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### Governance concept and importance
- Governance: from Greek ‘kubernan’ (‘to steer’); in public administration refers to institutions, rules, mechanisms, and established practices through which a government authority:
  - exercises its powers and functions,
  - discharges its responsibilities, and
  - manages its public resources.
- ‘Good governance’ is qualitative; quality affects effectiveness.
- Economic aspects include administrative efficiency, policy effectiveness, fairness and equity.
- UN ESCAP eight characteristics of good governance: participatory, consensus oriented, accountable, transparent, responsive, effective and efficient, equitable and inclusive and follows the rule of law.

### Legal frameworks and rule of law
- Well-designed and comprehensive legal frameworks are required where governance is based on the rule of law.
- Strong legal frameworks are especially important when designing and implementing reforms to ensure interaction with existing rules, structures and institutions.
- In contexts of weak rule of law and pervasive corruption, strong legal frameworks can help as part of broader mitigation efforts.
- The paper focuses primarily on country contexts where the rule of law is relatively robust.

### Taxation, sovereignty, and taxpayer safeguards
- Levying and enforcing taxes are core manifestations of sovereignty and public authority.
- Governance arrangements must ensure powers are exercised transparently and evenhandedly so that:
  - taxpayers’ rights are respected,
  - voluntary compliance is promoted, and
  - appropriate taxpayer safeguards exist when enforced compliance action is undertaken.
- Governance vulnerabilities weaken revenue collection and create opportunities for corruption.
- Poor revenue collection can create or exacerbate fiscal imbalances, deficit and debt accumulation and undermine public services.
- Poor tax governance may foster “creative compliance” cultures and low tax morale, eroding trust in government.

### Institutional integrity and continuous upgrading
- Institutions must be continuously upgraded to address new challenges (for example, technologies and opportunities for wrongdoing).
- Integrity of processes is especially important in higher-risk areas (for example, procurement, tax administration, public enterprises) and to promote effective internal controls.
- A tax administration should be—and be perceived to be—rules-based, transparent, fair and accountable to foster tax compliance through taxpayer trust.

### Weak legal design and “corrupt legality”
- Weaknesses in the legal framework (institutional and procedural) often underpin governance vulnerabilities in the tax system.
- Poor tax law design can create ‘corrupt legality’: legal gaps, unnecessary complexity and ambiguity that enable:
  - ‘negotiated interpretations’ and
  - ‘creative enforcement’ by tax officials,
  while taxpayers may comply ‘creatively’ with obligations.

### Limits of legal reform and complementarities
- Strengthening legal frameworks is necessary but not sufficient.
- Legal reform is more likely to succeed where corruption is not systemic and when multiple, mutually supporting institutions are improved.
- Reforms to tax administration yield greater payoff if tax laws are simplified and discretionary scope for tax officials is reduced.

### Scope and structure of the paper
- Presents an analytical framework on key legal design features for good governance of the tax system, focusing on legal arrangements to support tax administration and its interactions with taxpayers.
- Does not address broader tax policy, institutional and operational issues.
- Structure (as described): Section I outlines broader tax governance considerations and core governance principles in tax administration and tax procedure. Sections II and III apply core principles to derive legal principles for tax administration (section II) and tax procedure (section III). Finally, section VI offers conclusions.

### Key conclusions — I. Tax Governance: Concept and Core Principles
- Tax governance defined as "a coherent set of rules and institutions that comprehensively govern the tax system."
  - Encompasses institutional governance of tax administration and cuts across tax policy and legal design, lawmaking process, tax procedure, oversight structures, the judiciary, the international tax framework, and taxpayers.
  - Must ensure respect of legal certainty, equity and fairness, and proportionality.
  - May require empowering the judiciary to address governance shortcomings using administrative or constitutional law principles.
- Well-functioning tax systems anchor governance arrangements in law and promote the rule of law to:
  - promote tax policy and administration improvements,
  - strengthen state accountability and responsiveness,
  - support efficient and effective revenue collection.
- Tax law frameworks divided into three interrelated rule types:
  - Substantive tax rules,
  - Procedural (formal) tax rules,
  - Institutional rules and arrangements.
- Overarching legal design principles to strengthen governance:
  - Reducing uncertainty: identify obsolete provisions, untangle dysfunctional provisions, introduce comprehensive, clear and simple rules, reduce bureaucracy with transparent procedures.
  - Aiming for structure: consolidate fragmented provisions under tax codes; legislate tax changes via specific tax bills; develop impact assessment frameworks including implementation, revenue impact and ex post evaluation.
  - Ensuring transparent and effective implementation: access to justice, enforce court decisions, sequence reforms based on administrative capacity.
  - Getting ‘buy in’: formal and inclusive public consultation with key stakeholders.
  - Administering taxes ‘well’: strengthen institutional arrangements providing autonomy balanced with transparency and accountability; ensure efficient interaction with tax policy; use secondary instruments/regulations or administrative guidance for flexibility and clear implementation.
  - Ensuring taxpayer fairness: transparent implementation (including international context), effective dispute prevention/resolution, strong confidentiality and data governance, minimize discretion, address equality/equity concerns (for example, gender discriminatory policies).

### Key conclusions — II. Governance in Tax Administration and Tax Procedure: Core Principles
- No "one size fits all" model; country specificities matter.
- Guiding principles grouped under:
  - (a) Transparency and accountability;
  - (b) Sound decision-making structures;
  - (c) Fairness; and
  - (d) Effectiveness and efficiency.
- Interactions and synergies:
  - Procedural safeguards communicate fairness, effectiveness and efficiency to taxpayers and inform internal arrangements (e.g., staff integrity frameworks).
  - Transparency, accountability and sound decision-making shape how discretionary powers are applied.

### Governance arrangements in tax administration — core features and challenges
- Tax administrations are complex organizations with critical macroeconomic and developmental roles; they:
  - have specialized workforces and extensive office networks,
  - enforce wide-ranging legislation and wield intrusive legal powers,
  - rely on core business processes and digital systems holding confidential data,
  - are monitored against performance targets and typically advise on policy.
- Common governance challenges:
  - Overly complex and non-transparent organizational structures,
  - High compliance and administration costs,
  - Wide discretionary powers that increase corruption risk and undermine trust,
  - Misunderstanding or misuse of administrative autonomy without robust accountability.
- Legal frameworks vary: TAPA, stand-alone TAA for SARAs, or ministerial department frameworks via secondary law.
- Core governance features requiring legal basis include accountability, transparency, integrity, delegation, and safeguards on discretion.

### Core governance principles for tax administration — Accountability and Transparency
- Legal framework should provide robust accountability and transparency tailored to context.
- Accountability required at organizational and staff levels.
- Key accountability features:
  - Robust internal and external audit mechanisms (internal audit reporting directly and regularly to the Head; strong external oversight by Auditor-General/Court of Auditors).
  - Clear rules for oversight by minister/executive authority and/or parliament, including periodical reporting on revenue data and performance metrics.
  - Clear rules for use and control of financial resources with transparency and reporting.
  - Clear framework for staff conduct integrity, supported by systems and procedures and criminal enforcement for fraud and corruption.

### Box 1 — Basic Design Elements of a Staff Integrity Framework (core elements)
- Proper internal and external audit and reporting requirements; delegation framework and operational governance (e.g., ‘two pairs of eyes’).
- Merit-based recruitment and employment frameworks with defined competencies and competitive remuneration; mandatory ethics training and code of conduct.
- Corporate governance principles: fit and proper assessments for the Head and potential Board members; ethics and social responsibility committees; internal audit committees.
- Comprehensive staff disciplinary framework (including criminal liabilities) for breaches of duties, including confidentiality and abuse of powers, consistently enforced.
- Mandatory disclosure requirements to detect conflicts of interest.
- Publicly accessible, regularly updated asset declarations for elected officials, political appointees and senior staff, including gifts.
- Whistleblower framework with safeguards against reprisals.

### Transparency (organizational and taxpayer matters) — design highlights
- Regular public reporting on operations and finances and performance against objectives.
- Publication of anonymized private tax rulings and publication of administrative appeal decisions in anonymized form.
- Where individual tax waivers exist: reduced discretion, transparent procedures for granting waivers and regular publication of waivers granted (anonymized).
- Note: Transparency in collection (seen in some Nordic countries) may be considered but poses privacy concerns.

### Sound decision-making structures — legal design highlights
- Clear and transparent legal framework for responsibilities, delegation rules, and internal checks and balances.
- Functional segregation of duties (e.g., administrative review separate from audit).
- Escalation systems for complex decisions.
- Statutory basis for delegation and safeguards on discretionary powers: clear guidance on exercise of discretion, internal cross-checking systems, and public reporting where discretion is exercised.
- Common discretionary areas: Waivers; Instalments; Interest and penalties; Filing and payment extensions; Collection and recovery actions; Tax law interpretations.

### Institutional design and mandate — models and considerations
- Institutional model alternatives:
  - Directorate of responsible ministry;
  - Separate government department within MoF/Treasury;
  - Semi-autonomous revenue authorities (SARAs).
- Four broad institutional design variations:
  - Single directorate/department within the MoF;
  - Multiple directorates/units within the MoF;
  - Unified semi-autonomous body reporting to a Commissioner/Director General;
  - Unified semi-autonomous body with a board (decision-making or advisory).
- Institutional autonomy effects:
  - Enables operational freedom from political interference, organizational flexibility and potential efficiency gains.
  - Under the ministerial directorate model, tax administration under direct MoF control with shared centralized services.
  - SARAs generally operationally independent, may have greater flexibility from civil service rules.
- Legal basis and foundational instruments important for SARAs (legal personality, judicial standing, property ownership).
- Mandate typically: collect the right amount of tax at the right time in accordance with the rule of law, using resources efficiently with least burden to taxpayers; may include tax, customs, social security contributions, criminal tax investigations and money laundering investigations. Mandate may be explicit in law or derived from functions; making mandate explicit aids accountability.

### Autonomy — functional, operational, and financial (key legal-design considerations)
- Functional autonomy considerations:
  - (i) robust delegation of powers;
  - (ii) independence from political direction in decisions on a person’s tax affairs;
  - (iii) robust information and enforcement powers, including handling administrative appeals and imposing penalties according to law;
  - (iv) personal autonomy arrangements protecting staff from personal liability except for willful default or gross negligence;
  - (v) authority to provide public and private tax law interpretations subject to judicial review.
- Operational autonomy features:
  - administer in-house IT systems;
  - determine internal organization and set performance standards;
  - formulate strategic and business plans;
  - autonomy in HR policies (recruitment, career development, remuneration, incentives).
- Financial autonomy features:
  - flexibility to allocate resources within budget;
  - budget security (for instance, through a “safety net” on a yearly allocated budget);
  - operational flexibility in spending, supported by own financial services office in some cases.
- Financial autonomy supports adequate wages and conditions to attract staff and reduce corruption; must align with public financial management rules (budget estimates, performance-based incentives, etc.).

### Interaction with other legal frameworks
- Effectiveness requires interaction with: constitutional law, tax procedures law, public procurement law, fiscal law, civil service law, privacy law, general administrative law, and criminal law.
- These interactions ensure consistency of legal form/status, delegation frameworks, procurement for IT, budget and fiscal oversight, HR policy alignment, taxpayer information safeguards, operational independence, and accountability for abuse of power.

### SARAs — additional considerations
- SARAs increasingly assume tax administration functions; autonomy believed to improve revenue collection efficiency.
- SARAs commonly:
  - set operational policies to ensure freedom from political interference,
  - are accountable to ministry and/or parliament,
  - may enjoy independence from public service rules while under government control and oversight.
- Key design considerations when establishing SARAs:
  - Institutional autonomy via separate entity establishment,
  - Legal personality issues: judicial standing, contractual representation, procurement, property ownership.

### Governance organs and internal structures (SARA-specific)
- Head of SARA — law should specify:
  - transparent selection and appointment process, tenure with fixed term and possible one-time renewal, clear removal circumstances, minimum professional qualifications, conflicts of interest framework and possible cooling-off period, functions and powers including delegation and any regulatory powers.
- Management Board — role and features:
  - oversight and strategic guidance (not operational decision-making in individual tax affairs),
  - composition mixing ex-officio public sector members and possible private sector members,
  - selection and appointment via independent committee and approval by President/Parliament or MoF,
  - fixed tenure with possible one-time renewal or rolling tenure,
  - clear role definition vis-à-vis the Head.

### Institutional oversight (SARA-specific)
- Oversight arrangements must be explicitly prescribed in law and typically include:
  - direct relationship with responsible ministry (typically MoF);
  - accountability to MoF for administering revenue laws within governing rules without political involvement in specific cases;
  - complementary oversight by supreme audit institutions, parliamentary oversight, taxpayer ombudsperson, and management board where applicable.

### Enhanced accountability and transparency for autonomous SARAs
- Design features for enhanced accountability:
  - KPIs reported regularly to MoF and publicly;
  - Depositions of Management Board and/or head before Parliament;
  - Submission of annual report, strategic and business plans to MoF and Parliament;
  - Publication of strategic plan, annual business plan, monthly progress and expenditure reports.

