International Taxation: Opportunities and Risks

Jointly organized by the International Monetary Fund and
the World Bank Group

Sunday, April 17, 2016
Washington, D.C., USA

The International Monetary Fund and the World Bank hosted their 2nd annual Spring Meetings conference on taxation, entitled International Taxation: Opportunities and Risks. The conference was a dialogue between the IMF/WBG and officials from developing countries, other partner organizations, business and civil society representatives. It addressed four topics:

  • The purpose and structure of the framework for tax policy diagnostic assessment—a new IMF/WBG initiative to help member countries strengthen their tax systems—including in relation to international tax issues.
  • The lessons-learned and the most pressing capacity needs in dealing with aggressive tax planning and international tax matters, as identified by developing countries in the course of the IMF/WBG efforts in capacity-building.
  • The ongoing work by the IMF/OECD on how offshore transfers of domestic assets are currently taxed, and how they should be taxed.
  • The pressure on resource rich developing countries to reconsider their extractive industries (EI) fiscal regimes, motivated by the significant fall in commodity prices, and the heightened awareness of international tax planning issues.

For each of the four topics, brief expert presentations were made, followed by a panel discussion from invited speakers. A general discussion from the audience concluded each section.

Participation in the conference was by invitation only.

CONFERENCE AGENDA

Draft Agenda

1:30 PM
2:00 PM

Registration

2:00 PM
2:15 PM

Welcome and Introduction

This opening session will set the stage of the 2nd annual IMF/WBG Spring Meetings conference on international taxation. The session will introduce the objectives of the meeting – to assess the emerging opportunities and risks in international tax issues, and to discuss the role of the IMF and WBG in the global fight against profit shifting and tax avoidance.

Sri Mulyani Indrawati, Managing Director and Chief Operating Officer, WBG

As Managing Director and Chief Operating Officer, Sri Mulyani Indrawati is responsible for the World Bank’s operations worldwide. She works closely with client countries and member states to put operational strategies in place that address new and persistent development challenges in support of the World Bank’s goals of ending poverty and promoting shared prosperity.

Indrawati frequently represents the World Bank Group at the G20 and in other international fora. She is also responsible for the strategic direction and policy framework of the Bank’s Fund for the Poorest, IDA, one of the largest sources of assistance for the world’s 77 poorest countries. She also chairs the World Bank Group’s Advisory Council on Gender and Development.

Before joining the World Bank in June 2010, she served as Indonesia’s Minister of Finance in addition to being the Coordinating Minister of Economic Affairs. Her earlier positions include head of the Indonesian National Development Planning Agency, executive director at the International Monetary Fund.

Vitor Gaspar, Director, Fiscal Affairs Department, IMF

Vitor Gaspar, a Portuguese national, is Director of the Fiscal Affairs Department of the International Monetary Fund. Prior to joining the IMF, he held a variety of senior policy positions in Banco de Portugal, including most recently as Special Adviser. He served as Minister of State and Finance of Portugal during 2011-2013. He was head of the European Commission’s Bureau of European Policy Advisers during 2007-2010 and director-general of research at the European Central Bank from 1998 to 2004. Mr. Gaspar holds a Ph.D. and a post-doctoral agregado in Economics from Universidade Nova de Lisboa; he also studied at Universidade Católica Portuguesa.

2:15 PM
2:45 PM

Tax policy assessment framework – international tax issues

Ahead of the Financing for Development Conference in Addis Ababa, the IMF and the World Bank announced the launch of a new joint initiative to help member countries strengthen their tax systems. One of the pillars of the initiative includes the development of improved diagnostic tools to evaluate tax policies, identify priority tax policy reforms, and design the requisite support for their implementation. The session will discuss the new tax policy diagnostic framework, its purpose and structure, and explain the treatment of international tax issues within the framework.

