The Irish Revenue must find ways to continue its staff reduction programme
while not risking the efficiency of its compliance work, the office has said
in its self-assessment paper.
The Office of the Revenue Commissioners collects taxes and protects the border.
The European Union/International Monetary Fund Programme of Support foresees
annual revenues of EUR42bn by 2014. The Revenue Commissioners are tasked with
collecting more than 90% of this money.
The recently released Comprehensive Review of Expenditure is focussed on cost
reduction, but also stresses the dependence of fiscal consolidation on the revenue
side of the equation. The paper reviews the Revenue’s strategies from
a cost reduction standpoint and also considers opportunities for revenue raising.
It is in the latter area that the Revenue believes it can make its biggest contribution
to the government’s objective of achieving sustainable public finances.
Also emphasized is the need for the Revenue to give attention to recession
specific risks to prevent base erosion, fraud and evasion, smuggling and tax
debt default. The paper says such risks include growth in the shadow/cash economy,
tobacco smuggling and oil laundering, extraction fraud/false repayment or losses
claims, deliberate under-declaration of income and profits and complex aggressive
tax planning structures being offered by practitioners in pursuit of business.
It warns that these risks have the potential to become entrenched, if not adequately
controlled.
Turning to the self-assessment portion of the paper, the Revenue states that
it has reduced its administrative costs by almost 20% since 2008, while this
year’s employment control framework (ECF) puts staffing back to the level
it was in 1976. In the run up to the recent economic crisis Revenue’s
taxpayer base (PAYE employees, self assessed income tax payers and companies)
had been steadily growing, up 35% from 2001-09. To respond to this growth staff
allocation increased by 2.9% from 6,407 staff in 2001 to 6,592 in 2008. Investments
in IT infrastructure and improved processes led to a 31.5% increase in the total
number of taxpayers per head of staff.
However, since 2008 the total customer base declined by 1%, while staffing
has reduced by 655, with another 560 staff expected to retire by 2014. These
factors have meant an 11% increase in the ratio of taxpayers per head of revenue
staff. The Revenue considers that its ECF of 5,678 foreseen for 2014 is already
risky, and too steep a reduction in the context of the real risks to compliance.
In addition, it argues that further ECF reductions make that risk much closer
to a certainty. The report concludes that increased non-compliance would more
than outweigh any savings on staff and, in fact, many revenue administrations
recruit additional staff in a recession because of the increased risks.
The paper therefore states that while it can deliver on the numbers proposed
of 5,678, it can do so only over a slightly longer period – by around
2015/16. It will also be done on the following basis: that it gets sanction
to recruit openly and from within to replace critical skills at the same time
as it reduces numbers; and that it may replace expensive IT consultants with graduate
recruits in a “spend-to-save” proposal. In addition, in the area
of non-pay expenditure, the paper states that the Revenue needs an ongoing adequate
IT budget to enable it to continue to take transactions out of the system, thereby
releasing staff for compliance work, and to enable it to improve risk analysis
so that it can target non-compliance more efficiently.
Despite this staff reduction, the report shows that the Revenue has maintained
its focus on maximising the collection of receipts and increasing the level
of collection for each euro invested. The cost of processing each item is continuing
to reduce, while electronic service channels continue to generate savings in
frontline staff numbers. Satisfaction with the Revenue remains positive, with
91% of survey respondents satisfied or very satisfied.
The paper states that a move to a cumulative basis of collection for the universal
social charge (USC), currently administered on a “week 1” basis,
could improve receipts by around EUR50m per annum. With supporting legislation
and adequate ICT resources, the Revenue feels this could be in place by 2012.
For an employer such a move would mirror PAYE arrangements and provide a platform
for further reducing their compliance burden. The IT cost of development is
EUR2.2m.
A widespread mandatory electronic filing of returns and payments regime has
been provided in recent Finance Acts. This new approach is currently in mid
stage and will be fully implemented by 2014. The Revenue is also developing
an online protocol for the capture of accounts information, using XBRL, which
it says will deliver benefits in terms of reduced administrative burden on business
and allow better risk analysis and intervention targeting for individual tax
entities across industry sectors. Bringing forward the certain filing dates
for tax and duties would improve revenue cash flow, but this is unlikely to
be implemented earlier than 2013.