## 1vnmea2023002

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---

### Purpose and scope
- CD delivered by Mr. Andy Ditchfield and Mr. Steve Howlin (IMF Fiscal Affairs Department (FAD) Short Term Experts (STX)) to the General Department of Taxation (GDT) of Vietnam during the period February 14 to 22, 2023.
- Objective: consolidate and build on CRM remote training delivered in September and November 2022 by practically applying CRM principles to the tourism sector to finalize a tourism sector compliance improvement plan (CIP).
- The tourism sector CIP is a pilot to give GDT experience and confidence to extend contemporary CRM practices to other sectors and specific compliance risks.

### Recent developments and institutional issues
- Vietnam Tax System Reform Strategy (TSRS) for 2021-2030 requires a risk-based approach; TSRS approved by the Prime Minister.
- Risk Management Board (RMB):
  - Currently a temporary board within GDT; authority derived from circular 31.
  - RMB reports to a single Deputy Director General rather than to a Risk Management Steering Committee (RMSC).
  - International practice: an RMB typically reports to a RMSC composed of representatives from relevant departments.
  - Recommendation: establish an RMSC before Tourism CIP implementation (Appendix I describes roles/responsibilities).
- RMB capabilities and challenges:
  - RMB understands CRM principles and embraces using educate, facilitate and enforcement treatments across registration, filing, correct reporting and payment.
  - Dissemination of CRM principles beyond RMB is limited; outside RMB, focus remains on audit activity and audit results (hit rate, value of adjustments).
  - International experience: audit alone cannot shift underlying non-compliant behavior; contemporary CRM requires targeted programs of education, facilitation and enforcement.
- Rationale for selecting tourism as pilot:
  - Tourism significance: 8 percent of GDP in 2018.
  - Visitor numbers: 15 million foreign visits and 80 million domestic visits.
  - Tourism services delivered in Vietnam should be taxed in Vietnam, reducing leakage.
- Pilot geographic focus: the 5 main tourism provinces to enable manageable demonstration and comparison.

### Summary of support provided (workshops and CRM steps)
- Nine workshops held between February 14 to 22, 2023. Sequential CRM steps applied (A to F below).

- A. Understanding and improving the data collected
  - RMB had difficulties obtaining relevant, accurate and complete tourism data; RMB does not have direct access to IT-held data and must request it.
  - Partial data were displayed during workshops; RMB improved data after examinations.
  - Planned separate duplicate database for RMB in early 2024 to allow manipulation without compromising raw data integrity; must be synchronized regularly with raw data.
  - Data integrity issues observed: missing subsectors, inclusion of non-tourism business activities; some data not credible.
  - VSIC limitations: tourism not specifically designated; subsectors relevant to tourists can be identified cautiously; taxpayer returns mix local consumers, domestic tourists and foreign tourists—isolating tourists is not possible from return data.
  - Data filtering agreed for analysis:
    - Five provinces
    - Subsector (restaurants, hotels, retail, transport, entertainment, and tour operators)
    - Market segment (Large, medium, small)
    - Year
  - Example data finding: retail ratio of net VAT (output VAT minus input VAT) as a proportion of output VAT was just 1.64 percent over the three years 2018 to 2020; in some years input VAT exceeded output VAT in the medium market segment.
  - Observations:
    - Data seen limited to VAT returns (correct reporting pillar); further data needed for profits tax, wages tax and other pillars (registration, filing, payment).
    - Document V3.1 (Vietnam Tourism Risk Assessment – Research and data gathering template, November 2022) guides required data.
    - Fiscalization data (fiscal cash register and e-invoice data) recommended to identify risks (underdeclared sales, overclaimed purchases) and VAT refund fraud risks.
    - A revised version 2 of document V3.1 with relevant ratios was provided during assistance.

- B. Rating and ranking risks in tourism subsectors
  - Workshops segmented tourism by geography, subsector, pillars of compliance, market segment and other features (e.g., online sales).
  - High risks identified:
    - Filing and correct reporting (underdeclared sales and overclaimed purchases) for small and medium hotels.
    - Large market hotels: high risk due to transfer pricing opportunities.
  - RMB should establish consistent risk consequence and likelihood criteria.
  - Risk ranking must be confirmed by data and consultation within GDT, including provincial and district tax administrations.
  - Initial conclusions are provisional and expected to change as more data and experience accumulate.