### Core governance principles in tax procedure (summary)
- Fairness:
  - equity and neutrality complemented by legal taxpayer safeguards at all stages of tax procedure.
  - Key considerations: structured interaction (self-assessment backed by audit), IT for services, minimize discretionary interpretation, clearly prescribed criteria for discretion.
- Principle of sound administration:
  - right to impartial, fair, timely handling; right to be heard; access to file; protection of legitimate expectations; obligation to give reasons for decisions; segregation of powers; taxpayer ombudsperson; framework for basic taxpayer rights.
- Effectiveness and efficiency:
  - balance collection with efficient taxpayer services via clarity, simplicity, consistency, responsiveness; clear language, unified procedural laws, user-friendly guidance, timelines for responses and remedies for missed deadlines.

### Legal design considerations for tax procedure
- Two approaches:
  - Each substantive tax law contains its own administrative provisions.
  - A law on tax administration and procedure (TPL) sets out common administrative procedures for multiple substantive tax laws.
- Recommendation: Legal design should inform development of governance arrangements in tax procedure legislation and be used in diagnostics.

### Box 4 — Steps for Setting Up a Governance Framework in Tax Procedures Legislation
- Assessment and legal-design questions:
  - Undertake assessment of existing arrangements and shortcomings as part of wider governance diagnostic.
  - Ask: The What; The How; The Where; The When regarding legal features, instruments, placement, and sequencing.
- Benefits of a separate Tax Procedures Law (TPL):
  - sets out common administrative provisions,
  - strengthens tax administration management and operational capacity,
  - supports domestic revenue mobilization and governance,
  - reduces complexity in substantive tax laws,
  - promotes harmonization and functional organization across taxes,
  - enhances tax certainty and accessibility,
  - facilitates future reform and transparency of taxpayer rights.
- Key design considerations for a stand-alone TPL:
  - enhance governance arrangements across stages of tax procedure,
  - ensure smooth integration with broader domestic legal framework.
- Necessary steps for successful introduction:
  - careful review and redaction of substantive laws,
  - align with related laws (civil procedure, company law, court procedure),
  - adjust cross-references,
  - consolidate substantive tax legislation,
  - introduce transitional provisions,
  - educate tax administrators and taxpayers,
  - identify regulations/guidelines needed for implementation.

### Ensuring adequate taxpayer safeguards through governance arrangements in tax procedure
- Rationale: tax administrations have intrusive powers; legal safeguards needed to balance powers and provide remedies.
- Examples of rights and safeguards:
  - well-functioning objections and appeals processes,
  - advance rulings regimes,
  - accessible taxpayer services,
  - taxpayer charters or bills of rights,
  - taxpayer ombudsperson.
- Good practice: organize procedural protections in a separate section of tax administration law or in the TPL; cover registration, rulings, information powers and confidentiality, communications, access to file, filing and assessments, verification actions, refunds, penalties and interest, collection and enforcement, dispute resolution and judicial recourse.
- Key tax administration powers and corresponding fundamental taxpayer rights (selected pairings):
  - Power to enter premises — Right to privacy
  - Enforced collection actions — Right to property
  - Default and protective assessments — Right to be heard
  - Discretionary powers — Right to equal treatment
  - Tax audits — Right to due process
  - Objections and appeals — Right to review and (timely) remedy
- Multi-layered legal framework: constitutional principles, administrative law, TPL/tax administration law, secondary legislation, and international conventions.

### Annex I — Checklist highlights (Ensuring Adequate Taxpayer Safeguards)
- Registration and TIN use, equal timelines, obligations to notify changes, clear compulsory registration/de-registration rules with safeguards.
- Tax law interpretations: timely, transparent, non-retroactivity to taxpayers’ detriment, advance rulings with publication of redacted versions.
- Information powers and confidentiality: need-to-know access, strict confidentiality obligations, statutory framework for third-party reporting, proportionality in data collection, review mechanisms for excessive powers.
- Communications and notices: standards for service, electronic communication rules, reasonable written notice requirements.
- Right to information and access to file: timelines for access, obligation to notify data collection/use.
- Filing and assessments: e-filing frameworks, amending returns, assessment types and notification, criteria for filing extensions, prescription suspension/extension rules.
- Verification actions: right to be heard during audits, clarify burden of proof, minimum bookkeeping requirements, detailed auditor reports to taxpayers, due process safeguards for intrusive powers, oversight of automated decision-making.
- Refunds: clear time limits and interest on late refunds.
- Penalties and interest: commensurate penalties, specify interest calculation (e.g., daily or monthly), internal guidance, minimize discretion in waivers, order of application of payments.
- Collection and enforcement: legislative collection powers with due process protections, judicial clearance for serious measures, third party liability rules, internal oversight for significant actions, offsetting provisions, installment frameworks with clear eligibility, safeguards against undue hardship (minimum thresholds, ability for urgent court review, protection of minimum vitale, exclusion of certain property).
- Dispute resolution: unify processes, independent administrative review separate from audit, judicial appeal conditional on administrative appeal or failure to decide within prescribed time, reporting and transparency on appeals, qualifications/conflict rules for quasi-judicial bodies.

### Annex II — Examples of Mandate Provisions and Mission Statements (selected examples)
- Canada Revenue Agency (CRA) — Mandate (CRA Act, section 5) and mission/vision/promise and Values: Integrity, Professionalism, Respect, Collaboration.
- South African Revenue Service (SARS) — Objectives, Functions, Powers (Act 34 of 1997, sec. 3-5); functions to secure enforcement, advise Minister, perform functions cost-efficiently in accordance with section 195 of the Constitution; powers include determining staff establishment, acquiring property, opening bank accounts, instituting legal action, etc.
- Inland Revenue Authority of Singapore (IRAS) — Functions and powers (CAP. 138A of 2012, sec. 6-7) and mission/vision with corporate goals and core values: FAIRNESS, INTEGRITY, PROFESSIONALISM, TEAMWORK, INNOVATION.
- Directorate of Taxation, Republic of South Sudan — Taxation Act, 2009, Section 8: guiding principles emphasizing transparency, taxpayer education, uniform application, selection and training for honesty, swift and uniform sanctions, educational outreach, and reliance on compliance programs.

### Annex III — Institutional oversight and accountability provisions (Canada Revenue Agency Act highlights)
- Ministerial responsibility: Sec. 6(2) "The Minister is responsible for the Agency."
- Minister may direct on exercise of powers: Sec. 9; directions to the Agency: Sec. 11(1) and (2); compliance required: Sec. 12.
- Commissioner obligations to inform and assist Minister: Sec. 38(1) and (2).
- Management Board role and limits: Sec. 31(1) oversight of organization and resources; Sec. 34 prohibits Board directing Commissioner on exercise of statutory powers or enforcement.
- Corporate business plan, audits, and annual report: Secs. 47(3), 48, 49(1)-(2); Auditor General auditing role: Sec. 87; annual report requirements and tabled in Parliament: Sec. 88(1)-(2) with specified contents.

### Final overarching conclusions
- Core governance principles are foundational for robust tax administrations operating through fair and effective tax procedure arrangements.
- The paper develops an analytical framework to derive core legal principles for sound governance in tax administration and tax procedure to inform tax law design.
- Legal frameworks are crucial but insufficient alone; effective implementation requires mechanisms outside tax institutions (for example SAIs, law enforcement, and the courts).
- The tax policy function should work closely with tax administration to implement tax laws transparently and effectively and ensure balanced implementation mechanisms.
- Enhanced governance structures are necessary for SARAs given greater institutional autonomy.
- Governance arrangements in tax procedure help achieve balance: equity and neutrality-based policies should be complemented by legal frameworks providing taxpayer safeguards to ensure fair treatment, respect for fundamental rights, and trust promoting compliance.

*Source: wpiea2025017-print-pdf*

### Introduction ...........................................................................................................

### Introduction

### Governance concept and importance
- The term ‘governance’ derives from the Greek ‘kubernan’ (‘to steer’) and has various meanings depending on context.
- In public administration, ‘governance’ refers to the combination of institutions, rules, mechanisms, and established practices through which a government authority:
  - exercises its powers and functions,
  - discharges its responsibilities, and
  - manages its public resources.
- ‘Good governance’ is a qualitative concept: the quality of governance affects its effectiveness.
- Economic aspects of good governance include administrative efficiency and policy effectiveness, and also notions of fairness and equity.
- UN ESCAP identifies eight major characteristics of good governance: participatory, consensus oriented, accountable, transparent, responsive, effective and efficient, equitable and inclusive and follows the rule of law.

### Legal frameworks and rule of law
- In systems based on the rule of law, governance arrangements need support from well-designed and comprehensive legal frameworks.
- Strong legal frameworks are particularly important when designing and implementing reforms so governance arrangements interact appropriately with existing rules, structures and institutions.
- In environments where rule of law is weak and corruption is systemic and pervasive, adopting strong legal frameworks can help as part of broader efforts to mitigate those challenges.
- This paper focuses primarily on country contexts where the rule of law is relatively robust.

### Taxation, sovereignty, and taxpayer safeguards
- Levying and enforcing taxes are core manifestations of sovereignty and the exercise of public authority.
- Appropriate governance arrangements are required to ensure powers associated with that authority are exercised transparently and evenhandedly so that:
  - taxpayers’ rights are respected,
  - voluntary compliance is promoted, and
  - appropriate taxpayer safeguards are in place when enforced compliance action is undertaken.
- Governance vulnerabilities in the tax system weaken a government’s ability to collect revenues and create opportunities for corruption.
- Poor revenue collection can create or exacerbate fiscal imbalances, deficit and debt accumulation and undermine public services.
- Poor tax governance may foster behavioral problems such as an engrained culture of ‘creative compliance’ and low tax morale, with corrupt practices further eroding trust in government.

### Institutional integrity and continuous upgrading
- To reduce opportunities for corruption, institutions need to be upgraded continuously to keep pace with new challenges (for example, technologies and opportunities for wrongdoing).
- Ensuring integrity of processes is especially important in higher-risk areas (for example, procurement, tax administration, public enterprises) and to promote effective internal controls.
- A key component to encourage tax compliance is to foster taxpayers’ trust in the tax system; a tax administration needs to be—and be perceived to be—a rules-based, transparent, fair and accountable institution.

### Weak legal design and “corrupt legality”
- Governance vulnerabilities in the tax system can often be traced to weaknesses in the legal framework underpinning the tax system, including institutional and procedural aspects.
- Weak tax law design can facilitate corruption by promoting a state of ‘corrupt legality’: legal gaps, unnecessary complexity and ambiguity create opportunities for:
  - ‘negotiated interpretations’ and
  - ‘creative enforcement’ by tax officials,
  while taxpayers may comply ‘creatively’ with their tax obligations.

### Limits of legal reform and complementarities
- Strengthening the legal framework is necessary but not sufficient to address tax governance vulnerabilities.
- The chances of success for legal reform are higher where corruption is not systemic and when countries improve several, mutually supporting institutions.
- Reforms to tax administration will have greater payoff if tax laws are simplified and the scope for discretion by tax officials is reduced.

