 8 percent between 2023- 2025.
- Ongoing reform program:
  - Program designed with WB and ADB assistance envisages clearance of arrears to suppliers and commercial banks and restructuring of the debt to government.
  - Expected improvements: inventory management, collections, and rising export revenues to strengthen BT’s financial position over the medium-term.

### Non-guaranteed borrowing by other SOEs and contingent liabilities
- Tajiktransgaz signed a loan agreement for $300 million (3½ percent of 2019 GDP) to finance construction of a gas pipeline (Line D of the Central Asia-China Gas Pipeline).
- TALCO signed an MOU to borrow $545 million (6½ percent of 2019 GDP) from Chinese companies to finance modernization of its plant; agreement expected to be finalized in 2020.
- Given SOEs’ financial situations, such loans may become contingent liabilities for the government.

### SOE reform efforts in Tajikistan (progress and measures)
- Institutional improvements and transparency:
  - SOE Monitoring Department (SOEMD) established at the Ministry of Finance in 2010.
  - Gradual expansion of monitoring powers from 10 to the 24 largest SOEs; list recently updated and awaiting approval.
  - Inclusion of the Statement of Fiscal Risks (SFR) in the state budget document for 2016 and 2017; preparation of 2018 and subsequent SFRs facing delays.
  - Approval of a Strategy to Manage Fiscal Risks from SOEs (September 2016) and adoption of an Action Plan (July 2017); implementation has been slow.
  - Preparation of a new SOE law to promote profitability, financial sustainability, transparency and accountability; draft passed internal coordination and is awaiting final approval.
  - Government decree (May 2019) to establish a Fiscal Risks Coordination Council on the management of SOE fiscal risks.
- BT-specific reforms:
  - Decree issued to unbundle operations into generation, transmission and distribution.
  - Electricity Regulatory Department established under the Antimonopoly Agency.
  - Progress in improving collection rates.

### What more is needed — recommendations and policy actions
- BT-specific actions:
  - Implement the program designed with WB and ADB assistance.
  - Restructure BT’s existing loans and arrears to make them concessional in line with initial donor terms.
  - Repay commercial banks and suppliers to reduce BT’s debt burden.
  - Continue improvements in collection and further tariff increases to ensure full cost-recovery over the medium-term.
  - Provide targeted social safety nets to mitigate the impact of tariff increases on vulnerable populations.
  - Over the longer-term, continue deregulation and improve transparency and management (drawing on Georgia experience).
- Strengthening SOE oversight and fiscal risk management:
  - Full implementation of International Financial Reporting Standards (IFRS) by all large SOEs.
  - Ensure regular audits; address instances of adverse audit opinions and weak internal controls.
  - Comprehensive recording and reporting of all public debt, including non-guaranteed SOE debt.
  - Include SOE borrowing within the government’s overall medium-term debt envelope and strategy.
  - Large infrastructure and public policy investments should be undertaken by the government and financed through government borrowing; commercial borrowing by SOEs should be supported by strong corporate governance and proven commercial viability.
  - Improve staffing and capacity of the SOEMD (currently limited to 8 people) or outsource support for comprehensive monitoring and risk assessment.
  - Prepare and publish accrual-based consolidated financial statements for general government.
- Ambitious structural reforms:
  - Adopt institutional frameworks that grant SOE management more autonomy while strengthening ex-post monitoring and incentive mechanisms.
  - Approve revised list of SOEs to include all economically significant SOEs.
  - Continue preparation and inclusion of the SFR in budget documents.

### Key numeric indicators and fiscal magnitudes cited
- SOE employment: around 24 percent of the labor force.
- SOE share of GDP: approximately 17 percent.
- SOE assets: around 48 percent of GDP.
- Three largest SOEs hold over 80 percent of all SOE assets.
- Active SOEs as of 2017: 931.
- Cumulative SOE losses: 3.7 percent of GDP in 2018.
- Government loans outstanding to BT at end-2018: 17 percent of GDP.
- BT liabilities to banks and suppliers at end-2018: 6½ percent of GDP.
- Annual electricity tariff increases implemented since 2016: about 17 percent.
- Planned annual tariff increases: 17 percent till 2022; 8 percent between 2023- 2025.
- Tajiktransgaz loan: $300 million (3½ percent of 2019 GDP).
- TALCO MOU: $545 million (6½ percent of 2019 GDP).
- SOEMD staffing: 8 people.

### Annex — international experience (selected lessons)
- Reform approaches in comparator countries:
  - Georgia: phased power sector reforms including unbundling, privatization, tariff reform, and market mechanisms; lessons emphasize independent regulator and transparent competition.
  - Malaysia: transformation of Government Linked Companies with KPIs, performance-based contracts, board and management changes; results include improved revenues, profitability, and global expansion.
  - Kazakhstan: establishment of state asset management and sovereign wealth funds, updated corporate governance codes, abolition of price regulation except for “natural monopolies”; results show improved financial reporting and auditing practices but persistent challenges with SOE incentives and cost-recovery.