- C. Analyzing taxpayer behavior and developing a blend of treatments
  - Motivations for non-compliance identified: greed, social acceptance, concerns about public spending, unrecognized benefits of taxation, regulatory burden, geographic remoteness, low fear of detection or effective action by GDT.
  - Treatments identified: educate, facilitate and enforce strategies.
  - Need to shift GDT mindset from audit-only focus to a balanced approach including education and facilitation; effectiveness should not be measured by audit results alone.
  - Graduated treatment strategy illustrated:
    - Highest risk taxpayers: audited (in-depth profile, interview, audit techniques, assessment).
    - Medium risk taxpayers: letter indicating poor tax performance, self-assessment tools, future compliance monitoring.
    - Low risk taxpayers: education, communication and media, monitoring.
  - Case selection criteria should be reviewed to align with regional focus on tourism; templates and instructions (profile, audit, letters) and specific reports (audit quality, self-assessment, staff development) are part of the approach.

- D. Developing a tourism CIP
  - A CIP was prepared based on workshop conclusions.
  - Appendix II provides a one-page overview of the CIP and background documentation; background part needs expansion with more detail.

- E. Planning the implementation of the CIP
  - Two workshops discussed implementation prerequisites and measuring success: capacity development, communications and messaging, taxpayer services, audit capability and quality assurance, workflows, monitoring and measuring success.
  - GDT should prepare a detailed implementation action plan covering all CIP aspects.

- F. Next sector focus: e-commerce
  - Workshop covered e-commerce scope, segmentation (domestic, international, goods, services), supply chain participants, intervention points and potential treatments.
  - RMB should apply the same CRM process and provided PowerPoint slides/documents to e-commerce.

### Recommendations and further assistance
- Key recommendations:
  - Establish a Risk Management Steering Committee (RMSC) to review, approve and oversee the CIP and key risk documents; demonstrate governance and improve integration among core GDT functions.
  - Improve data quality: RMB, IT and registration/filing/payment departments should define and agree data requirements for risk management to ensure accurate, complete and relevant data for risk assessments, rankings and the CIP.
  - Improve RMB access to data: while RMB access is planned for 2024, timely interim access is critical to finalize the tourism CIP; from 2024 RMB should have access to all relevant data across the four pillars, including e-invoices, fiscalization data and any third-party data.
  - RMB engagement with provincial tax administrations: establish robust relationships so provincial administrations understand CRM benefits and participate in CIP development and delivery.
  - Finalize tourism CIP documentation and plans, including analysis of accurate and complete data; use notes to the draft CIP at Appendix II.
- Further FAD assistance that could be provided:
  - Review and recommend on CIP implementation plans before CIP implementation.
  - Deliver Tourism CIP presentations to selected provincial administrations (Hanoi, Da Nang, Ho Chi Minh City).
  - Prepare tourism project audit instructions (hotels, restaurants, retail).
  - Develop tourism project letters for medium risk taxpayers.
  - Audit quality assurance process design.
  - Review of risk criteria used in audit case selection.

### Recommended key actions and timelines
- Access data and critically assess the data
  - Action: Access data as per V3.1 data request; use the data to confirm/deny initial risk ranking conclusions made during Feb workshops.
  - Timeline: May 2023
- Complete Draft CIP for tourism sector
  - Action: Closely follow guidance to complete the CIP as provided in the draft CIP, document V15.0.
  - Timeline: May 2023
- Develop Tourism CIP implementation action plan
  - Action: Develop a detailed action plan in consultation with departments that will deliver activities; set timeframes, expectations and a monitoring and reporting mechanism.
  - Timeline: May 2023