### Scope and structure of the paper
- The paper presents an analytical framework on key legal design features necessary for good governance of the tax system, focusing on legal arrangements to support the operation of the tax administration and its interactions with taxpayers.
- It does not address broader tax policy, institutional and operational issues.
- The paper is structured as follows: Section I outlines broader tax governance considerations and presents a set of core governance principles in tax administration and tax procedure. Sections II and III apply these core principles to derive key legal principles that strengthen governance arrangements for tax administration (section II) and tax procedure (section III). Finally, section VI offers some

*Source: wpiea2025017-print-pdf - Introduction*

### conclusions.

### Conclusions

### I. Tax Governance: Concept and Core Principles
- Tax governance is defined as "a coherent set of rules and institutions that comprehensively govern the tax system." It:
  - Includes but goes beyond the institutional governance of the tax administration and cuts across tax policy and legal design, the lawmaking process, tax procedure, oversight structures, the judiciary, the international tax framework, and taxpayers.
  - Must ensure respect of fundamental legal principles, most notably legal certainty, equity and fairness, and proportionality.
  - May require that the judiciary be empowered to address governance shortcomings in the design or administration of tax laws based on general principles of administrative or constitutional law to ensure legal certainty and adherence to the rule of law.
- Well-functioning tax systems anchor governance arrangements in law and promote the rule of law through proper governance structures, which can:
  - Promote improvements in tax policy and administration.
  - Strengthen state accountability and responsiveness to citizens.
  - Support efficient and effective revenue collection to implement government policies.
- Tax law frameworks can be divided into three interrelated types of rules:
  - Substantive tax rules (what is being taxed).
  - Procedural (formal) tax rules (how taxes are collected).
  - Institutional rules and arrangements (who administers taxes).
- Overarching legal design principles and considerations that apply across these rule types to strengthen governance arrangements:
  - Reducing uncertainty, through:
    - Identifying obsolete provisions and arrangements.
    - Untangling dysfunctional tax provisions.
    - Introducing comprehensive, clear and simple rules in substantive and procedural tax legislation.
    - Reducing bureaucracy through clear and transparent procedures.
  - Aiming for structure, through:
    - Consolidating fragmented tax provisions under tax codes.
    - Legislating for changes to tax law on a periodic basis using specific tax bills rather than making tax changes via other non-tax specific legislation.
    - Developing an impact assessment framework, including implementation considerations, revenue impact and ex post evaluation.
  - Ensuring transparent and effective implementation of tax rules and tax reforms, through:
    - Access to justice and enforcement of relevant court decisions.
    - Sequenced application of reforms, based on an assessment of the administrative capacity to implement them.
  - Getting ‘buy in’: Ensuring a fair and inclusive discussion on proposed tax policies and measures, engaging all key stakeholders through a formal and inclusive public consultation process.
  - Administering taxes ‘well’, by:
    - Strengthening tax administration institutional arrangements that provide for sufficient autonomy balanced with transparency and accountability mechanisms.
    - Ensuring efficient and effective interaction with the tax policy function.
    - Utilizing secondary instruments (e.g., regulations) or administrative actions (e.g., guidance) to enhance flexibility and provide for clear implementation arrangements.
  - Ensuring taxpayer fairness, through:
    - Transparent and well governed implementation of tax laws including in an international context.
    - Enhancing effectiveness of dispute prevention and dispute resolution mechanisms.
    - Establishing strong confidentiality and data governance to ensure data reliability and integrity.
    - Minimizing discretion in the application of tax laws.
    - Addressing equality and equity concerns in taxation (for example, gender discriminatory policies).

### II. Governance in Tax Administration and Tax Procedure: Core Principles
- There is no "one size fits all" institutional model for tax administration; country specificities matter (policy considerations, socioeconomic circumstances, degree of administrative (in)efficiency, disparities across national legal systems).
- Guiding principles for the design and operation of tax administrations (reflected in tax procedure legal frameworks) are grouped under:
  - (a) Transparency and accountability;
  - (b) Sound decision-making structures;
  - (c) Fairness; and
  - (d) Effectiveness and efficiency.
- Interactions and synergies:
  - Fairness, effectiveness and efficiency are communicated to taxpayers through procedural safeguards and inform internal arrangements (e.g., staff integrity frameworks) and mission statements.
  - Transparency and accountability, and sound decision-making structures inform tax administration frameworks and significantly impact tax procedures, including how discretionary powers are applied.

### II. Governance Arrangements in Tax Administration
- Tax administrations:
  - Are complex organizations central to supporting government fiscal policies.
  - Play critical macroeconomic and developmental roles.
  - Often are large organizations with specialized workforces and extensive office networks interacting with taxpayers and stakeholders.
  - Enforce a wide range of legislation and may have intrusive legal powers.
  - Rely on core business processes and increasingly digital systems capable of holding and analyzing vast amounts of confidential or sensitive information.
  - Are monitored against performance targets, including revenue collection, and typically have a policy advisory role.
  - Must be directly accountable to government and/or parliament and to taxpayers.
- Common governance challenges:
  - Organizational structures that are too complex and non-transparent.
  - High compliance and administration costs.
  - Wide discretionary powers that may lead to real or perceived corrupt behavior and poor service delivery standards, jeopardizing taxpayer compliance and public trust.
  - Misunderstanding or misuse of administrative autonomy in the absence of robust accountability frameworks.
- Legal frameworks for tax administrations vary:
  - Tax Administration and Procedures Act (TAPA) with dedicated tax administration section.
  - Stand-alone Tax Administration Act (TAA) for (semi-autonomous) revenue authorities.
  - Ministerial department frameworks based on secondary law or subsidiary instruments (e.g., ministerial decree).
- Regardless of institutional arrangements, the following core governance features need a solid basis in law.

### A. Core Governance Principles for Tax Administration — Accountability and Transparency
- The legal framework should provide robust accountability and transparency arrangements, aligned with the broader legal, political and socioeconomic context.
- Accountability is required at both the organizational level (under the head's ultimate responsibility) and at the staff level.
- Key features of a comprehensive accountability framework include:
  - Robust internal and external audit mechanisms, such as a separate internal audit function that reports directly and regularly to the Head, and strong oversight provided by external authorities or bodies, such as the Auditor-General or Court of Auditors.
  - Clear rules for oversight by, and accountability to, a relevant minister or executive authority (finance, treasury, or revenue), and/or parliament, including through periodical reporting (on revenue data or other performance metrics).
  - Clear rules for the use of and control over financial resources, including transparency and reporting mechanisms.
  - A clear framework for integrity of staff conduct, supported by systems and procedures, including effective criminal enforcement for fraud and corruption.

*Source: wpiea2025017-print-pdf - conclusions*

### Box 1. Basic Design Elements of a Staff Integrity Framework

### Box 1. Basic Design Elements of a Staff Integrity Framework

### Core integrity design elements
- Proper internal and external audit and reporting requirements. 27 These should be complemented by a sound delegation framework and operational governance arrangements, such as the application of the ‘two pairs of eyes’ principle.
- Merit-based recruitment and employment frameworks based on clearly defined competencies, competitively remunerated—including good work benefits—to reduce temptation for officials to accept bribes, complemented by mandatory ethics training and a code of conduct for tax officials. 28
- Corporate governance principles applicable to staff and management organs, for example fit and proper assessments for the Head (and, where relevant, members of the Board) and establishment of ethics and social responsibility committees, in addition to internal audit committees. 29
- Comprehensive staff disciplinary framework (including criminal liabilities) to address breaches of tax officials’ duties, including breaches of confidentiality, abuse of powers and corrupt practices, consistently enforced including through criminal prosecution and punishment upon conviction, where relevant.
- Mandatory disclosure requirements to detect and address conflicts of interest situations.
- Appropriately calibrated, regularly updated and publicly accessible asset declarations for elected officials, or political appointees and senior staff, including for gifts. 30
- Whistleblower framework to enable staff to report wrongdoing in the workplace, with appropriate safeguards against reprisals.

*Source: Authors’ compilation*

### Transparency (organizational and taxpayer matters)
- Regular public reporting on the operations and finances of the tax administration, including assessments against performance objectives.
- Publication of (anonymized) private tax rulings, 32 in addition to their exchange with relevant competent authorities based on exchange of information (EOI) networks, 33 and publication of administrative appeal decisions (in anonymized form).
- When a system of individual tax waivers is in place, reduced discretion, transparent procedures for granting those waivers and regular publication of waivers granted (on an anonymized basis).
- Note: Another area where greater transparency could be considered is transparency in collection seen in some Nordic countries. Such an approach however is not widely adopted and may pose privacy concerns. 31

### Sound decision-making structures
- Require a clear and transparent legal framework to underpin responsibilities and procedures, including clear rules for delegation of powers complemented by appropriate internal checks and balances. 34
- Functional segregation of duties and responsibilities (for example, the internal administrative review or objection function should be totally separate from the audit function to ensure independence of the review process).
- Escalation system for more complex decisions.
- A clear statutory basis for delegation of powers is necessary; delegation mechanisms may be set out in primary legislation or via a broad delegation to the head of the tax administration with subsidiary legislation or administrative rules for sub-delegation.
- Clear conditions and safeguards on application of discretionary powers to reduce corruption vulnerabilities and risks; safeguards include:
  - clear rules and guidance on when and how discretion will be exercised; 35
  - internal systems to enable cross-checking of discretionary decisions, including through regular audits, and public reporting of cases where discretionary power is exercised. 36
- Common areas where discretionary powers are explicitly provided in tax legislation or exercised in absence of clear legal framework include: Waivers; Instalments; Interest and penalties; Filing and payment extensions; Collection and recovery actions; Tax law interpretations.

### B. Legal design considerations — institutional design and mandate
- Institutional model alternatives:
  - tax administrations operating as a directorate of the responsible ministry;
  - tax administrations as separate government department within a responsible ministry (typically the Ministry of Finance (MoF) or Treasury);
  - semi-autonomous revenue authorities (SARAs), established as a structure or body that is separate from any ministry or government department.
- Four broad institutional design variations identified: 38
  - A single directorate/department within the MoF; 39
  - Multiple directorates or units within the MoF;
  - A unified semi-autonomous body, where tax administration and support functions are the responsibility of a Commissioner or Director General who reports to a government minister (typically the MoF);
  - A unified semi-autonomous body with a board, where tax administration and support functions are the responsibility of a Commissioner or Director General who reports to an oversight body/board of management that may include external members. The management board may either be decision-making or advisory. 40
- Institutional autonomy effects:
  - Enables management of day-to-day operations free of political interference and other undue influence.
  - Offers flexibility in organization, management and resources, potentially improving effectiveness and efficiency.
  - Under the ministerial directorate model, the tax administration falls under direct control of the MoF and centralized services are shared.
  - Under the separate government department model, staff report to a single head with powers specified in law and maybe subject to a performance agreement with the MoF.
  - SARAs are generally operationally independent organizations, reducing opportunities for unwarranted political influence, 41 and allowing—but not requiring—greater operational independence from standard civil service rules. 42
- Legal basis and foundational instruments are particularly important for SARAs (e.g., legal personality, judicial standing, ability to own property).

- Mandate:
  - Collect the right amount of tax at the right time in accordance with the rule of law, using resources as efficiently as possible with the least possible burden to taxpayers—regardless of institutional model.
  - May include tax and customs, social security contributions, other public revenue, and in some countries criminal tax investigations and money laundering investigations. 45
  - May have a policy advisory role that the legal framework may not explicitly provide for or recognize.
  - Mandate is often not explicitly expressed in law but can be derived from functions and powers; for SARAs, an explicit mandate provision can usually be found in their constituting act.
  - Making the mandate explicit is a useful tool to guide accountability.

### Autonomy — functional, operational, and financial
- General: tax administrations need an adequate degree of autonomy; degree varies across country contexts and legal frameworks. 47 48 49
- Functional autonomy key legal design considerations:
  - (i) a robust delegation of powers system;
  - (ii) decision making on a person’s tax affairs independent of political direction;
  - (iii) robust information and enforcement powers, including the power to handle administrative appeals and complaints and to impose penalties and other sanctions according to the law; 50
  - (iv) personal autonomy arrangements, for example, a framework for the protection of staff from personal liability (except in the cases of willful default or gross negligence); 51
  - (v) the authority to provide tax law interpretations, both in the form of public and private rulings, of how tax laws will be interpreted, subject to review by judicial bodies. 52
- Operational autonomy features:
  - ability to administer its own in-house IT systems;
  - discretion to determine the internal organizational structure and set administration performance standards;
  - ability to formulate strategic and business plans;
  - a degree of autonomy to HR policies (recruitment, career development and remuneration, including incentives).
- Financial autonomy features:
  - sufficient flexibility to allocate resources within the budget;
  - budget security (for instance, through a “safety net” on a yearly allocated budget);
  - operational flexibility in spending, which may be supported by its own financial services office (usually in the case of SARAs).
  - Financial autonomy supports ability to provide adequate and appropriate wages and other employment conditions to attract and retain qualified staff and reduce likelihood of corrupt behavior; must be supported by a framework of adequate public financial management rules (for instance, provision of budget estimates, performance-based incentives, etc.). 53

### Interaction with other legal frameworks
- Effectiveness depends on close interaction with other relevant tax and non-tax legal frameworks. Indicative areas to review:
  - Constitutional law: ensure consistency of legal form and status within broader public sector framework.
  - Tax procedures law: ensure sufficient powers supported by clear and transparent framework for delegation of powers.
  - Public procurement law: ensure appropriate framework for procurement of resources (for instance, IT infrastructure).
  - Fiscal law: ensure consistency of the tax administration’s budget and fiscal oversight.
  - Civil service law: ensure consistency of human resources policies.
  - Privacy law: ensure taxpayer information is appropriately safeguarded.
  - General administrative law: ensure operational independence is supported (for instance, power of sub-delegation).
  - Criminal law: support accountability of the tax administration and its leadership, and prevent abuse of power and misuse of tax confidentiality.
- Figure 3 summarized key considerations to ensure successful integration of the tax administration framework. 54

### C. Additional considerations in Semi-Autonomous Revenue Authorities (SARAs)
- SARAs increasingly take over most tax administration functions from traditional line departments within the MoF; the greater degree of autonomy is believed to improve level and efficiency of revenue collection in a jurisdiction. 55
- SARAs commonly enabled to set their own operational policies to ensure freedom from political interference; SARA officials are public servants but SARAs often have greater flexibility than general public service in HR policies and procurement procedures.
- SARAs are almost always accountable to a ministry and/or the parliament for delivery against statutory mandate; in some cases fully autonomous revenue authorities enjoy complete independence from public service rules while still under government control and robust oversight. 57
- When establishing SARAs, a stand-alone legal framework (Tax Administration Act) is often created. Key design considerations include:
  - Institutional autonomy typically achieved by establishing the SARA as a separate entity from the MoF.
  - Legal character: SARAs may be awarded separate legal personality depending on the legal system; related issues include judicial standing (the right to sue and be sued), representation to enter into contractual obligations, procurement, and ability to own and dispose of property. 58

*Source: Authors’ compilation*

### Box 2. Examples of Provisions for the Awarding of Legal Personality

### Box 2. Examples of Provisions for the Awarding of Legal Personality

### Examples of statutory language establishing legal personality
- Inland Revenue Authority of Singapore Act — Article 3 — Establishment and incorporation of Inland Revenue Authority of Singapore:
  - "There is hereby established a body to be known as the Inland Revenue Authority of Singapore which shall be a body corporate with perpetual succession and a common seal and shall, by that name, be capable of —(a) suing and being sued; (b) acquiring, owning, holding and developing or disposing of property, both movable and immovable; and (c) doing and suffering such other acts or things as bodies corporate may lawfully do and suffer."
- Liberia Revenue Authority Act — Section 4 — Establishment of the Authority:
  - "(1) There is established the Liberia Revenue Authority as a body corporate with perpetual existence and a common seal. It may sue and be sued in its own name, and subject to the provisions of this Act perform such acts as bodies corporate may lawfully perform; ..."
  - "(4) The Authority may, for the performance of its functions, acquire and hold movable and immovable property and may enter into contracts or any other transaction that a state-owned enterprise may enter into."