Chair: Marijn Verhoeven, Lead Economist and Cluster Lead, Governance Global Practice, WBG

Marijn Verhoeven is a Lead Economist and Cluster Lead with the World Bank Group’s Governance Global Practice, where he leads work on domestic revenue mobilization and fiscal risk of state-owned enterprises and contributes to work streams on extractive industry governance, evidence-based PFM reforms, political economy analysis, and public expenditure reviews. Before joining the World Bank, Marijn worked at the IMF where he was the Fund’s resident representative in Bangladesh and Deputy Division Chief of the Expenditure Policy Division. He was educated at Tilburg University in the Netherlands.

Speaker: Victoria Perry, Assistant Director, Fiscal Affairs Department, IMF

Victoria Perry is Assistant Director in the Fiscal Affairs Department and Division Chief of the Tax Policy Division at the International Monetary Fund. Since joining the IMF in 1993, she has provided technical assistance in tax policy and revenue administration to more than 40 countries in Africa, Europe, and Asia. From 2002 to 2008 she served as Division Chief for Revenue Administration in FAD. She is a coauthor of the book “The Modern VAT,” published by the IMF in 2001. Prior to joining the IMF, Ms. Perry was the Deputy Director of the Harvard University International Tax Program, teaching comparative income taxation and value added taxation and providing technical assistance in revenue policy through the Harvard Institute for International Development. Ms. Perry previously practiced tax law with the Boston law firm of Hale and Dorr (now WilmerHale). She is past president of the American Tax Policy Institute; current vice president of the board of the National Tax Association; and past Chair of the Value Added Tax Committee of the American Bar Association Section of Taxation. She received her J.D. from the Harvard Law School, and her B.A. from Yale University in economics and philosophy.

Presentation
Discussant: Savior Mwambwa, International Tax Campaign Manager, ActionAid International

Savior Mwambwa is the International Tax Campaign Manager for ActionAid. Savior is formerly Policy and Advocacy Manager for the Tax Justice Network -Africa (TJN-A) based in Nairobi Kenya. Savior headed the Centre for Trade Policy and Development (CTPD) between 2007 and 2013 where he had been instrumental in providing leadership to the Tax justice campaign in Zambia. He has been involved in strengthening the capacities of local grass roots organisations abilities to influence trade and investment policies as well as holding to account Multinational Companies (MNCs) for their activities.

He holds a post graduate qualification in International Trade Policy and Trade Law from Lund University and the Trade Policy Institute of Africa (TRAPCA) and a Bachelors of Arts Degree (Development Studies & Economics) from the University of Zambia.

2:45 PM
3:30 PM

Building capacity in international tax matters

Lack of capacity has been identified by developing countries as the central issue in dealing with aggressive tax planning and international tax matters. This session will discuss the IMF/WBG efforts in capacity-building, including through bilateral and regional instruments and programs. The emphases of this session is on the lessons learned from this capacity building efforts and the most pressing capacity-building areas, essential to be addressed going forward. The session will report on the results of the WBG/IMF consultations with developing countries on transfer pricing issues held in Washington DC in March 2016.

Chair: Marcio Verdi, Executive Secretary, CIAT

Marcio Verdi serves as CIAT Executive Secretary since 2010, working to promote cooperation among the organization's member countries, with priority focus on matters of international taxation, promotion of transparency, ethics and cooperation in the field of information technology applied to tax administrations. Prior to joining CIAT, Mr. Verdi spent 28 years in the Brazilian Government Administration, including as the General Management Coordinator of State-owned Companies, and General Tax Policy Coordinator. He has specialized in International Economics and Advanced Quantitative Methods in the University of Brasilia (UnB). He holds a Postgraduate degree in Theory and Implementation of a Modern Economy from the George Washington University (GWU).