### Appendix I — Role of the Risk Management Steering Committee (RMSC) (summary)
- Purpose:
  - Provide strategic insight, approval, support and governance for identification and mitigation of compliance risks using contemporary Compliance Risk Management (CRM) processes.
  - Add value to Risk Management Board (RMB) work by applying collective experience to improve and approve RMB recommendations.
- Typical composition (should consist of senior officials from a broad range of areas within GDT):
  - Director General as chair of the committee
  - Deputy Directors
  - Risk Management Board leader
  - Leaders of pillars of compliance functional areas (registration, filing, payment)
  - Heads of audit, including a provincial audit representative and head of Large Taxpayers Office
  - Heads of small and medium taxpayer segments
  - Education and customer services/support
  - Communications and marketing
  - Law interpretation
  - Internal Inspection (Objections)
  - External representatives from Ministry of Finance and Customs
  - Others may be added as needed
- Specific practical responsibilities (selection):
  - Providing intelligence on known and emerging risks
  - Reviewing and approving risks identified and risk rankings recommended by RMB
  - Reviewing and approving treatment plans and allocation of resources
  - Approving compliance improvement plans and capability improvements
  - Monitoring and reviewing performance against plans and adjusting treatment strategies to improve effectiveness

### Appendix II — Tourism Compliance Improvement Plan – Key points (summary)
- PLAN OVERVIEW
  - Aim: to make a sustainable improvement in compliance in this significant and non-compliant sector by practically applying contemporary compliance risk management principles.
  - Approach: data driven, whole of GDT approach (audit, education, services) focusing on highest risk aspects of tourism.

- SEGMENT PROFILE (as drafted)
  - Definition: Businesses operating in Tourism across all segments, which contributes 2% of GDP (2021) but likely to increase to pre-COVID levels of 8/9%. Tourism is located in 5 main geographic provinces.
  - Revenue: Net tax revenue (CIT/VAT/PIT) from this segment is xx billion.
  - Number of taxpayers: There are xxxx businesses in this sector, mostly small and medium businesses.
  - Tax returns: Total filing obligations for all taxpayers is xxx for annual and yyyy for quarterly/monthly.
  - Key subsectors: Transport, accommodation, restaurants and cafes, tour operators, retail and entertainment.
  - Important intermediaries: Travel agents, customs.

- RISK ASSESSMENT (registered risk ratings identified in workshops)
  - Registration risk - HIGH (mainly small and micro segment across all subsectors, includes household businesses in restaurants and hotels and street vendors)
  - Filing risk - HIGH (failure to file evident across all subsectors, particularly in accommodation)
  - Reporting risk - HIGH (underreporting of sales mainly in cash transactions and inflation of expenses; in large taxpayer sub-sector transfer pricing is a key risk)
  - Payment risk – NOT RATED
  - Typical taxpayer behaviors: Greed, social norms and no fear of being caught, especially in medium and small segments.
  - Geographic focus for treatments: five geographic provinces where tourists predominantly visit.

- RISK TREATMENT (selected)
  - Facilitative approaches:
    - Broad one to many communications in the subsectors focusing on education, social impact and consequences of being identified and acted upon.
    - Targeted communications to medium risk taxpayers/businesses requiring improvement in tax obligations such as correct tax reporting performance.
    - Prompting messages to taxpayers and follow up contact (telephone calls/interviews etc).
  - Enforcement approaches:
    - Interviews, audits and examinations for highest risk taxpayers (particularly those that have not responded to targeted messaging).
    - Outbound calls for non-filing.
    - Penalties and prosecutions for continued non-compliance and those that deliberately and repeatedly ignore obligations.
  - Rationale: Combine facilitative and enforcement approaches; escalate to enforcement when taxpayers do not respond to facilitative measures. International experience shows many respond to facilitative approaches producing sustainable compliance improvement.

- WORKFLOW AND MONITORING (planned counts)
  - One to many communications: 50
  - One to one communications: 5000
  - Prompting messages: 2000
  - Audits/examinations: 250
  - Telephone calls/interviews: 500
  - Penalties/prosecutions: 50
  - Implementation: Requires appointment of project manager and delivery monitored by a CIP Steering Committee.
  - Reporting: Detailed plan should set numbers of activities each month with expected outcomes; completed activities and outcomes are reported to monitor progress and measure efficiency.