### Mandate and role in tax policy
- SARAs generally have a mandate explicitly prescribed in legislation, through standalone provisions or founding-law provisions on core functions and powers (and sometimes objectives).
- Interaction with the Tax Policy Function:
  - Ultimate responsibility for tax policymaking appropriately rests with the MoF or Treasury.
  - Tax administrations typically play at least a supportive role in tax policy in recognition of their technical expertise.61
  - For SARAs—created to be independent from the MoF or Treasury—it is common for their role in tax policymaking to be more explicitly defined in law.
  - Aggregate taxpayer data necessary for policy analysis and revenue is held by the tax administration and must be provided to the relevant tax policy function in the MoF.
  - Tax administrations can identify trends and issues relevant for policy makers; the administrative feasibility of policy options is best understood by the tax administration and should inform policy decisions.
  - Recommendation: In the context of a newly established SARA, formalize the collaborative relationship with the tax policy function in the legal framework.62

### Greece — statutory framework for MoF–IAPR relations (Box 3)
- Context: Greek tax administration transitioned from a structure within the MoF to a SARA, established as an independent administrative authority outside the MoF without legal personality; reform effective as of January 1, 2017 via a separate tax administration act.63
- Main elements prescribed in founding legislation (Article 5 of Greek Law 4389/2016):64
  - The IAPR is not subject to hierarchical control or administrative supervision by the MoF, government bodies or other administrative authorities or any other public or private organization.
  - The MoF is awarded the power to submit strategic proposals and issue strategic directives to the IAPR for implementing government policies, though they may not extend to organizational or operational aspects of the IAPR, nor on staff matters.
  - The IAPR must provide the MoF with periodical updates on activities and performance and must provide aggregate data needed for tax and customs policy purposes; the MoF may not submit a request for information for specific cases.
  - The IAPR may propose to the MoF legislative provisions on matters within its remit.
  - The MoF must notify legislative provisions on matters pertaining to tax and customs policy and the implementation of tax and customs policy before submitting them to Parliament; the IAPR may provide a non-binding opinion within a prescribed deadline.65
  - The IAPR must notify regulatory decisions and interpretative guidelines (circulars) to the minister, who may provide a non-binding opinion within a prescribed deadline.

### Governance organs and internal structures
- Legislative clarity is needed on governance organs and structure of SARAs, including personal autonomy arrangements and protection from personal liability.
- Head of the SARA — typical features to specify in law:
  - Selection and appointment: Selected through a transparent process (run by the Board, if there is a Board structure), and appointed by Parliament, Government, Minister for Finance or President.
  - Tenure: Fixed term, with the possibility of a one-time renewal for another fixed term.
  - Removal: Clear stipulation of circumstances (for instance, acts of fraud and gross negligence, or underperformance as stipulated in the performance contract, where applicable)66 and, if there is a Board structure, requisite votes from Board members needed for removal.
  - Integrity: Minimum professional qualifications and/or sufficient relevant experience in tax or wider public administration, and a clear framework of conflicts of interest for appointment and possibly a cooling-off period after end of term in line with rules pertaining to other senior public officials.
  - Functions and Powers: Clear framework of functions and powers, authority to delegate powers, and explicit prescription in law of any regulatory powers awarded to the Head (for instance, power to issue secondary legislation on procedural matters).67
- Management Board — features and rationale:
  - Purpose: Enhanced governance feature to ensure internal checks and balances, protection from political interference in operational decision making, oversight and strategic guidance (or decision making) on administrative policies such as human resources, strategic and operational plans, performance management, organizational changes and budget execution.68
  - Basic features:
    - Composition: Number of ex-officio members from the public sector (for instance, MoF and ministers from other key ministries) and possibly ex officio representatives from the private sector.69
    - Selection and appointment: Power to select non ex-officio members should be vested in an independent committee and approved by the President/Parliament or the MoF.
    - Tenure: Fixed term with the possibility of a one-time renewal for another fixed term or a rolling tenure.70
    - Functions and Powers: Clear framework defining the Board’s role in relation to the Head, and oversight and decision making tasks.
  - Note: The Management Board should not exercise operational decision making in respect of a person’s tax affairs.69

### Institutional oversight
- Clear institutional oversight arrangements are key for SARAs because they are not subject to standard oversight mechanisms of a ministry structure.71
- Typical features:
  - Direct relationship with the government through the ministry with overall responsibility for revenue (typically the MoF).72
  - The SARA is generally accountable to the MoF for effectively administering the revenue laws and doing so within the rules and authorities that govern tax administration operations, while ensuring no political involvement in specific cases nor day-to-day management operations.
  - Oversight arrangements must be explicitly prescribed in law (for example, the oversight role of the MoF).73
  - Complementary oversight: supreme audit institutions (e.g., Auditor General), parliamentary oversight (submission of annual corporate plan, budget and annual report to Parliament, appearance of the Head in public parliamentary hearings), taxpayer ombudsperson function, and management board oversight where applicable.
  - Annex III (referenced) presents an illustrative example of institutional oversight and accountability provisions.

### Enhanced accountability and transparency for autonomous SARAs
- Enhanced autonomy requires enhanced accountability and transparency arrangements. Basic design features include:
  - KPIs to be reported on a regular basis to the MoF and made publicly available.
  - Depositions of the Management Board and/or the head of the Authority before the Parliament.
  - Submission of the annual report and strategic and business plans to the MoF and the Parliament.
  - Submission of periodical reports to the MoF and special reports to the MoF and the Parliament on key issues.
  - Publication of a strategic plan, an annual business plan, monthly progress reports and monthly reports on expenditure as part of budget execution.

### Core governance principles in tax procedure (summary)
- Fairness:
  - Policies based on equity and neutrality should be complemented by a legal framework providing taxpayer safeguards to ensure fair treatment in all stages of tax procedure.74,75
  - Key considerations: structured interaction (e.g., self-assessment backed by audit), use of IT for taxpayer services, minimizing discretionary interpretation by tax officers, clearly prescribed criteria for discretionary powers.76,77
- Principle of sound administration:
  - Right to have affairs handled impartially, fairly and within a reasonable time; includes right to be heard, access to file, protection of legitimate expectations, obligation to give reasons for decisions.78
  - In tax context: adequate reasoning and right to administrative review of decisions, segregation of powers (objections reviewed by officials not responsible for the original decision), appointing a taxpayer ombudsperson, framework for protection of basic taxpayer rights.79,80,81
- Effectiveness and efficiency:
  - Balance effective tax collection with efficient taxpayer services through clarity, simplicity, consistency, responsiveness.82
  - Design considerations: clear/simple language in legislation and administrative decisions, simple and reliable administrative/procedural laws applying equally across main tax types, user-friendly guidelines and consistent interpretations, clear timelines for responding to taxpayer requests and remedies for missed deadlines (e.g., automatic denial/granting, interest on late refunds).83,84

### Legal design considerations for tax procedure
- Two main legislative approaches:
  - Each substantive tax law contains a complete set of administrative provisions specific to that tax.
  - A law or laws on tax administration and procedure set out common administrative procedures that apply to all or most substantive tax laws, leaving specific provisions to substantive tax laws.85
- Recommendation: Legal design considerations should inform development of good governance arrangements in tax procedure legislation and be used in diagnostic exercises (see Box 4).

*Source: Box 2. Examples of Provisions for the Awarding of Legal Personality, wpiea2025017-print-pdf*

### Box 4. Steps for Setting Up a Governance Framework in Tax Procedures Legislation

### Box 4. Steps for Setting Up a Governance Framework in Tax Procedures Legislation

### Assessment and legal-design questions
- Undertake an assessment of existing arrangements and identification of shortcomings, often as part of a wider governance ‘diagnostic’ exercise on fiscal or general public law structures and institutions.
- Legal design should address the following questions:
  - The What: What are the legal features that need to be introduced? What are the structures and arrangements that need to be adopted?
  - The How: What legal instruments are going to be used? Can primary law instruments be combined with secondary law instruments? Can statutory law instruments be combined with soft law instruments? What are the necessary implementation arrangements? Are the arrangements designed as part of a wider tax reform?
  - The Where: Where are the legal provisions going to be introduced? Are they going to amend existing substantive and/or procedural provisions or is there a need for new, stand-alone frameworks?
  - The When: Are the necessary arrangements going to be introduced “all-at-once” in the context of a broad tax law reform or in a more sequenced manner?

### Benefits of introducing a separate Tax Procedures Law (TPL)
- The TPL sets out the common administrative provisions that apply to the main substantive tax laws and provides a firm foundation for modernizing tax administration.
- Consolidation and modernization through a TPL:
  - Strengthens tax administration management.
  - Improves operational capacity and efficiency of the tax administration.
  - Supports domestic revenue mobilization.
  - Enhances governance in administering the tax system.
- Removing tax administration provisions from substantive tax laws:
  - Reduces complexity and length of substantive tax laws (for example income tax and value added tax acts).
  - Focuses substantive tax laws on defining the tax base.
- A unified procedural framework:
  - Promotes harmonization of tax procedure practices within the tax administration and between tax types.
  - Enables modern tax administration practices where tax administration is organized on a functional basis (for example, unified administration of tax audit and collection across taxes).
  - Reduces duplication and poorly coordinated actions that burden taxpayers and reduce efficiency.
- Tax certainty and accessibility:
  - A unified TPL enhances tax certainty and allows tax officers to transfer administration knowledge between taxes.
  - Decreases frictions between tax administration provisions in different tax laws.
  - Provides easy access to the tax procedure framework for taxpayers and tax administrators, promoting voluntary compliance.
  - Example: taxpayers (including foreign investors) can more easily determine processes to challenge assessments or the books and records required to be kept.
- Facilitation of future legislative reform:
  - TPLs consolidate tax administration provisions that can be generalized to apply to all types of taxes, so changes to the TPL can affect multiple substantive tax laws.
- Transparency of taxpayer rights and obligations:
  - TPLs can ensure taxpayer confidentiality, mechanisms to confirm liabilities are satisfied, processes to support taxpayers in hardship, clear appeal rights, and mechanisms for obtaining advice on transactions.
  - Facilitates judicial handling of tax disputes by focusing disputes on substantive rather than procedural issues.
- Temporal organization and readability:
  - Organizing the TPL to reflect the tax administration life cycle (from fundamental obligations and powers, to advice, registration, record keeping, etc.) enables filling gaps and facilitates readability.

### Key design considerations for a stand-alone TPL
- Two main design areas:
  - Enhancing governance arrangements in tax procedure (covering stages and aspects of tax procedure and the tax administration as an institution).
  - Making the new framework functional and ensuring smooth integration into the tax law system and broader domestic legal framework, including fit with administrative law and possible regional harmonization needs.

### Necessary steps for the successful introduction of a Tax Procedures Law (Box 5)
- Undertake a careful review of substantive laws to identify necessary redactions upon introduction of the TPL:
  - Identify overlap between the TPL and substantive tax laws.
  - Redact overlapping provisions from substantive tax laws while ensuring unique functions within specific substantive laws are retained where necessary.
- Ensure alignment with related laws:
  - Verify interaction with civil procedure rules, company law, and court procedure, and ensure effective interaction with the TPL.
- Ensure any cross-references are adjusted:
  - Many tax laws include cross-references to other tax laws; these must be revised to refer to the TPL.
- Consolidate pieces of substantive tax legislation:
  - Use the redaction exercise as an opportunity to streamline substantive tax legislation and publish revised consolidations of each substantive tax law.
- Coming into force:
  - Introduce a basic framework of transitional provisions and address specific transitional issues (including deferred application of certain provisions) to ensure effective transition to the TPL.
- Educate tax administrators and taxpayers on the new law:
  - Educate tax officers and taxpayers (including intermediaries) about the new law and its enforcement; public awareness may begin with presenting the draft law for public consultation.
- Implementation:
  - Identify key areas for which regulations and/or guidelines are required to support implementation of the TPL.

