3.1 The nature of emerging technologies and their impact on the tax profession and revenue authorities in other jurisdictions are considered in this chapter to better understand the underlying nature of the issues and likely best practice, providing a basis for the comparison with developments in this country. The jurisdictions examined are New Zealand, the UK, Canada, the Netherlands, Sweden, Finland, Estonia, Singapore, the Russian Federation, the USA and South Africa.

3.2 In order to gain a deeper appreciation, the IGT review team has researched available material and directly engaged with the above revenue authorities, where possible, to obtain further insights regarding their current or planned use of new technologies along with the expected roles, relationships and support to tax professionals in this journey.

3.3 The consideration of each country as a separate case study is instructive. Each jurisdiction has responded to changing technologies and social expectations with a unique approach specific to their circumstances and needs. Each revenue authority did not start from the same basis. They also do not necessarily share all the same views on the future state, which is perhaps not surprising. However, almost all of them share the common goals of digitising services and adopting a user-centred approach to designing and developing a single taxpayer file or account.106

3.4 The separate consideration of both the tax profession and revenue authority is important. Whilst points of intersection will arise, separate consideration of each facilitates a clearer comparative analysis between each party’s current and future functions.

New Zealand

The role of tax professionals

3.5 The national revenue authority in New Zealand is the Inland Revenue Department (IRD). The IRD considers that tax practitioners or tax agents significantly contribute to the efficient operation of their tax system and will continue to play a key role in assisting the community to navigate the future tax administration.107

3.6 The IRD currently provides a range of support services to tax agents including dedicated account managers, dedicated phone services and access to client information held in IRD’s online service, ‘MyIR’.108

3.7 The IRD supplies every listed tax agent with an account manager to provide support and assistance, including:109

  • Relationship management: a centralised point of contact for specific issues to facilitate resolution of exceptional issues and complaints as well as negotiate and update status.
  • Education and information: to actively provide support and increase awareness of the self-service tools IRD provides, keep tax agents informed with information updates and provide reports which cannot be accessed through self-service.
  • Compliance and monitoring: register and monitor tax agents to ensure they are meeting their legislative and compliance requirements.

3.8 As part of registering new tax agents, the IRD is required by legislation to maintain a list of tax agents, although the list is not made publicly available.110 Where it is detected that tax agents do not meet their obligations under the required guidelines or legislation, account managers can:111

  • withdraw extensions of time;
  • negotiate interim guidelines and dates; or
  • remove them as a listed tax agent.

3.9 In practice, it is rare for the IRD to delist or refuse to list a tax agent.112 It has been suggested that more regulated tax agent rules, such as those in Australia, would be beneficial. However, it is considered that any tax integrity benefit is outweighed by higher compliance and administrative costs.113

3.10 Tax agents are encouraged to manage their clients’ tax obligations using the IRD website and the various self-service options available, including:114

  • MyIR Secure Online Services which allows tax agents to manage their clients’ tax affairs such as linking clients, transferring credits and payments, viewing clients’ earnings information, balances and transactions;
  • E-File which facilitates the direct transmission of data directly from their own computer to IRD systems;
  • tax agent’s self-service line, a dedicated telephone service which they can use to confirm client earning information, check the status of a refund and link clients for example; and
  • StationeryXpress which can be used by tax agents to request access to stationery produced by the IRD.

Technological and future developments

3.11 The IRD is currently undergoing a business transformation process, which is a multi-stage change program, aimed at streamlining its processes, policies and customer services as well as upgrading its technology program.115

3.12 During the transformation, the IRD has shifted away from building and maintaining infrastructure to using standard off-the-shelf software solutions.116 It has actively sought assistance from a wide range of third party providers, spending $211 million on contractor and consultant services. For example, in February 2016 the IRD entered into a 10-year contract with Spark and its subsidiary Revera to provide data centres and associated services.117 To upgrade the IRD technology program, IRD is using a FAST GenTax product, which is a commercial off-the-shelf solution providing specialist functionality for revenue authorities. In implementing this product, the IRD has worked closely with the Finnish tax authority who also uses this product and has successfully completed the first implementation in January 2016.118 The new systems are being run in parallel to legacy systems for several years as a risk mitigation strategy.119