- EVALUATION OF COMPLIANCE STRATEGY
  - Direct measures:
    - Additional registrations, lodgments and payments secured
    - Revenue from activities such as communication messages, prompts and other targeted facilitation measures
    - Additional tax from enforcement activities such as audits and investigations
  - Broader impact measures:
    - General increases in registrations, filings, payment, and revenue increases for the whole population
  - Methodological note:
    - Use a suite of measures; consider a control mechanism by not applying the treatment strategy to one region with high tourism to compare outcomes.

- CAPABILITY DEVELOPMENT (identified needs)
  - Access to accurate, complete, and relevant data across all four pillars of tax obligations and by sub-sector
  - Skills and resources to deliver the facilitative strategies
  - Improved audit capability to further understand and address specific risks at the taxpayer level
  - Improved understanding of CRM and its benefits across the GDT provincial and district offices

*Source: IMF FAD short-term in-country CD summary report to GDT, February 14–22, 2023.*

### 1.      This is a summary report concerning an in-country capacity development (CD) activity

### 1vnmea2023002 - 1.      This is a summary report concerning an in-country capacity development (CD) activity

### Purpose and scope
- CD delivered by Mr. Andy Ditchfield and Mr. Steve Howlin (IMF Fiscal Affairs Department (FAD) Short Term Experts (STX)) to the General Department of Taxation (GDT) of Vietnam during the period February 14 to 22, 2023.
- Objective: consolidate and build on CRM remote training delivered in September and November 2022 by practically applying CRM principles to the tourism sector to finalize a tourism sector compliance improvement plan (CIP).
- The tourism sector CIP is a pilot to give GDT experience and confidence to extend contemporary CRM practices to other sectors and specific compliance risks.

### Recent developments
- Vietnam Tax System Reform Strategy (TSRS) for 2021-2030 requires a risk-based approach; TSRS approved by the Prime Minister.
- Risk Management Board (RMB):
  - Currently a temporary board within GDT; authority derived from circular 31.
  - RMB reports to a single Deputy Director General rather than to a Risk Management Steering Committee (RMSC).
  - International practice: an RMB typically reports to a RMSC composed of representatives from relevant departments.
  - Recommendation: establish an RMSC before Tourism CIP implementation (Appendix I describes roles/responsibilities).
- RMB capabilities and challenges:
  - RMB has a good understanding of CRM principles and embraces using educate, facilitate and enforcement treatments across registration, filing, correct reporting and payment.
  - Dissemination of CRM principles beyond RMB is limited; outside RMB, focus remains on audit activity and audit results (hit rate, value of adjustments).
  - International experience: audit alone cannot shift underlying non-compliant behavior; contemporary CRM requires targeted programs of education, facilitation and enforcement.
- Rationale for selecting tourism as pilot:
  - Tourism significance: 8 percent of GDP in 2018.
  - Visitor numbers: 15 million foreign visits and 80 million domestic visits.
  - Tourism services delivered in Vietnam should be taxed in Vietnam, reducing leakage.
- Pilot geographic focus: the 5 main tourism provinces to enable manageable demonstration and comparison.

### Summary of support provided (workshops and CRM steps)
- Nine workshops held between February 14 to 22, 2023. Sequential CRM steps applied (A to F below).

A. Understanding and improving the data collected
- RMB had difficulties obtaining relevant, accurate and complete tourism data; RMB does not have direct access to IT-held data and must request it.
- Partial data were displayed during workshops; RMB improved data after examinations.
- Planned separate duplicate database for RMB in early 2024 to allow manipulation without compromising raw data integrity; must be synchronized regularly with raw data.
- Data integrity issues observed: missing subsectors, inclusion of non-tourism business activities; some data not credible.
- VSIC (Vietnam standard industrial code) limitations: tourism not specifically designated; subsectors relevant to tourists can be identified cautiously; taxpayer returns mix local consumers, domestic tourists and foreign tourists—isolating tourists is not possible from return data.
- Data filtering agreed for analysis:
  - Five provinces
  - Subsector (restaurants, hotels, retail, transport, entertainment, and tour operators)
  - Market segment (Large, medium, small)
  - Year
- Example data finding: retail ratio of net VAT (output VAT minus input VAT) as a proportion of output VAT was just 1.64 percent over the three years 2018 to 2020; in some years input VAT exceeded output VAT in the medium market segment.
- Observations:
  - Data seen limited to VAT returns (correct reporting pillar); further data needed for profits tax, wages tax and other pillars (registration, filing, payment).
  - Document V3.1 (Vietnam Tourism Risk Assessment – Research and data gathering template, November 2022) guides required data.
  - Fiscalization data (fiscal cash register and e-invoice data) recommended to identify risks (underdeclared sales, overclaimed purchases) and VAT refund fraud risks.
  - A revised version 2 of document V3.1 with relevant ratios was provided during assistance.