Speaker: Richard Stern, Lead Tax Specialist, Global Tax Team, WBG

Richard Stern is Lead Tax Specialist for the World Bank Group’s Global Tax Team, as well as coordinating work on the international tax and tax transparency work on the team. The Global Tax Team works on reforming tax policy and administration to increase compliance by in all taxpayer segments, from SMEs to Multinational Enterprises, as well as fostering tax transparency for the entire tax system. He has also extensively worked on taxation in the extractives sector. Previously, Mr. Stern led the IFC’s Global Tax Team. Before that he was the Regional Program Coordinator for Africa at FIAS. He has worked extensively in Sub-Saharan Africa as well as in Eastern Europe and Asia, leading studies of barriers to investment as well as designing action plans for governments—especially in the area of tax policy and administration. Before joining FIAS in 2003, Mr. Stern was an economist at the International Monetary Fund for 8 years, working mainly on post-Soviet countries, the Balkans, Central African countries, and post-conflict countries. At the IMF he worked on monetary and fiscal issues, as well as debt reduction under the HIPC initiative. Mr. Stern holds a PhD in Economics from the University of California at Berkeley (1992), a MS in International Relations from Georgetown School of Foreign Service (1986), and a BA from Williams College (1983).

Presentation


Panel:

    José Alejandro Mejía Giraldo, Head of the International Audit Unit, National Taxes and Customs Direction (DIAN), Colombia

    Jose Alejandro Mejía is the Head of the International Audit Unit of the Colombian Tax Administration (DIAN). He has also served in the Colombian Tax Administration (DIAN) as Advisor to the General Tax Commissioner from December 2012 to November 2015, where he worked mainly on the International Tax Policy Issues, such as the negotiation of international tax treaties and the development of exchange of information instruments in Colombia. Before joining the Colombian Tax Administration (DIAN), he worked for a Colombian law firm and for the National Business Association of Colombia as advisor for tax law matters. Mr. Mejía serves as Colombian Delegate to international exchange of information groups in the OECD and in the Global Forum on Transparency and Exchange of Information for Tax Purposes.

    Davit Chitaishvili, Adviser, Department for International Relations Georgia Revenue Service, Georgia

    David Chitaishvili is an Adviser to the Head of the Department for International Relations at the Georgia Revenue Service (GRS). He holds a bachelors degree of Jurisprudence from Tbilisi State University and Master of International Business Law degree from Central European University, Budapest. He is in charge of drafting and negotiating International Agreements on behalf of GRS. As an adviser to the International Relations Department he is coordinating the involvement of GRS to the BEPS Project at different levels and he represents GRS at the Global Forum on Transparency of Exchange of Information (including Peer Review Group) as well as in several working bodies of the OECD.

    Michael Durst, Senior Fellow, International Centre for Tax and Development (ICTD)

    Michael Durst has been a member of the District of Columbia Bar for almost thirty-five years, and has practiced in the areas of international taxation and transfer pricing. He has taught in several U.S. law schools and has published widely in the area of tax problems of developing countries. In the mid-1990s he directed the IRS’s Advance Pricing Agreement Program, which issues rulings in the area of international transfer pricing. He has participated in technical assistance missions of the US Treasury and the IMF. Michael serves as a Senior Fellow of the International Centre for Tax and Development based at the University of Sussex in the United Kingdom.

3:30 PM
3:45 PM

Coffee Break

3:45 PM
4:30 PM

Offshore transfers of assets – Update on analysis

The session will summarize ongoing work on how offshore transfers of domestic assets are currently taxed, and how they should be taxed. This work is part of a joint project by the IMF, with the OECD, undertaken at the request of the G20 Development Working Group. The IMF and OECD will report to the G20 during the 3rd quarter of 2016.

Offshore transfers of assets occur when shares of a foreign company owning a domestic asset are sold in the foreign country. The domestic law of both countries, in addition to the provisions of tax treaties, if any, determines which country has the right to tax the capital gains from that sale, and whether that gain is taxed once, twice, or not at all. The presentation will summarize existing conditions, impacts on tax in developing and developed countries, and discuss a recommended framework for how these transfers ought to be taxed.

Chair: Jim Brumby, Director, Public Service and Performance, Governance Global Practice, WBG

Jim Brumby is a Director in the Governance Global Practice of the World Bank. He recently completed 2-1/2 years based in Jakarta, where he was Governance manager for the region, having transitioned from the job of Manager for the core Indonesia country economics program. He has been engaged on public management and economic reform at state, national and international levels for about thirty years, held management positions for the Treasury of the state of Victoria in Australia, the Treasury of New Zealand, the OECD, the IMF and, since 2007, at the World Bank. He holds an MPA from Harvard University.