### Ensuring adequate taxpayer safeguards through governance arrangements in tax procedure
- Rationale:
  - Tax administrations possess intrusive powers that can impact fundamental taxpayers’ rights; legal safeguards are required to balance those powers and provide remedies where powers are misused.
  - Digital transformation, data mining, and machine learning increase the need for transparency and accountability in processes and procedures.
- Examples of taxpayer rights and safeguards:
  - Well-functioning objections and appeals processes.
  - Efficient practice for obtaining advance certainty through rulings.
  - Accessible and efficient taxpayer services.
  - Taxpayer charters or bills of rights that group taxpayer rights and obligations in a single, thematic, principle-based document; these may be legislated or administrative statements and may include detailed service standards.
  - Establishment of a taxpayer ombudsperson function to assist taxpayers separate from normal administrative and judicial proceedings.
- Good practice in legal design:
  - Organize legal provisions guaranteeing procedural protections to taxpayers in a separate section of the tax administration law or include them in the TPL organized on temporal or functional lines.
  - Main areas to cover: (a) registration and taxpayer identification; (b) tax law interpretations; (c) tax administration information powers and confidentiality; (d) communications and notices; (e) right to information and access to file; (f) filing and tax assessments; (g) verification actions (tax audits and investigations); (h) refunds; (i) penalties and interest; (j) collection and enforcement; and (k) dispute resolution and judicial recourse.
- Key tax administration powers and corresponding fundamental taxpayer rights (Box 6)
  - Compulsory registration/de-registration — Free exercise of profession – right of association
  - Power to enter into premises — Right to privacy
  - Departure prohibition orders — Freedom of movement
  - Information powers — Right to confidentiality
  - Enforced collection actions — Right to property
  - Default and protective assessments — Right to be heard
  - Discretionary powers — Right to equal treatment
  - Tax audits — Right to due process
  - Reversal of the burden of proof — Presumption of innocence, right to due process
  - Objections and appeals — Right to review and (timely) remedy
  - Tax law interpretation and application — Right to good administration
  - “Naming and shaming” — Right to privacy, right to due process
- Multi-layered legal framework:
  - Foundational principles in constitutions, general principles of law and administration, tax administration and procedure laws, and general administrative procedure legislation.
  - International conventions (for example the EU Charter of Fundamental Rights) also shape taxpayer rights.
  - Statutory protections for key functions and powers of the tax administration should be in primary legislation covering main stages and aspects of tax procedure; depending on legal tradition, some protections may be in secondary legislation (regulations, ministerial decrees).
- Importance of a comprehensive legal framework to promote uniform application of taxpayer protections as a tax certainty tool.

### Conclusions (as presented)
- Certain core governance principles are foundational for building robust tax administrations operating through fair and effective tax procedure arrangements.
- The paper develops an analytical framework to derive core legal principles for sound governance arrangements in tax administration and tax procedure to inform tax law design.
- Legal frameworks are crucial but insufficient alone; effective implementation requires mechanisms outside tax institutions (for example SAIs, law enforcement, and the courts).
- Tax policy function should work closely with the tax administration to implement tax laws transparently and effectively and to ensure balanced implementation mechanisms.
- Attention should be given to enhanced governance structures for SARAs in light of their greater institutional autonomy.
- Governance arrangements in tax procedure assist in achieving balance; policies based on equity and neutrality should be complemented by a sound legal framework providing adequate taxpayer safeguards to ensure fair treatment, respect for fundamental rights, and trust that promotes compliance.

*Source: wpiea2025017-print-pdf - Box 4. Steps for Setting Up a Governance Framework in Tax Procedures Legislation*

### Annex I. Ensuring Adequate Taxpayer

### Annex I. Ensuring Adequate Taxpayer Safeguards through Governance Arrangements in Tax Procedure; a Checklist

### Registration and taxpayer identification
- Ensure that registration requirements and processing timelines are equal for all taxpayers, through clear deadlines for the tax administration to respond to requests/queries.
- Provide a clear framework for taxpayers’ obligations to notify changes in registry, through explicit deadlines.
- Include a general requirement that Tax Identification Numbers (TINs) be used on all communications, including the filing of tax returns.
- Lay out clearly in legislation a framework for registration, liabilities and indemnities of withholding agents.
- Ensure that compulsory registration/de-registration powers are set out clearly in the law and are complemented by appropriate safeguards for taxpayers, for example an obligation to justify compulsory de-registration.
- Generally, ensure that whenever a deadline is prescribed appropriate consequences are specified in case the deadline is not met by either the tax administration or the taxpayer.

### Tax law interpretations
- Provide a framework for timely and transparent tax law interpretations, through regularly updated and consolidated circulars or guidance.
- Ensure that changes in tax law interpretations that are to the detriment of taxpayers will not apply retroactively.
- Establish an advance tax rulings regime with specific rules governing its operation and provide for the publication of redacted versions of private advance rulings issued.

### Tax administration information powers and confidentiality
- Provide that access to confidential information by tax officials is on a need-to-know basis and subject to strict confidentiality obligations, with exceptions to confidentiality clearly stipulated in the law101 and adequate penalties and liabilities for breaches.
- Establish a clear statutory framework for collecting information from third parties, including (i) specifying the initial categories of third parties and reporting type (e.g., content, frequency and format) in the law;102 and (ii) ensuring that, legally, persons required to report specific information are also legally required to collect that information in the first place.
- Clearly define legal authority to request and receive information, support information sharing and administrative assistance with other government agencies103 and foreign governments, including robust procedural arrangements and confidentiality requirements.
- Ensure confidentiality of taxpayer information by adopting provisions which legally obligate the tax administration to keep that information confidential unless disclosure is needed for the administration of the tax laws or specifically authorized by other legislation, complemented with serious penalties for breaches of confidentiality requirements.
- Apply the principle of proportionality in the collection and use of data, for example avoiding onerous information reporting requirements or the extra administrative burden on taxpayers when the requested data is already available to the tax administration from third parties.
- Provide taxpayers and third parties the option to challenge the exercise of any excessive information-gathering powers by way of administrative or judicial review.

### Communications and notices
- Put in place a comprehensive set of procedural protections for taxpayers which support the commitment of the tax authorities to taxpayer service, including developing standards and timelines relating to taxpayer communications and notices.
- Those provisions should, at a minimum: (i) set out when notice is considered received by a taxpayer (e.g., rules of service); (ii) allow the tax authorities to produce forms and notices and to issue general guidelines and interpretations to the public; (iii) address when communication can be made electronically; and (iv) indicate the language of communication with the tax authority.
- Provide reasonable notice in writing of a requirement for a person—whether a taxpayer, withholding agent or other party—to furnish information about a taxpayer or to appear at a time and place identified in the notice for examination or to produce documents.

### Right to information – Access to file
- Include provisions that provide for taxpayer rights to information, such as that taxpayers may request information about the status of their request/complaint/outstanding tax liabilities or generally access their administrative file, upon their request.104
- Provide timelines for the tax administration to grant access to file.
- Introduce an obligation to notify taxpayers on data collection and use.

### Filing and tax assessments
- Establish a clear framework for e-filing and an obligation to provide proof of filing and/or a copy of any tax or information return filed by the taxpayer.
- Set out clear eligibility criteria for a simplified filing procedure, if applicable.
- Allow taxpayers the possibility to file amending tax returns to correct submitted tax returns where they discover errors made, including the possibility of amending prepopulated returns.
- Establish a thorough framework on the different types of assessments, the conditions under which they may arise and the procedures through which they may be imposed.
- Notify the taxpayer in case of reassessment, especially if a result of cross-matching information available to the tax administration from third parties and ensure the right to be heard.
- Provide a clear framework of criteria for the extension of filing deadlines, minimizing discretion.
- Prescribe comprehensively in the law situations in which a prescription period is suspended or extended, including in case of fraud or to give effect to a decision of the administrative review unit or a court on a review or appeal that commenced before but was finalized after the expiry of the prescription period.

### Verification actions: tax audits and investigations
- Ensure the taxpayer’s right to be heard during the audit procedure, by providing reasonable timelines for the taxpayers to present their objections.
- Clarify the burden of proof framework, in accordance with general legal principles.
- Offer protection against legal presumptions, by establishing a framework for rebuttable presumptions.
- Ensure that all relevant minimum bookkeeping requirements are provided in legislation, including: (i) a definition of taxpayers required to keep books and records; (ii) a framework for keeping them in an electronic form; and (iii) the period of time for which they need to be preserved at the disposal of the tax administration (i.e., within the time limits for reassessment).
- Require auditors, when they assess additional tax, to prepare a report (and provide it to the taxpayer) that specifies in detail the reasons for the re-assessment and documents the taxpayers’ response to these reasons.
- Provide that powers encroaching on personal and property rights (such as entry into premises) are exercised through clear due process safeguards.105
- Establish a framework for data integrity, including oversight arrangements behind automated decision making (e.g., risk assessment criteria) and an accountability mechanism for wrong use of data and/or algorithms.
- Ensure that powers under a general anti-avoidance rule are exercised by tax officials of sufficient seniority.
- Place appropriate time limitations and clear conditions on the ability of tax authorities to reexamine a tax return and issue a reassessment.
- Set out clear rules on tax audits process, such as, (i) risk assessment criteria; (ii) notification on the initiation of a tax audit; (iii) a framework for the conduct of on-site audits; (iv) taxpayer representation during a tax audit; and (v reasonable timeframes for a tax audit.106

### Refunds
- Provide for clear and proportionate time limits for tax refunds based on objective and transparent criteria.
- Establish a framework for the payment of interest on behalf of the tax administration in case of late refunds and overpayments.

### Penalties and interest
- Apply a penalty system commensurate with the gravity of the tax violations.
- Set up a system of non-punitive interest, specifying in the law (i) precisely how interest is to be calculated e.g., on daily or monthly balances;107 and (ii) providing for the possibility to be adjusted periodically to reflect market developments.
- Issue internal guidance for the application of various penalties and make this information publicly available.
- Minimize discretion in the authority to apply and waive penalties and interest and issue criteria to explain how this discretion will be used.
- Include a provision which sets out the order of the application of payments in circumstances where a tax debtor makes a payment that is less than the total amount of tax, penalty and interest due.108
- Align the time period for imposing penalties to the different time periods for making assessments and set out a clear procedure for their imposition, including a provision requiring a notice of imposition of a penalty.

### Collection and enforcement
- Set out in legislation the tax administration’s collection enforcement powers and the general rules for their application.
- Provide for procedural protections to taxpayers (including third party debtors) by offering appropriate notice and appeal recourse.
- Provide legal safeguards against improper exercise of powers, e.g. require that at every escalation point in the collections process the taxpayer must be notified (in writing) and given the opportunity to pay prior to the implementation of harsher measures.
- and ensure the legislation includes due process safeguards such as requiring advance judicial clearance or judicial approval shortly after the tax authorities enter residential premises or issue a departure prohibition order.
- Extend third party liability to company managers and controlling members under clearly prescribed conditions.
- Provide for active internal oversight, especially where the collections action may have significant consequences (such as closing down a business or seizing /selling assets).
- Ensure compatibility between the administrative appeals process and any emergency judicial recourse against enforced collection action.
- Include an offsetting provision to enable any amounts owed to a tax debtor by the tax authorities to be applied or offset against the taxpayer’s debt.
- Offer the possibility of settling tax debt in installments, while providing for clear and transparent eligibility and access criteria, minimizing discretion.
- Set up a framework to ensure that recovery powers do not lead to undue hardship for taxpayers, such as: (i) a minimum tax debt threshold before an act of distraint is taken; (ii) an ability for taxpayers to make an urgent application to the court for review of the distraint order; (iii) Ensuring the taxpayer’s minimum vitale, by providing that a minimum amount is retained in their bank account; (iv) and/or the exclusion of certain properties from a distraint action (for example, basic household goods and assets that are jointly owned with another person).