B. Rating and ranking risks in tourism subsectors
- Workshops segmented tourism by geography, subsector, pillars of compliance, market segment and other features (e.g., online sales).
- High risks identified:
  - Filing and correct reporting (underdeclared sales and overclaimed purchases) for small and medium hotels.
  - Large market hotels: high risk due to transfer pricing opportunities.
- RMB should establish consistent risk consequence and likelihood criteria.
- Risk ranking must be confirmed by data and consultation within GDT, including provincial and district tax administrations.
- Initial conclusions are provisional and expected to change as more data and experience accumulate.

C. Analyzing taxpayer behavior and developing a blend of treatments
- Motivations for non-compliance identified: greed, social acceptance, concerns about public spending, unrecognized benefits of taxation, regulatory burden, geographic remoteness, low fear of detection or effective action by GDT.
- Treatments identified: educate, facilitate and enforce strategies.
- Need to shift GDT mindset from audit-only focus to a balanced approach including education and facilitation; effectiveness should not be measured by audit results alone.
- Graduated treatment strategy illustrated:
  - Highest risk taxpayers: audited (in-depth profile, interview, audit techniques, assessment).
  - Medium risk taxpayers: letter indicating poor tax performance, self-assessment tools, future compliance monitoring.
  - Low risk taxpayers: education, communication and media, monitoring.
- Case selection criteria should be reviewed to align with regional focus on tourism; templates and instructions (profile, audit, letters) and specific reports (audit quality, self-assessment, staff development) are part of the approach.

D. Developing a tourism CIP
- A CIP was prepared based on workshop conclusions.
- Appendix II provides a one-page overview of the CIP and background documentation; background part needs expansion with more detail.

E. Planning the implementation of the CIP
- Two workshops discussed implementation prerequisites and measuring success: capacity development, communications and messaging, taxpayer services, audit capability and quality assurance, workflows, monitoring and measuring success.
- GDT should prepare a detailed implementation action plan covering all CIP aspects.

F. Next sector focus: e-commerce
- Workshop covered e-commerce scope, segmentation (domestic, international, goods, services), supply chain participants, intervention points and potential treatments.
- RMB should apply the same CRM process and provided PowerPoint slides/documents to e-commerce.

### Recommendations and further assistance
- Key recommendations:
  - Establish a Risk Management Steering Committee (RMSC) to review, approve and oversee the CIP and key risk documents; demonstrate governance and improve integration among core GDT functions.
  - Improve data quality: RMB, IT and registration/filing/payment departments should define and agree data requirements for risk management to ensure accurate, complete and relevant data for risk assessments, rankings and the CIP.
  - Improve RMB access to data: while RMB access is planned for 2024, timely interim access is critical to finalize the tourism CIP; from 2024 RMB should have access to all relevant data across the four pillars, including e-invoices, fiscalization data and any third-party data.
  - RMB engagement with provincial tax administrations: establish robust relationships so provincial administrations understand CRM benefits and participate in CIP development and delivery.
  - Finalize tourism CIP documentation and plans, including analysis of accurate and complete data; use notes to the draft CIP at Appendix II.
- Further FAD assistance that could be provided:
  - Review and recommend on CIP implementation plans before CIP implementation.
  - Deliver Tourism CIP presentations to selected provincial administrations (Hanoi, Da Nang, Ho Chi Minh City).
  - Prepare tourism project audit instructions (hotels, restaurants, retail).
  - Develop tourism project letters for medium risk taxpayers.
  - Audit quality assurance process design.
  - Review of risk criteria used in audit case selection.