*Prepared by Nailya Menlasheva and Yuri Sobolev; December 26, 2019.*

### References

### References

### A. The Main Characteristics of Tajikistan’s Tax Regime and Tax Policy
- Tax revenues increased from 13 percent of GDP in 2000 to 22.8 percent in 2014; declined to 21.3 percent in 2018.
- Number of taxes reduced from 21 to 10.
- Effective tax rate (ETR) on profits reported by businesses in Tajikistan is "almost 7 and 2 times" that in Georgia and Kyrgyz Republic respectively; Tajikistan’s effective CIT rate reported as 17.7 percent (Table 2).
- Road user tax (RUT) rate is 1 percent but charged on firms’ turnover, making it roughly equivalent to a 17 percent tax on reported profit (Table 2).
- Social tax paid by employers is 28.5 percent (highest in the CCA).
- Tajikistan’s VAT has multiple rates: 0, 5, and 18 percent.
- CIT has three rates: 13, 15, and 23 percent for goods, services, and nonresidents respectively.
- RUT dual rates: 0.25 percent for trade and procurement and 1 percent for other activities.
- Taxpayers with turnover below the threshold of TJS 1 mln (approximately USD 100,000) are subject to a simplified tax regime.
- The 5 percent VAT rate reflects reduced VAT granted to a few sectors.

### B. Tax Incentives in Tajikistan — Design and Effects
- Multiple VAT, CIT, PIT, and customs duty exemptions/incentives exist across sectors.
- Generous profit-based incentives include:
  - A 5-year corporate income tax holiday available to investments over USD 0.5 million.
  - Sectoral incentives for: construction of hydropower stations; import of raw materials to make final goods; poultry farms and feed producers; tourism; securities market participants; production sharing agreements.
  - Firms in four free economic zones benefit from reduced taxes and custom fees.
  - Simplified tax for small businesses and a unified tax for agricultural producers grant exemptions from PIT (for small businesses), CIT, RUT, VAT, and land tax (for agricultural producers).
- Cost-based incentives such as accelerated depreciation are allowed but used less widely.
- Profit-based incentives predominate over cost-based incentives.
- Incentives are often not linked to new investment and are vulnerable to abuse (e.g., disguising existing investment as new; broad import VAT and customs exemptions; leakage from special economic zones).
- Tax incentives likely eroded the tax base: tax revenues as a share of GDP in 2018 decreased by 1.5 percent relative to 2014.
- In 2018, trade related tax revenues consisted 30 percent of total tax revenues.
- Tajikistan heavily relies on import related tax revenues; import-related taxes declined despite imports increasing sharply in 2018.

### C. International Experience with Tax Incentives — Empirical Findings
- Cross-country studies show tax incentives in LICs usually create complexities and erode the tax base; associated with abuse and corruption (Kinda 2014, IMF 2015).
- Reforms that simplified tax regimes, curtailed exemptions, and improved tax administration contributed to tax revenue growth (example: Mauritania — VAT collection net of refunds increased by 2.5 percentage point of GDP during tax reforms 2009-2013).
- Investment surveys indicate tax incentives are not the most important consideration for business investment; stability, predictability, less discretion, and transparent tax systems rank higher (UNIDO survey: tax incentives rank 11th out of 12).
- Empirical evidence suggests tax incentives do not have a sizable long-term effect on investment; in some cases FDI displaced domestic investment (Klemm and Van Parys, 2009).
- International experience suggests cost-based incentives (e.g., accelerated depreciation) are generally preferable to profit-based incentives for boosting investment.

### D. Advantages and Disadvantages of Common Tax Incentives (Summary)
- Lower Corporate Income Tax Rate: simple to administer; may result in profit shifting and windfalls to existing high-return firms.
- Tax Holidays: simple; can attract short-term projects and incentivize tax avoidance by disguising existing investments as new.
- Investment Allowances and Tax Credits: targetable and transparent; risk of abuse, administrative burden, and distortion toward short-lived assets.
- Accelerated Depreciation: preserves benefits of allowances/credits without discriminating against long-lived assets; reduces investment distortion under CIT.
- Exemptions from Indirect Taxes (VAT, import tariffs): allow avoidance of contact with tax administrators; prone to abuse and weaken VAT administration.
- Export Processing Zones: can distort locational decisions and typically result in leakage of untaxed goods into the domestic market.

### E. Tax Incentives Reform Recommendations
- Transition to a new economic model emphasizing private investment and job creation; reduce reliance on public investment and remittances.
- Broaden the tax base and gradually rationalize high tax rates while maintaining fiscal sustainability.
- Phase out inefficient profit-based incentives over time; move toward cost-based, transparent, and non-discretionary incentives (including accelerated depreciation).
- New incentives should:
  - Adhere to international best practices.
  - Be rule-based rather than discretionary.
  - Be consolidated into the Tax Code and under the Ministry of Finance.
  - Include estimated fiscal cost in the tax expenditure report.
  - Be reported through a proper system for firms benefiting from incentives.
- Implement near-term reforms beginning with a detailed cost–benefit analysis of existing incentives, including special economic zones.
- Pre-announce reforms credibly and allow phased implementation to enable businesses to adjust.
- Additional administrative reforms recommended: drop nuisance taxes, eliminate multiple rates where relevant, and simplify tax payment and compliance procedures to reduce compliance costs, encourage firm growth, expand the tax base, and improve compliance.

*Italic: Source — Selected sections and policy recommendations extracted from the IMF content unit.*

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_Source: https://www.imf.org/-/media/files/publications/cr/2021/english/1tjkea2021007.pdf_