3.13 The IRD has also leveraged technological developments such as APIs and facilitates collaboration with third parties. In March 2016, the IRD made the first API available for submitting GST returns and since that time, additional APIs have been released.120

3.14 Software providers are encouraged to register with the IRD. They can do so by providing certain information to the IRD. They are also required to self-assess whether they meet a range of technical specifications and consent to a criminal history check. Registering allows software developers to gain access to a range of services, including those offered to tax agents.121

3.15 As part of its transformation, the IRD has also recently undertaken a major structural review of its operations. For some years, individuals have not been required to lodge an income tax return if they only earn salary and wages and pay the correct amount of tax.122 Under legislation currently before Parliament, the IRD will automatically calculate and issue refunds and bills where the Commissioner of Inland Revenue is reasonably satisfied that the income reported from third parties is the customer’s only income. The legislation also includes proposals to extend some of the online services currently available to tax agents to other intermediaries such as bookkeepers.

3.16 The IRD anticipates that the investigations and compliance areas, which currently comprise approximately 1,200 Full Time Equivalent (FTE) employees may be impacted in the future by the increased use of data analytics which will inform its knowledge and identification of potential issues.123 In fact, its current workforce is expected to be reduced by 25 to 30 per cent as part of transitioning the capabilities to better meet the needs of the future.124

3.17 To assess the progress of IRD’s transformation, a rigorous program of independent quality assurance reviews is conducted.125 The latest review was conducted by KPMG in August 2017 to assess its readiness to complete the next stage of implementation. KPMG found that:

… the Programme continues to be well managed as it progresses towards both its short and long term goals. Programme control remains good (indeed in many areas the programme continues to be among the most effective we have seen), and generally, the Programme continues to demonstrate the characteristics of a high performing team …126

3.18 In relation to tax agents, the IRD expects that even though the nature of services provided to their clients will change in the future, they will continue to have a vital role in shaping compliance outcomes.127 To enhance access to IRD tax agent services, tax agents in the future may have better access to information held by the IRD about their clients and any actions the IRD may be taking. It is believed that such a change would enable tax agents to work in ‘real time’ and reduce tax time pressures.128

3.19 The IRD will also be seeking to determine what services are most important to tax agents, what additional services may assist them in their future role and what they would like the IRD to consider in designing more digital service offerings for tax agents and other tax service providers in the future.129

3.20 The IRD plans to support the tax profession in adapting to changes so that they can continue to meet their obligations and their client’s needs.130 For example, from mid to late 2017, the IRD focused on building awareness and understanding of recent changes amongst service providers, software developers and tax agent professional bodies by increasing face-to-face, video and digital engagement through social media, webinars and apps.131

United Kingdom

The role of tax professionals

3.21 HMRC believes that tax agents will continue to play an important and integral role in the future tax system but, as technology drives change in the tax system, they may focus more on complex issues and assisting taxpayers to comply with their tax obligations rather than on administrative tasks.

3.22 It is estimated that approximately 72,000 tax agent firms are currently acting on behalf of 12 million individuals and businesses. Most businesses, including approximately 86 per cent of small and mid-size businesses, engage the services of tax agents preferring to spend time running their business than dealing with the complexities of taxation.132

3.23 Knowing that many taxpayers rely on tax agents, HMRC has made a strategic decision to welcome the use of those agents to represent customers where they add value in helping their clients get their tax right.133 HMRC is of the view that the ‘one-to-many’ relationship between agent and client offers great potential.

3.24 The key pillars of HMRC’s Agents Strategy are:

  • providing digital services for agents which allow them to see and do what their clients can see and do;
  • raising professional standards in the tax agent market; and
  • enabling agents to add greater value to the tax system through a range of services and compliance approaches.

3.25 Through its Making Tax Digital (MTD) program, HMRC has built the digital foundations for the above strategy, and already has a range of services available to agents, including a real time digital service for clients to authorise new agents to act on their behalf.