### Recommended key actions and timelines
- Access data and critically assess the data
  - Action: Access data as per V3.1 data request; use the data to confirm/deny initial risk ranking conclusions made during Feb workshops.
  - Timeline: May 2023
- Complete Draft CIP for tourism sector
  - Action: Closely follow guidance to complete the CIP as provided in the draft CIP, document V15.0.
  - Timeline: May 2023
- Develop Tourism CIP implementation action plan
  - Action: Develop a detailed action plan in consultation with departments that will deliver activities; set timeframes, expectations and a monitoring and reporting mechanism.
  - Timeline: May 2023

*Source: IMF FAD short-term in-country CD summary report to GDT, February 14–22, 2023.*

### 34.      The following is a list of workshop materials and other documents provided during the

### 34. The following is a list of workshop materials and other documents provided during the CD activity

### Workshop materials and documents
- V3.1 Vietnam Tourism Risk Assessment – Research and data gathering template (updated 19 February 2023) (English update) — W
- V6.0 CRM (Tourism sector). Overview February 2023 assistance — W
- V7.0 Understanding and analysing the data gathered by GDT — W
- V8.0 Segmenting the population, risk rating and ranking — W
- V8.1 Exercise - Rating and ranking tourism sub sectors — D
- V8.2 Risk register content — D
- V9.0 Supply chain analysis, participants and stakeholders — W
- V10.0 Understanding the behaviours that drive non-compliance — W
- V10.1 Summary and explanation of factors influencing compliance behaviour — D
- V10.2 Exercise - risk, behaviours, treatments - tourism sector — D
- V11.0 Strategy development to educate, facilitate and enforce compliance — W
- V12.0 Implementing strategies - timeline, capability, communications and workflow planning — W
- V13.0 Measuring efficiency and effectiveness — W
- V14.0 Focus on e-commerce as the next priority risk — W
- V15.0 Draft Compliance Improvement Plan v3 — D

### Appendix I — Role of the Risk Management Steering Committee (RMSC)
- Purpose:
  - Provide strategic insight, approval, support and governance for identification and mitigation of compliance risks using contemporary Compliance Risk Management (CRM) processes.
  - Add value to Risk Management Board (RMB) work by applying collective experience to improve and approve RMB recommendations.
- Typical composition (should consist of senior officials from a broad range of areas within GDT):
  - Director General as chair of the committee
  - Deputy Directors
  - Risk Management Board leader
  - Leaders of pillars of compliance functional areas (registration, filing, payment)
  - Heads of audit, including a provincial audit representative and head of Large Taxpayers Office
  - Heads of small and medium taxpayer segments
  - Education and customer services/support
  - Communications and marketing
  - Law interpretation
  - Internal Inspection (Objections)
  - External representatives from Ministry of Finance and Customs
  - Others may be added as needed
- Specific practical responsibilities:
  - Providing intelligence on known and emerging risks
  - Reviewing and approving risks identified and risk rankings recommended by RMB
  - Reviewing, improving and approving risk assessments by providing strategic insight and practical experience of risks
  - Reviewing and approving treatment plans by providing strategic insight, operational experience and support for plans
  - Approving compliance improvement plans
  - Approving allocation of resources to implement treatment plans
  - Approving capability improvements to ensure effective delivery of the plans
  - Reviewing and approving compliance improvement effectiveness measures
  - Monitoring and reviewing performance against plans
  - Reviewing the effectiveness of risk treatment strategies
  - Adjusting treatment strategies to improve effectiveness

### Appendix II — Tourism Compliance Improvement Plan – Summary One-Page (Vietnam Draft Compliance Improvement Plan – Tourism Sector)
- 1. PLAN OVERVIEW
  - Aim: to make a sustainable improvement in compliance in this significant and non-compliant sector by practically applying contemporary compliance risk management principles.
  - Approach: data driven, whole of GDT approach (audit, education, services) focusing on highest risk aspects of tourism.