Speakers:

David Wentworth, Fiscal Affairs Department, IMF

David Wentworth is a Senior Economist in the Tax Policy Division of the Fiscal Affairs Department of the IMF. He fields include international tax, financial institutions, natural resources, and general tax policy. Previously he was a Vice President at the American Council of Life Insurers, a staff economist in the Office of Tax Analysis at the U.S. Treasury, and a Senior Manager at KPMG. He holds degrees from Yale University and Sarah Lawrence College.

Presentation
Roberto Schatan, Fiscal Affairs Department, IMF

Roberto Schatan is a senior economist with FAD, where he advises member countries on tax policy, particularly on international tax issues. Before joining the IMF in 2011, he was a senior advisor at the Centre for Tax Policy and Administration at the OECD. Previously, he held different positions at Mexico’s Ministry of Finance; first, he was deputy general director for tax policy and later an advisor on tax reform to Mexico’s Minister of Finance. For a number of years he did a tour of duty at the Tax Administration Service where he was in charge of all aspects of transfer pricing.

Roberto obtained its B.A. from Sussex University (UK), and has graduate degrees in economics from UCLA (MA) and from the National University of Mexico (PhD).

Panel:

    Doris Akol, Commissioner General, Uganda Revenue Authority (URA)
    Case Study: Heritage Oil vs. URA

    Ms. Doris Akol has been serving as the Commissioner General of the Uganda Revenue Authority (URA) since October 2014. Prior to that she served as the URA’s Commissioner for Legal Affairs and Board Matters and the Company's Legal Secretary. Ms. Akol holds (L.L.M.) Degrees from McGill University Canada and Makerere University Kampala and is an Advocate of Uganda’s Courts of Judicature. She also has a Postgraduate Diploma in Financial Management from Uganda Management Institute Kampala.

    Presentation
    Dinesh Kanabar, CEO, Dhruva Advisors LLP, India
    Case Study: Vodafone Group PLC vs. Government of India

    Dinesh Kanabar is the ‎CEO of Dhruva Advisors, a leading tax and advisory boutique in India; prior thereto, he was the Dy CEO of KPMG in India. He has worked on some of the largest tax issues in India, including the Vodafone litigation. He has worked extensively with the Government on various tax advisory committees.

    Presentation
4:30 PM
5:15 PM

International tax issues and the extractive industries

Resource rich developing countries are under pressure to raise revenues to address the fiscal impact of the significant fall in commodity prices. These pressures, together with the heightened awareness of international tax planning, has led many governments to reconsider their extractive industries (EI) fiscal regimes. Particular focus is on profit shifting by multinational extractive companies, given the often higher tax burden on these companies, with governments considering greater use of fiscal instruments targeted at gross revenues rather than net profits. This session will consider the revenue impacts of profit shifting on the EI sector, and then discuss the international experience in addressing this issue through fiscal instruments. It will also consider the use of fiscal models, such as the IMF Fiscal Analysis for Resource Industries (FARI) model, in identifying the impact of profit shifting and evaluating the different fiscal instruments.

Chair: Ruud De Mooij, Deputy Division Chief, Tax Policy Division, FAD, IMF

Ruud de Mooij is Deputy Division Chief in the Tax Policy Division of IMF’s Fiscal Affairs Department. Before joining the IMF, he was Professor of Public Economics at Erasmus University Rotterdam. He has published extensively on tax issues, including in the American Economic Review and the Journal of Public Economics. His current research focuses on income taxation, international tax issues, and the corrective role of tax. Mr. de Mooij is also a research fellow at the University of Oxford, the University of Bergen, ZEW in Mannheim, and at the CESifo network in Munich.