3.26 HMRC also provides agents with expert curated information on complex technical matters and is working towards enabling them to see and do what their clients can see and do digitally. The role of the tax agent is also built into the design of new digital services and compliance work.

3.27 The tax profession in the UK is self-regulated through a number of professional bodies. Approximately two-thirds of tax agents are estimated to be members of one or more professional bodies. Several of these bodies jointly own a set of standards called the Professional Conduct in Relation to Taxation (PCRT). The PCRT was updated in March 2017 to make clear that members must not engage in tax avoidance arrangements.

3.28 Approximately one-third of tax agents are not affiliated with a professional body. They are only subject to ‘regulation’ by HMRC who applies a standard which complements the PCRT.134 HMRC is currently discussing with the profession how to ensure common standards are set and enforced across the whole of the tax services market, including firms which are not members of professional regulatory bodies.

3.29 Options are being explored for strengthening the above regulatory framework. This includes HMRC’s use of existing powers, amongst which is disclosure of information to the professional bodies about members whose conduct is unacceptable. As the Second Permanent Secretary of HMRC has noted that:135

… the more we can get agents up that value chain, the more we can remove the need for those [compliance] interventions; and the more agents can sit down with clients and deal with compliance risks themselves, by taking a broader view of what’s in the best interests of a client.

3.30 HMRC is also considering options for differentiating service provision for tax agents to support this aim.

Technological and future developments

3.31 Following extensive consultation, HMRC is introducing MTD for Business. There is estimated to be £9 billion tax lost due to error and carelessness each year in the UK and such digitisation should assist in alleviating this issue.

3.32 From April 2019, all VAT registered businesses with a taxable turnover above the VAT threshold (currently £85,000) are required to keep digital VAT business records and send their VAT returns to HMRC using MTD compatible software.

3.331 Respondents to the original consultation supported the move to a digital tax system, but had concerns about the pace of change and the capability of small businesses to adapt. As a result, the Government announced in 2017, that MTD will not be made mandatory for other taxes until at least 2020. MTD for income tax is available now on a voluntary basis.

3.34 It is believed that the move to digital integration will eliminate many of the existing paper based processes, allowing businesses and their agents to devote more time and attention to maximising business opportunities, encouraging growth and fostering good financial planning.

3.35 HMRC recognises that many businesses and agents choose to use third party software over HMRC's own digital services, and the majority of online lodgements are via software products designed by a community of approximately 600 developers. Accordingly, as part of its third party tax software and API strategy, HMRC has significantly increased the support given to third party software developers. It has created an API Developer Hub providing developers with a ‘one-stop shop’. More sophisticated APIs are also being released and developers are being provided with operational and relationship management support. The intent is to ‘enable more third party products to carry out more tax functions and in greater detail’, providing a better experience for all taxpayers and improving compliance as the inclusion of business rules and validation within the APIs is reducing the amount of errors.

3.36 Similar to New Zealand, software developers must register with HMRC on the API Developer Hub. HMRC conducts a number of checks before approving their registration which gives the developer access to ‘production APIs’. They cannot access production APIs without being approved.

3.37 In addition to APIs, HMRC has had successes in using robotics to automate tax processes. For example, tax refund claims submitted online are now handled by a robot that processes simple cases in full including writing back to the taxpayer and adding an audit trail to HMRC's records. More complex claims are referred for manual handling.

3.38 HMRC has also begun looking at use cases for AI and blockchain. It has introduced a 24-hour online assistant, called Ruth, who is available to provide guidance on tax queries — where necessary, queries may be referred to an actual tax officer. With respect to blockchain, its Chief Technology Officer has stated that a ‘slow-and-go-approach’ has been adopted due to security concerns, regulatory oversight and reputational risk.