### Dispute resolution and judicial recourse
- Unify the dispute resolution process for all taxes.
- Create an independent administrative review function within the tax administration but separate from the audit function, providing for a framework of impartiality of tax officers and for segregation of powers.
- Make a judicial appeal dependent on a prior administrative appeal decision and allow judicial appeal where there is a failure by the tax administration to make an administrative review decision within a prescribed time period.
- Set out a process for seeking administrative review of assessments and clear time limits for doing so, running from the date on which the assessment was made and notice of the assessment given to the taxpayer.
- Require the tax authorities to consider the taxpayer’s request and provide the taxpayer with a decision on the request, with reasons, and provide concrete timelines for reaching a (written) decision on administrative review.
- Offer the taxpayer the possibility to be heard/make submissions before the administrative review function.
- Clarify the approach taken to payment of (total or portion of) tax where there is a dispute about tax liability, while allowing the taxpayer to appeal in any case. Nonpayment of (a portion of) tax should not preclude the right for an appeal but rather be linked with suspension of collection for the rest of the debt.
- Establish reporting and transparency arrangements, such as an obligation to publish redacted versions of the administrative review unit’s decisions and appeals statistics (for instance, number of appeals submitted, cases examined per type of tax, amount of tax disputed, amount of taxes waived, time taken to resolve cases etc.).
- If there is a quasi-judicial stage109, minimum qualifications and conflicts of interest conditions for the members of the quasi-judicial body, as well as a transparent application and selection process should be provided in the law.

*Annex I. Ensuring Adequate Taxpayer Safeguards through Governance Arrangements in Tax Procedure; a Checklist*

### Annex II. Examples of Mandate Provisions and

### Annex II. Examples of Mandate Provisions and Mission Statements

### Canada Revenue Agency (CRA) — Mandate and Mission
- Mandate (CRA Act, section 5)
  - "The Agency is responsible for:
    (a) supporting the administration and enforcement of the program legislation;
    (b) implementing agreements between the Government of Canada or the Agency and the government of a province or other public body performing a function of government in Canada to carry out an activity or administer a tax or program;
    (c) implementing agreements or arrangements between the Agency and departments or agencies of the Government of Canada to carry out an activity or administer a program; and
    (d) implementing agreements between the Government of Canada and an aboriginal government to administer a tax."
- Mission statement (CRA website)
  - "CRA Mission: Administer tax, benefits, and related programs, and ensure compliance on behalf of governments across Canada, thereby contributing to the ongoing economic and social well-being of Canadians."
  - "CRA Vision: Trusted, fair, and helpful by putting people first."
  - "CRA Promise: Contributing to the well-being of Canadians and the efficiency of government by delivering world-class tax and benefit administration that is responsive, effective, and trusted."
  - CRA Values:
    - Integrity - "We establish and preserve trust with all stakeholders by applying the law fairly and upholding our standards."
    - Professionalism - "We are knowledgeable, accurate, conscientious, innovative, and service-oriented."
    - Respect - "We interact with people in a way that makes them feel heard and valued. We listen and respond judiciously."
    - Collaboration - "We recognize and act on opportunities to work together to deliver the Agency’s mandate. We consult, and share ideas, fostering innovation to improve the service experience, both internally and externally."

### South African Revenue Service (SARS) — Objectives, Functions, Powers, and Mission
- Mandate (Act 34 of 1997, sec. 3-5)
  - Objectives
    - "SARS's objectives are the efficient and effective –
      (a) collection of revenue; and
      (b) control over the import, export, manufacture, movement, storage or use of certain goods."
  - Functions
    - "(1) To achieve its objectives SARS must –
      (a) secure the efficient and effective, and widest possible, enforcement of –
        (i) the national legislation listed in Schedule 1; and
        (ii) any other legislation concerning the collection of revenue or the control over the import, export, manufacture, movement, storage or use of certain goods that may be assigned to SARS in terms of either legislation or an agreement between SARS and the organ of state or institution concerned;
      (b) advise the Minister on –
        (i) all matters concerning revenue; and
        (ii) the exercise of any power or the performance of any function assigned to the Minister or any other functionary in the national executive in terms of legislation referred to in paragraph (a); and
      (c) advise the Minister of Trade and Industry on matters concerning the control over the import, export, manufacture, movement, storage or use of certain goods.
      (2) SARS must perform its functions in the most cost-efficient and effective manner and in accordance with the values and principles mentioned in section 195 of the Constitution."
  - Powers
    - "(1) SARS may do all that is necessary or expedient to perform its functions properly, including to –
      (a) determine its own staff establishment, appoint employees and determine their terms and conditions of employment in accordance with section 18;
      (b) bargain collectively with the recognized trade unions representing SARS employees;
      (c) obtain the services of any person, including any state department, functionary or institution, to perform any specific act or function;
      (d) acquire or dispose of any right in or to movable or immovable property, which may include ownership;
      (e) open and operate on its own bank accounts;
      (f) insure itself against any loss, damage, risk or liability;
      (g) perform any specific act or function within its competence on behalf of any other person, including any state department, functionary or institution;
      (h) impose fees or charges when performing an act or function in terms of paragraph (g);
      (i) perform legal acts, or institute or defend any legal action in its own name;
      (j) engage in any activity, whether alone or together with other organizations in the Republic or elsewhere, to promote proper, efficient and effective tax administration, including customs and excise duty administration; and
      (k) do anything that is incidental to the exercise of any of its powers."
  - Note in source: "There’s no explicit reference to the Mandate in the law, but only in the SARS site: The mandate of the South African Revenue Service (SARS) is to collect all revenues due, ensure optimal compliance with tax and customs legislation, and provide a customs and excise service that will facilitate legitimate trade as well as protect the economy and society."
- Mission statement (SARS website)
  - "It is SARS' mission to optimize revenue yield, facilitate trade and enlist new tax contributors by promoting awareness of the obligation to comply with South African tax and customs laws, and to provide quality and responsive service to the public."

### Inland Revenue Authority of Singapore (IRAS) — Functions, Powers, and Mission
- Mandate (CAP. 138A of 2012, sec. 6-7)
  - Functions of the Authority
    - "(1) The functions of the Authority are —
      (a) to act as agent of the Government and provide service in administering, assessing, collecting and enforcing payment of income tax, property tax, estate duty, stamp duties, betting and sweepstake duties, private lotteries duty and such other taxes as may be agreed between the Government and the Authority;
      (b) to advise the Government on matters relating to taxation and to liaise with the appropriate ministries and statutory bodies on such matters;
      (c) to represent Singapore internationally in respect of matters relating to taxation;
      (d) [Deleted by Act 10 of 2007]
      (e) to provide service in respect of the granting of licenses or permits by the Comptroller of Property Tax or the Commissioner of Estate Duties under any written law;
      (f) to provide service and advice to the Government and statutory bodies in respect of matters relating to the valuation of immovable properties; and
      (g) to perform such other functions as are conferred on the Authority by any other written law.
      (2) In addition to the functions imposed by this section, the Authority may undertake such other functions as the Minister may assign to the Authority and in so doing the Authority shall be deemed to be fulfilling the purposes of this Act and the provisions of this Act shall apply to the Authority in respect of such functions."
  - Powers of Authority
    - "(1) The Authority shall have power to do all things necessary or convenient to be done for or in connection with the performance of its functions.
      (2) Without prejudice to the generality of subsection (1), the powers of the Authority shall include power —
      (a) to enter into contracts;
      (b) to form or participate in the formation of a company;
      (c) to utilize all property of the Authority, movable and immovable, in such manner as the Authority may think expedient including the raising of loans by mortgaging such property;
      (d) to engage in any activity, either alone or in conjunction with other organizations or international agencies, to promote better understanding of taxation;
      (e) to provide technical advice or assistance, including training facilities, to tax authorities of other countries;
      (f) to make charges for services rendered by the Authority;
      (g) to grant loans to employees of the Authority for any purpose specifically approved by the Authority;
      (h) to provide recreational facilities and promote recreational activities for, and activities conducive to, the welfare of employees of the Authority;
      (i) to provide training for employees of the Authority and to award scholarships or otherwise pay for such training; and
      (j) to do anything incidental to any of its powers."
- Mission statement (IRAS website)
  - Our Vision
    - "The leading revenue authority in the world
      A partner of the community in nation-building and inclusive growth
      A dynamic team of competent and committed people"
  - Corporate goals and core values
    - "Our corporate goals are to:
      Foster an economic environment that supports inclusive growth
      Provide excellent service
      Maximize voluntary compliance
      Enhance organizational and staff productivity and agility
      Achieve a high level of staff competence, ownership and satisfaction"
    - Core values:
      - FAIRNESS — "Treat everyone in the same circumstances equally"
      - INTEGRITY — "Do what is right without fear or favor in all circumstances"
      - PROFESSIONALISM — "Serve our nation responsively, with competence, pride, commitment and empathy"
      - TEAMWORK — "Work with one another with mutual trust and respect to achieve Whole-of-IRAS and Whole-of-Government outcomes"
      - INNOVATION — "Continuously seek new ways to do our work better"

### Directorate of Taxation, Republic of South Sudan — Guiding Principles and Values
- The Taxation Act, 2009, Section 8. Guiding Principles and Values
  - "The Directorate of Taxation (DT) shall observe the following guiding principles and values when exercising its functions and duties:
    (a) ensure transparency in operations so that the level of government entitled to the revenue proceeds has complete information on revenue collections and can validate the calculations of its share;
    (b) clearly enlighten the citizens on their rights and duties under this Act in a manner that is educating and permits the self-assessment of taxes;
    (c) make easily understood forms and instructions freely available to the public;
    (d) ensure that the law is applied uniformly to all taxpayers by publicizing explanations on how the DT will apply the law where such application may affect a number of taxpayers;
    (e) through the selection, training, and promotion of revenue officers, encourage them to be honest, courteous, and fair and to apply the law, regulations and rulings to each case on the basis of the objective facts;
    (f) apply sanctions and penalties that are clearly understood and are swiftly applied in a uniform manner;
    (g) make educational visits to taxpayers to ensure that they understand their rights and duties; and,
    (h) to reduce DT’s reliance on sanctions that punish taxpayers for violations, develop programs and practices that encourage taxpayers to comply with the law."

### Annex III. Institutional Oversight and Accountability Provisions in the Canada Revenue Agency Act

### Relations with the Minister and Directions
- Minister responsible
  - Sec. 6(2). "The Minister is responsible for the Agency."
- Minister may direct on exercise of powers
  - Sec. 9. "The Minister may direct the Commissioner or any other person in the exercise of a power or the performance of a duty or function of the Minister that the Commissioner or the person is authorized to exercise or perform under subsection 8(1) or (4) or under the program legislation."
- Directions to the Agency
  - Sec. 11(1). "The Minister may issue a written direction to the Agency, addressed to the Chair of the Board, on any matter within the authority or responsibility of the Board that, in the Minister’s opinion, affects public policy or could materially affect public finances."
  - Sec. 11(2). "A direction issued under subsection (1) is not a statutory instrument for the purposes of the Statutory Instruments Act."
- Compliance with directions
  - Sec. 12. "Every person who is directed by the Minister under section 9 or 10 or subsection 11(1) must comply with the direction."
- Commissioner to keep Minister informed
  - Sec. 38(1). "The Commissioner must keep the Minister informed of any matter that could affect public policy or that could materially affect public finances, and any other matter that the Minister considers necessary."
  - Sec. 38(2). "The Commissioner must assist and advise the Minister in the exercise of the Minister’s powers and in the performance of the Minister’s duties and functions under any Act of Parliament or of a province and in the carrying out of the Minister’s duties as a minister of the Crown."

### Role of the Management Board and Limits
- Role of the Management Board
  - Sec. 31(1). "The Board is responsible for overseeing the organization and administration of the Agency and the management of its resources, services, property, personnel and contracts."
- Limitation Restriction
  - Sec. 34. "The Board may not direct the Commissioner or any other person (a) in the exercise of a power or the performance of a duty or function conferred or delegated under the program legislation or the laws of a province or authorized to be exercised or performed on the Minister’s behalf under this Act; or (b) on the administration and enforcement of the program legislation."

### Corporate Business Plan, Audits, and Annual Report
- Corporate business plan
  - Sec. 47(3). "The Agency must submit the corporate business plan in the form and manner and within the time specified by the Treasury Board and provide any further information that the Treasury Board may require in respect of it."
  - Sec. 48. "The Agency must act in a manner consistent with its most recent corporate business plan and comply with any terms and conditions specified by the Treasury Board."
  - Sec. 49(1). "After the Treasury Board approves the corporate business plan, the Agency must submit a summary of the plan to the Minister for approval."
  - Sec. 49(2). "The Minister must cause a copy of the summary to be tabled in each House of Parliament on any of the first fifteen days on which that House is sitting after the Minister approves it."
- Audits
  - Sec. 87. "The Auditor General of Canada is the auditor for the Agency and must
    (a) annually audit and provide an opinion to the Agency and the Minister on the financial statements of the Agency; and
    (b) provide the Minister, the Commissioner and the Board with copies of reports of audits carried out under this section."
- Annual report
  - Sec. 88(1). "The Agency must, before December 31 of each year following the Agency’s first full year of operations, submit an annual report on the operations of the Agency for the preceding fiscal year to the Minister, and the Minister must cause a copy of the report to be tabled in each House of Parliament on any of the first fifteen days on which that House is sitting after the Minister receives it."
  - Sec. 88(2). "The annual report must include
    (a) the financial statements of the Agency, prepared in accordance with accounting principles consistent with those applied in preparing the Public Accounts referred to in section 64 of the Financial Administration Act, and the Auditor General of Canada’s opinion on them;
    (b) information about the Agency’s performance with respect to the objectives established in the corporate business plan;
    (c) a summary statement of any assessment prepared under section 59;
    (d) any report made by the Public Service Commission under subsection 56(1); and
    (e) any other information that the Minister may require to be included in it."