Speakers:

    Peter Mullins, Deputy Division Chief, Tax Policy Division, FAD, IMF

    Peter Mullins is a Deputy Division Chief with the Tax Policy Division of the Fiscal Affairs Department of the International Monetary Fund in Washington DC. Peter has extensive experience in tax policy having been involved in the area for over 25 years. Prior to joining the IMF in 2005, Peter was the General Manager of the Business Tax Division in the Australian Treasury. He has worked in both the private and public sectors, including many years as a senior official in the Australian Tax Office.

    Presentation
    Jan Loeprick, Public Sector Specialist, WBG

    Jan Loeprick is a Public Sector Specialist of the World Bank’s Global Tax Team, covering a range of tax policy and administration issues. He previously coordinated IFC’s business taxation advisory portfolio in Eastern Europe and Central Asia. Jan also worked in the International Tax Department at the Austrian Ministry of Finance, and taught as a lecturer at Dresden University. He holds a PhD in Economics from the Vienna University of Business and Economics (WU) and an M.A. in International Economics and Development from Johns Hopkins (SAIS).

    Presentation

Panel:

    Alonso Segura Vasi, Minister of Economy and Finance, Peru

    Alonso Segura Vasi is the Minister of Economy and Finance of Peru, where he previously was Chief of Staff. He has been Chief Economist and Head of Strategy at Banco de Crédito del Perú (BCP), Peru´s largest bank; Chief Economist at Banco Wiese Sudameris (now Scotiabank Peru); Advisor to Executive Director for the Southern Cone and Economist at the Financial Affairs Department at the International Monetary Fund; among other positions. Mr. Segura is an Economist from the Pontificia Universidad Católica del Perú (PUCP). He holds a Masters degree in Economics from the University of Pennsylvania, where he also pursued doctoral studies (PhD (ABD)). He holds international certificates in investments (Chartered Financial Analyst-CFA) and risk management (Financial Risk Manager-FRM). He has held teaching positions at the University of Pennsylvania, the Pontificia Universidad Católica del Perú and Universidad del Pacífico in Peru. He is a Fulbright Scholar.

    Seth Terkper, Minister of Finance and Economic Planning, Ghana

    Seth Terkper is the Minister for Finance and Economic Planning of Ghana. He is a Chartered Accountant who holds a MPA degree from the Kennedy School, Harvard University. As a Deputy Minister in the MOFEP from March 2009 to January 2013, Mr. Terkper worked mainly on the Budget and Medium-Term Expenditure Framework (MTEF) as well as on revenue policy and administration. During the period, he became very active in working on government business in Parliament, including the passage of Bills and approval of International Agreements. He is a member of the Board of Directors of the BOG and chaired the joint Steering Committee of the Ghana Revenue Authority (GRA) and Ghana Integrated Financial Management Information System (GIFMIS) reforms. Between July 1999 and February 2009, Mr. Terkper held various positions (last as Senior Economist) in the Fiscal Affairs Department (FAD) of the IMF.

5:15 PM
5:30 PM

Concluding Remarks and Next Steps

Michael Keen, Deputy Director, Fiscal Affairs Department, IMF

Michael Keen is Deputy Director of the Fiscal Affairs Department of the International Monetary Fund, where he was previously head of the Tax Policy and Tax Coordination divisions. Before joining the Fund, he was Professor of Economics at the University of Essex and visiting Professor at Kyoto University. He was awarded the CESifo-IIPF Musgrave prize in 2010, delivered the 2012 Chelliah lecture at NIPFP in Delhi, is Honorary President of the International Institute of Public Finance (of which he was elected President from 2003 to 2006), and in 2008 was ranked the world’s leading author in public economics journals. He has led technical assistance missions to over thirty countries on a wide range of issues in tax policy, and consulted for the World Bank, European Commission, and the private sector. He has served on the Board of the National Tax Association in the U.S., and on the editorial boards of American Economic Journal: Economic Policy, International Tax and Public Finance (of which he was joint founder), Journal of Public Economics, the Review of Economic Studies and many other journals. He is co-author of books on The Modern VAT, the Taxation of Petroleum and Minerals, and Changing Customs. Recent publications also appear in the American Economic Review, Economic Policy, the Journal of Public Economics, Journal of Development Economics and the National Tax Journal.