- 2. SEGMENT PROFILE
  - Definition: Businesses operating in Tourism across all segments, which contributes 2% of GDP (2021) but likely to increase to pre-COVID levels of 8/9%. Tourism is located in 5 main geographic provinces.
  - Revenue: Net tax revenue (CIT/VAT/PIT) from this segment is xx billion.
  - Number of taxpayers: There are xxxx businesses in this sector, mostly small and medium businesses.
  - Tax returns: Total filing obligations for all taxpayers is xxx for annual and yyyy for quarterly/monthly.
  - Key subsectors: Transport, accommodation, restaurants and cafes, tour operators, retail and entertainment.
  - Important intermediaries: Travel agents, customs.

- 3. RISK ASSESSMENT
  - Registered risk ratings identified in workshops:
    - Registration risk - HIGH (mainly small and micro segment across all subsectors, includes household businesses in restaurants and hotels and street vendors)
    - Filing risk - HIGH (failure to file evident across all subsectors, particularly in accommodation)
    - Reporting risk - HIGH (underreporting of sales mainly in cash transactions and inflation of expenses; in large taxpayer sub-sector transfer pricing is a key risk)
    - Payment risk – NOT RATED
  - Typical taxpayer behaviors: Greed, social norms and no fear of being caught, especially in medium and small segments.
  - Geographic focus for treatments: five geographic provinces where tourists predominantly visit.
  - Note: These risks and their ratings were identified in workshops as the highest risks. Other risks exist but are considered lower risk by default.

- 4. RISK TREATMENT
  - Facilitative approaches:
    - Broad one to many communications in the subsectors focusing on education, social impact and consequences of being identified and acted upon.
    - Targeted communications to medium risk taxpayers/businesses requiring improvement in tax obligations such as correct tax reporting performance.
    - Prompting messages to taxpayers and follow up contact (telephone calls/interviews etc).
  - Enforcement approaches:
    - Interviews, audits and examinations for highest risk taxpayers (particularly those that have not responded to targeted messaging).
    - Outbound calls for non-filing.
    - Penalties and prosecutions for continued non-compliance and those that deliberately and repeatedly ignore obligations.
  - Rationale: Combine facilitative and enforcement approaches; escalate to enforcement when taxpayers do not respond to facilitative measures. International experience shows many respond to facilitative approaches producing sustainable compliance improvement.

- 5. WORKFLOW AND MONITORING
  - Focus: Five geographic provinces; treatment activity counts planned and actual:
    - One to many communications: 50
    - One to one communications: 5000
    - Prompting messages: 2000
    - Audits/examinations: 250
    - Telephone calls/interviews: 500
    - Penalties/prosecutions: 50
  - Implementation: Requires appointment of project manager and delivery monitored by a CIP Steering Committee.
  - Reporting: Detailed plan should set numbers of activities each month with expected outcomes; completed activities and outcomes are reported to monitor progress and measure efficiency.

- 6. EVALUATION OF COMPLIANCE STRATEGY
  - Direct measures:
    - Additional registrations, lodgments and payments secured
    - Revenue from activities such as communication messages, prompts and other targeted facilitation measures
    - Additional tax from enforcement activities such as audits and investigations
  - Broader impact measures:
    - General increases in registrations, filings, payment, and revenue increases for the whole population
  - Methodological note:
    - Use a suite of measures; consider a control mechanism by not applying the treatment strategy to one region with high tourism to compare outcomes.

- 7. CAPABILITY DEVELOPMENT
  - Identified capability needs:
    - Access to accurate, complete, and relevant data across all four pillars of tax obligations and by sub-sector
    - Skills and resources to deliver the facilitative strategies
    - Improved audit capability to further understand and address specific risks at the taxpayer level
    - Improved understanding of CRM and its benefits across the GDT provincial and district offices

*Source: PDF content provided from the Vietnam tourism sector compliance materials and appendices.*

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_Source: https://www.imf.org/-/media/files/publications/cr/2023/english/1vnmea2023002.pdf_