*Source: wpiea2025017-print-pdf - Annex II. Examples of Mandate Provisions and Mission Statements*

### References

### References

### Tax administration frameworks and governance
- Aaron, H. and Slemrod, J. (eds.), 2004, The Crisis in Tax Administration, Brookings Institution Press
- Alink, M. and Van Kommer, V., 2015, IBFD Handbook on Tax Administration (Second Revised Edition), IBFD
- Bird, R. and Casangera de Jantscher, M. (eds.), 1992, The Reform of Tax Administration, in Improving Tax Administration in Developing Countries, Bird, R. and Casangera de Jantscher, M. (eds.), International Monetary Fund, Washington
- Bird, R., 2004, Administrative Dimensions of Tax Reform, Asia-Pacific Tax Bulletin, March 2004. https://www.researchgate.net/publication/24137632_Administrative_Dimensions_of_Tax_Reform/link/02e7e529f5799e93fd000000/download
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- Bronzewska, K. and Van der Enden, E., 2014, Tax Control Framework – A Conceptual Approach: The Six Nuances of Good Tax Governance, Bulletin for International Taxation, 2014 (Volume 68), No 11, IBFD
- CIAT, 1996, Minimum Necessary Attributes for a Sound and Effective Tax Administration, approved by the CIAT General Assembly held in Santo Domingo, Dominican Republic. https://www.ciat.org/Biblioteca/DocumentosInstitucionales/CartaDocumento(AtributosMinimos)/minimum_necessary_attributes.pdf
- CIAT, 2005, Model Code of Conduct. https://www.ciat.org/Biblioteca/DocumentosTecnicos/Ingles/2005_model_code_conduct.pdf
- CIAT, 2009, Technical Conference, Strengthening of the Tax Administration’s Capacity. https://www.ciat.org/strengthening-of-the-tax-administrations-capacity-2/?lang=en
- CIAT, 2011, Tax Administration Institutional Strengthening, Tax Thematic Series. https://www.ciat.org/Biblioteca/SerieTematica/Ingles/2011_No10_apr_institu_stre.pdf
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- Jenkins, G., 1994, Modernizing of tax administration: Revenue boards as an instrument for change, Bulletin for International Fiscal Documentation, 48(2)
- Mann, A., (2004), Are Semi-Autonomous Revenue Authorities the Answer to Tax Administration Problems in Developing Countries – A Practical Guide, USAID. http://web.worldbank.org/archive/website01531/WEB/IMAGES/SARA_STU.PDF
- Taliercio, R., 2004, Designing for Performance: The Semi-Autonomous Revenue Authority Model in Africa and South America, World Bank, Washington. https://openknowledge.worldbank.org/handle/10986/14224
- Vanistendael, F., 1996, Legal Framework for Taxation, in Tax Law Design and Drafting, Thuronyi, V. (ed.), Vol. 1, International Monetary Fund. https://www.imf.org/en/Publications/Books/Issues/2016/12/30/Tax-Law-Design-and-Drafting-Volume-1-1550
- Végh, G. and Gribnau, H., Tax Administration Good Governance, EC Tax Review, 2018–1
- World Bank, 2010, Integration of Revenue Administration: A Comparative Study of International Experience, World Bank, Washington. https://openknowledge.worldbank.org/handle/10986/13529
- World Bank, 2019, Thinking Strategically about Revenue Administration Reform: The Creation of Integrated, Autonomous Revenue Bodies, prepared by Junquera-Varela, R.F., Awasthi, R., Balabushko, O., Nurshaikova, A.. https://documents1.worldbank.org/curated/en/940661576565536211/pdf/Thinking-Strategically-about-Revenue-Administration-Reform-The-Creation-of-Integrated-Autonomous-Revenue-Bodies-Policy-Note.pdf

### International organizations, guidance, and policy papers
- AOTCA/CFE/STEP, 2016, Towards Greater Fairness in Taxation: A Model Taxpayer Charter, IBFD.
- Asian Development Bank, 2020, A Comparative Analysis of Tax Administration in Asia and the Pacific, 2020 edition, available at https://www.adb.org/publications/comparative-analysis-tax-administration-asia-pacific-2020
- Bank for International Settlements (BIS), 2012, Basel Core Principles for Effective Banking Supervision. https://www.bis.org/publ/bcbs230.pdf
- Council of the European Union, 2020, Council conclusions on fair and effective taxation in times of recovery, on tax challenges linked to digitalization and on tax good governance in the EU and beyond, 20 FISC 226 ECOFIN 1097 (2020). https://www.consilium.europa.eu/media/46939/st13350-en20.pdf
- European Commission, 2007, Fiscal Blueprints: A path to a robust, modern and efficient tax Administration. https://op.europa.eu/en/publication-detail/-/publication/50c10975-0e41-4aaf-8bdb-6992d3740207
- European Commission, 2016, Guidelines for a Model for A European Taxpayers’ Code. https://taxation-customs.ec.europa.eu/system/files/2016-11/guidelines_for_a_model_for_a_european_taxpayers_code_en.pdf
- European Commission, 2020, Communication on Tax Good Governance in the EU and beyond, COM (2020) 313 final. https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM%3A2020%3A0313%3AFIN
- European Parliament, 2011, European Parliament Resolution of 8 March 2011 on tax and Development – Cooperating with Developing Countries on Promoting Good Governance in Tax Matters. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52010DC0163&from=EN
- European Parliament, 2015, Directorate General for Internal Policies, Promoting Good Tax Governance in Third Countries: The Role of the EU, IP/A/ECON/2015-08. https://www.europarl.europa.eu/RegData/etudes/IDAN/2015/569976/IPOL_IDA(2015)569976_EN.pdf
- IMF/OECD, 2017, Tax Certainty, Report for the G20 Finance Ministers. https://www.oecd.org/tax/tax-policy/tax-certainty-report-oecd-imf-report-g20-finance-ministers-march-2017.pdf
- IMF/OECD, 2019, Progress Report on Tax Certainty, Report for the G20 Finance Ministers and Central Bank Governors. https://www.oecd.org/ctp/g20-report-on-tax-certainty.htm
- IOTA, 2018, Improving Tax Governance and Ensuring Data Security. https://www.iota-tax.org/sites/default/files/publications/public_files/improving-tax-governance-and-ensuring-data-security.pdf
- OECD, 1998, Electronic Commerce: Taxation Framework Conditions, a Report by the Committee on Fiscal Affairs as presented to Ministers at the OECD Ministerial Conference, “A Borderless World: Realising the Potential of Electronic Commerce” on 8 October 1998. https://www.oecd.org/ctp/consumption/1923256.pdf
- OECD, 2003, Taxpayers Rights and Obligations, Centre for Tax Policy and Administration, OECD, Paris.
- OECD, 2011, Asset Declarations for Public Officials: A Tool to Prevent Corruption. https://www.oecd.org/daf/anti-bribery/assetdeclarationsforpublicofficialsatooltopreventcorruption.htm
- OECD, 2013, Co-operative Compliance: A Framework: From Enhanced Relationship to Co-operative Compliance, OECD Publishing, Paris. https://doi.org/10.1787/9789264200852-en.
- OECD, 2014a, The Governance of Regulators, OECD Best Practices Principles for Regulatory Policy, OECD Publishing, Paris. https://www.oecd-ilibrary.org/governance/the-governance-of-regulators_9789264209015-en
- OECD, 2014b, Tax revenues as a motor for sustainable development in Mobilising Resources for Sustainable Development - Development Co-operation Report 2014. https://www.oecd-ilibrary.org/docserver/dcr-2014-11-en.pdf?expires=1632584556&id=id&accname=guest&checksum=4E819038FF9AE3CD763F7A8F86B4938F
- OECD, 2015, G20/OECD Principles of Corporate Governance, OECD Publishing, Paris. https://www.oecd.org/corporate/principles-corporate-governance/
- OECD, 2021a, Behavioural Insights for Better Tax Administration: A Brief Guide. https://www.oecd.org/tax/forum-on-tax-administration/publications-and-products/behavioural-insights-for-better-tax-administration-a-brief-guide.pdf
- OECD, 2021b, Tax Administration 2021: Comparative Information on OECD and other Advanced and Emerging Economies, OECD Publishing, Paris. https://doi.org/10.1787/cef472b9-en.
- OECD, 2021c, Italy’s Tax Administration: A Review of Institutional and Governance Aspects. https://www.oecd.org/tax/administration/italy-tax-administration-a-review-of-institutional-and-governance-aspects.pdf
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- Platform for Collaboration on Tax (PCT), 2016, "Enhancing the Effectiveness of External Support in Building Tax Capacity in Developing Countries (2016)". http://www.oecd.org/tax/enhancing-the-effectiveness-of-external-support-in-building-tax-capacity-in-developing-countries.pdf
- Tax Administration Diagnostic Assessment Tool (TADAT), Field Guide, 2015, (http://www.tadat.org/files/IMF_TADAT-FieldGuide_web.pdf)

### IMF publications, technical notes, and working papers
- International Monetary Fund (IMF), 1997, Guidance Note: Good Governance – the IMF’s Role. https://www.imf.org/external/pubs/ft/exrp/govern/govern.pdf
- IMF, 2006, Revenue Authorities: Issues and Problems in Evaluating their Success, prepared by Kidd, M., and Crandall, W., IMF Working Paper. https://www.imf.org/external/pubs/ft/wp/2006/wp06240.pdf
- IMF, 2010a, Revenue Administration: Functionally Organized Administration, prepared by Kidd, M, IMF Technical Notes and Manuals. https://www.imf.org/external/pubs/ft/tnm/2010/tnm1010.pdf
- IMF, 2010b, Revenue Administration: A Toolkit for Implementing a Revenue Authority, prepared by Kidd, M. and Crandall, W. IMF Technical Notes and Manuals. https://www.imf.org/external/pubs/ft/tnm/2010/tnm1008.pdf
- IMF, 2010c, Revenue Administration: Performance Measurement in Tax Administration, prepared by Crandall, W., IMF Technical Notes and Manuals. https://www.imf.org/external/pubs/ft/tnm/2010/tnm1011.pdf
- IMF, 2010d, Revenue Administration: Autonomy in Tax Administration and the Revenue Authority Model, prepared by Crandall, W., IMF Technical Notes and Manuals. https://www.imf.org/external/pubs/ft/tnm/2010/tnm1012.pdf
- IMF, 2013, Tax Law Note, How Can an Excessive Volume of Tax Disputes Be Dealt With? prepared by Victor Thuronyi, V. and Espejo, https://www.imf.org/external/np/leg/tlaw/2013/eng/tdisputes.pdf
- IMF, 2014, Managing Income Tax Compliance through Self-Assessment, prepared by A. Okello, IMF Working Paper. https://www.imf.org/en/Publications/WP/Issues/2016/12/31/Managing-Income-Tax-Compliance-through-Self-Assessment-41415
- IMF, 2015a, Policy Paper, Current Challenges in Revenue Mobilization: Improving Tax Compliance. https://www.imf.org/en/Publications/Policy-Papers/Issues/2016/12/31/Current-Challenges-in-Revenue-Mobilization-Improving-Tax-Compliance-PP4944
- IMF, 2015b, Working Paper, The Evolving Functions and Organization of Finance Ministries, prepared by Allen, R., Hurcan, Y., Murphy, P., Queyranne, M. and Ylaoutinen, S., WP/15/232. https://www.imf.org/external/pubs/ft/wp/2015/wp15232.pdf
- IMF, 2015d, Understanding Revenue Administration: An Initial Data Analysis Using the Revenue Administration Fiscal Information Tool, prepared by Lemburger, A., Masters, A., and Cleary, D. https://www.imf.org/external/pubs/ft/dp/2015/fad1501.pdf
- IMF, 2016a, Introducing a General Anti-Avoidance Rule (GAAR): Ensuring That a GAAR Achieves Its Purpose, prepared by Waerzeggers, C., and Hillier, C., IMF Tax Law Technical Note, 01/2016. https://www.imf.org/en/Publications/Tax-Law-Technical-Note/Issues/2016/12/31/Introducing-a-General-Anti-Avoidance-Rule-GAAR-Ensuring-That-a-GAAR-Achieves-Its-Purpose-43662
- IMF, 2016b, Introducing an Advance Tax Ruling (ATR) Regime, prepared by Waerzeggers, C., and Hillier, C., IMF Tax Law Technical Note, 02/2016. https://www.imf.org/en/Publications/Tax-Law-Technical-Note/Issues/2016/12/31/Introducing-an-Advance-Tax-Ruling-ATR-Regime-43933
- IMF, 2017, Policy Paper, The Role of the Fund in Governance Issues —Review of the Guidance Note – Preliminary Considerations – Background Notes. https://www.imf.org/en/Publications/Policy-Papers/Issues/2017/08/01/pp080217-background-notes-the-role-of-the-fund-in-governance-issues-review-of-the-guidance-note
- IMF, 2018, Policy Paper, Review of 1997 Guidance Note on Governance—A Proposed Framework for Enhanced Fund Engagement. https://www.imf.org/en/Publications/Policy-Papers/Issues/2018/04/20/pp030918-review-of-1997-guidance-note-on-governance
- IMF, 2019a, Fiscal Monitor – Curbing Corruption. https://www.imf.org/en/Publications/FM/Issues/2019/03/18/fiscal-monitor-april-2019
- IMF, 2019b, How to Design Tax Policy in Fragile States, How to Note 19/04, Prepared by Mario Mansour and Jean-Luc Schneider. https://www.imf.org/~/media/Files/Publications/HowToNotes/HowToNote1904.ashx
- IMF, 2019c, ISORA 2016: Understanding Revenue Administration, No. 19/05, prepared by Crandall, W., Gavin, E., and Masters, A. https://www.imf.org/-/media/Files/Publications/DP/2019/English/ISORAURAEA.ashx
- IMF, 2019d, The Role of Board Oversight in Central Bank Governance: Key Legal Design Issues, WP/19/293, prepared by Bossu, W., and Rossi, A., IFM Working Paper. https://www.imf.org/en/Publications/WP/Issues/2019/12/27/The-Role-of-Board-Oversight-in-Central-Bank-Governance-Key-Legal-Design-Issues-48906
- IMF, 2019e, Designing Interest and Tax Penalty Regimes, prepared by Waerzeggers, C., Hillier, C., and Aw, I., IMF Tax Law Technical Note, 01/2019. https://www.imf.org/en/Publications/Tax-Law-Technical-Note/Issues/2019/04/04/Designing-Interest-and-Tax-Penalty-Regimes-46648
- IMF, 2020a, Keeping the Receipts: Transparency, Accountability, and Legitimacy in Emergency Responses, Special Series on COVID-19. https://www.imf.org/-/media/Files/Publications/covid19-special-notes/en-special-series-on-covid-19-keeping-the-receipts.ashx
- IMF, 2020b, The Development Path Less Traveled: The Experience of Rwanda, prepared by Redifer, L., Alper, E., Meads, N., Gursoy, T., Newiak, M. and Thomas, A. https://www.imf.org/en/Publications/Departmental-Papers-Policy-Papers/Issues/2020/08/17/The-Development-Path-Less-Travelled-The-Experience-of-Rwanda-49609
- IMF, 2021a, Economic Governance Reforms to Support Inclusive Growth in the Middle East, North Africa, and Central Asia, No. 21/01. https://www.imf.org/-/media/Files/Publications/DP/2021/English/EGRSIGEA.ashx
- IMF, 2021b, ISORA 2018: Understanding Revenue Administration, No. 19/05, prepared by Crandall, W., Gavin, E., and Masters, A. https://www.imf.org/en/Publications/Departmental-Papers-Policy-Papers/Issues/2021/11/03/Understanding-Revenue-Administration-464865
- IMF, 2023a, Leveraging anti-money laundering measures to improve tax compliance and help mobilize domestic revenues, prepared by Mathias, E., and Wardzynski, A., IMF Working Paper No. [23/X]. International Monetary Fund. Washington D.C. https://www.imf.org/en/Publications/WP/Issues/2023/04/21/Leveraging-Anti-money-Laundering-Measures-to-Improve-Tax-Compliance-and-Help-Mobilize-532652
- IMF, 2023b, Staff Guidance Note on the Implementation of the IMF Strategy for Fragile and Conflict-Affected States. https://www.imf.org/en/Publications/Policy-Papers/Issues/2023/03/22/Staff-Guidance-Note-on-The-Implementation-of-The-Imf-Strategy-for-Fragile-and-Conflict-531261
- IMF, 2024a, Revenue Authorities and Their Boards of Management: Recent Developments, prepared by Crandall, William, Elizabeth Gavin, Maureen Kidd, and Andrew Masters. 2024. IMF Technical Notes and Manuals 2024/05, International Monetary Fund, Washington, DC. https://www.imf.org/en/Publications/TNM/Issues/2024/08/23/Revenue-Authorities-and-their-Boards-of-Management-Recent-Developments-551872
- IMF, 2024b, Citizens Perceptions of Tax Authorities and Tax Efficiency, prepared by Telma Yamou, Alun H. Thomas, and Kaihao Cai., IMF Working Papers 2024, 234 (2024). https://doi.org/10.5089/9798400292866.001

### Regional and country studies, case analyses, and comparative work
- Anastasiou, A., Kalligosfyris, C. and Kalamara E., 2021, An Analysis of the Efficiency of Tax Administrations of 26 European Countries in 2017, Bulletin for International Taxation, 2021 (Volume 75), No 2, IBFD
- Asian Development Bank, 2020, A Comparative Analysis of Tax Administration in Asia and the Pacific, 2020 edition, available at https://www.adb.org/publications/comparative-analysis-tax-administration-asia-pacific-2020
- Das-Gupta, A., 2006, Implications of Tax Administration for Tax Design: A Tentative Assessment in The Challenges of Tax Reform in a Global Economy, Alm, J., Martinez-Vasquez, J. and Rider, M. (eds.), Springer
- Dimitrakopoulos, D., Passas, A., 2020, The Depoliticisation of Greece’s Public Revenue Administration: Radical Change and the Limits of Conditionality, Springer
- Durand, F., 2002, State Institutional Development: Assessing the Success of the Peruvian Tax Reform, Mimeo, San Antonio, University of Texas
- Fjeldstad, O.H. and Moore, M., 2009, Revenue Authorities and Public Authority in sub-Saharan Africa, Journal of Modern African Studies, 47, 1, pp. 1–18
- Gouonzález de Frutos, U., 2019, The EU and OECD Contend to Lead Global Tax Governance, in The External Tax Strategy of the EU in a Post-BEPS Environment, Jiménez, A.M. (ed.), IBFD
- Hlope, D. and Friedman, S., 2002, ...And their hearts and minds will follow...? Tax Collection, Authority and Legitimacy in Democratic South Africa, IDS Bulletin 33, 3
- Redifer et al., IMF, 2020, The Development Path Less Traveled: The Experience of Rwanda (see IMF listing above)

### Legal design, tax law drafting, and dispute resolution
- Gordon, R. and Thuronyi, V., 1996, Tax Legislative Process, in Tax Law Design and Drafting, Thuronyi, V. (ed.), Vol. 1, International Monetary Fund. https://www.imf.org/en/Publications/Books/Issues/2016/12/30/Tax-Law-Design-and-Drafting-Volume-1-1550
- Gordon, R., 1996, Law of Tax Administration and Procedure, in Tax Law Design and Drafting, Thuronyi, V. (ed.), Chapter. 4, Vol. 1, International Monetary Fund. https://www.imf.org/en/Publications/Books/Issues/2016/12/30/Tax-Law-Design-and-Drafting-Volume-1-1550
- Pistone, P., Roeleveld, J., Hattingh, J., Pinto Nogueira, J. and West, C., 2019, Fundamentals of Taxation: An Introduction to Tax Policy, Tax Law and Tax Administration, IBFD
- Pistone, P. (ed.), 2019, Tax Procedures, EATLP Annual Congress Madrid, EATLP International Tax Series, Vol. 18, IBFD
- Thuronyi, V., 1996, Drafting Tax Legislation, in Tax Law Design and Drafting, Thuronyi, V. (ed.), Vol. 1, International Monetary Fund. https://www.imf.org/en/Publications/Books/Issues/2016/12/30/Tax-Law-Design-and-Drafting-Volume-1-1550
- UN, 2021, UN Handbook on Dispute Avoidance and Resolution. https://desapublications.un.org/publications/united-nations-handbook-dispute-avoidance-and-resolution

### Technology, digitalization, privacy, and data security
- Collosa, A., 2021, Simplification of Tax Systems and Digitalization of Tax Administrations, in Kluwer Tax Blog. http://kluwertaxblog.com/2021/05/05/simplification-of-tax-systems-and-digitilisation-of-tax-administrations/
- Favaloro, G.A.C., 2021, The Exchange of Tax Information between EU Member States and Third Countries Privacy and Data Protection Concerns, European Taxation, 2021 (Volume 61), No 4, IBFD
- Hadwick, D., & S. Lan, Lessons to Be Learned from the Dutch Childcare Allowance Scandal: A Comparative Review of Algorithmic Governance by Tax Administrations in the Netherlands, France and Germany, 13 World Tax J. 4 (2021), Journal Articles & Opinion Pieces IBFD.
- IOTA, 2018, Improving Tax Governance and Ensuring Data Security. https://www.iota-tax.org/sites/default/files/publications/public_files/improving-tax-governance-and-ensuring-data-security.pdf

### Behavioral, compliance, and taxpayer rights research
- Gangl, K., Hofmann, E. and Kirchler, E., 2015, Tax authorities' interaction with taxpayers: A conception of compliance in social dilemmas by power and trust, New Ideas in Psychology, Volume 37, 2015, Pages 13-23. https://www.sciencedirect.com/science/article/pii/S0732118X14000592
- Owens, J., McDonell, R., Franzsen, R. and Amos, J., (eds.), 2017, Inter-agency Cooperation and Good Tax Governance in Africa, WU (Vienna University of Economics and Business) & University of Pretoria, Pretoria University Law Press
- Owens, J., and Pemberton J.-L. (eds), 2021, Cooperative Compliance: A Multi-Stakeholder and Sustainable Approach to Taxation (Eucotax series), Wolters Kluwer
- OECD, 2021a, Behavioural Insights for Better Tax Administration: A Brief Guide. https://www.oecd.org/tax/forum-on-tax-administration/publications-and-products/behavioural-insights-for-better-tax-administration-a-brief-guide.pdf
- Observatory on the Protection of Taxpayers’ Rights, 2023, The IBFD Yearbook on Taxpayers’ Rights. https://www.ibfd.org/sites/default/files/2024-05/2023-optr-yearbook.pdf

### Anti-corruption, governance, and integrity
- IMF, 2019a, Fiscal Monitor – Curbing Corruption. https://www.imf.org/en/Publications/FM/Issues/2019/03/18/fiscal-monitor-april-2019
- UNDP, 2011, Governance Principles, Institutional Capacity and Quality in Towards Human Resilience: Sustaining MDG Progress in an Age of Economic Uncertainty. https://www.undp.org/publications/towards-human-resilience-sustaining-mdg-progress-age-economic-uncertainty
- UN ESCAP, 2009, What is good Governance? https://www.unescap.org/sites/default/d8files/knowledge-products/good-governance.pdf
- Weeks-Brown, R., 2020, Strengthening Governance and Fighting Corruption to Foster Sustainable and Inclusive Economic Growth in Ethics & Progress, Towards Conscious Capitalism, ICC Netherlands. https://www.weekofintegrity.org/wp-content/uploads/2020/12/ICC_Book2020_spreads_issuu.pdf
- World Bank, 2020, Enhancing Government Effectiveness and Transparency - The Fight Against Corruption (Global Report). https://www.worldbank.org/en/topic/governance/publication/enhancing-government-effectiveness-and-transparency-the-fight-against-corruption

### Selected books, monographs, and historical accounts
- Rossoti, C., 2005, Many Unhappy Returns: One Man’s Quest to Turn Around the Most Unpopular Organization in America, Harvard Business School Press
- Sawyer, A., 2021, Expanding the Commissioner’s Core Powers: Should New Zealanders Be Concerned?, Bulletin for International Taxation, Vol. 75, No 4, IBFD
- Slemrod, J. and Gillitzer, C., 2013, Insights from a Tax-systems Perspective, CESifo Economic Studies
- Steuerle, E., 2008, Tax Policy’s Principles and Principals. Contemporary U.S. Tax Policy [2nd Edition]. Urban Institute Press: Washington, D.C. https://webarchive.urban.org/publications/211511.html
- Tuck, P., De Cogan, D. and Snape, J., 2019, A tale of the merger between the Inland Revenue and Customs & Excise in Peter Harris and Dominic de Cogan (eds.), Studies in the History of Tax Law vol. 9 (Oxford: Hart). https://media.bloomsburyprofessional.com/rep/files/9781509924936sample.pdf
- Pistone, P., Roeleveld, J., Hattingh, J., Pinto Nogueira, J. and West, C., 2019, Fundamentals of Taxation: An Introduction to Tax Policy, Tax Law and Tax Administration, IBFD

*Source: wpiea2025017-print-pdf - References*

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_Source: https://www.imf.org/-/media/files/publications/wp/2025/english/wpiea2025017-print-pdf.pdf_