Canada

The role of tax professionals

3.39 Canada’s tax administrator, the Canada Revenue Agency (CRA), values the role that tax professionals play in the tax system. This was highlighted in 2014 when the CRA and Chartered Professional Accountants of Canada (CPA of Canada) signed a framework agreement calling for an enhanced working relationship.136 The CRA and the CPA of Canada engage in open and collaborative dialogue, including the use of a working committee as a feedback mechanism to improve program delivery.137

3.40 The CRA has a Tax Professionals webpage which provides a broad range of information, including latest news items affecting tax professionals and how they may use CRA services.138 It also has a ‘Represent a Client’ portal which provides registered tax preparers with access to their client’s tax information, depending on the authorisation provided by the client.139

3.41 The CRA has implemented a 3-year pilot project whereby a dedicated telephone support line provides small and medium income tax service providers with increased access to CRA income tax technical information through which they can assist their clients.

3.42 On 14 January 2014, the CRA issued a consultation document entitled Proposal – Registration of Tax Preparers Program (RTPP). As a part of the proposal there were extensive cross country consultations with the tax practitioner community. Having regard to the feedback, the CRA undertook further research and analysis to determine the level of systems and legislative changes that would be required to implement the RTPP.

3.43 As the CRA’s research found that significant investment would be required to implement the RTPP as originally designed, it is now considering other options that would serve to implement the objectives of the proposed RTPP, through existing CRA programs, in a more cost-effective manner.

3.44 At the end of 2016, the CRA held a series of forums with professional accountants as well as small to medium enterprises (SMEs), called the ‘Serving You Better (SYB)’ consultations, to determine ways in which government services can be adapted to their needs.140 Further SYB consultations were held with small and medium businesses and professional accountants in 2018 to find ways to improve its programs and services. These consultations are a key component of the CRA’s commitment to delivering enhanced federal government services to SMEs.

Technological and future developments

3.45 The CRA has implemented an e-services modernisation strategy aimed at allowing Canadians to interact with them digitally and securely. This strategy seeks to improve ‘digital service options to provide end-to-end, modern e-services, which are fast, easy, and secure’.141

3.46 The CRA also allows third party software providers to access the APIs it has developed. This has resulted in development of software which has facilitated online lodgment of a significant number of income tax returns.142 In addition to being able to lodge an initial return, the CRA’s ReFILE service enables individuals and EFILE143 service providers to send online adjustments for income tax and benefit returns with certified software. Although it does not automate tax returns to the extent where lodgment is not required, it offers a service called ‘Auto-fill my return’ which allows individuals and authorised representatives to automatically fill in parts of an income tax and benefit return with information that the CRA has available at the time of lodgment.144

3.47 The CRA has also made progress in relation to real-time processing of their income tax and benefit returns. The CRA’s Express NOA service enables individuals and authorised representatives to view and print the notice of assessment in their EFILE or NETFILE-certified145 tax preparation software after the return has been received and processed by the CRA, usually within a matter of seconds after lodgment.

3.48 Further technological development opportunities were announced as part of the Budget 2017, in which the Government of Canada announced the creation of an independent research facility for artificial intelligence. Canada’s Finance Minister has stated that:146

Technology is changing fast, and with it comes opportunity. By encouraging cutting-edge technology like AI while at the same time creating a culture of lifelong learning, we will be with Canadians every step of the way as they lead us into a future filled with possibility.

3.49 The establishment of this facility may open up opportunities for the CRA to assess the benefits that AI may offer.147

The Netherlands

The role of tax professionals

3.50 At the Organisation for Economic Cooperation and Development’s (OECD) Forum on Tax Administration in Cape Town, a Deputy Commissioner of the Netherlands’ Tax and Customs Administration (NTCA) observed that tax intermediaries play a pivotal role by endorsing compliant behaviour and transparency and thus can become trustworthy stakeholders for tax authorities.148

3.51 In 2005, the NTCA introduced a ‘horizontal monitoring’ program to enhance relationships and endorse compliance arrangements with large taxpayers. This program enables large businesses to commit themselves to ‘tax control frameworks’ which provide the NTCA with increased confidence that those businesses are in control of their tax compliance.149 Tax practitioners play a large role in the development and maintenance of these frameworks.

3.52 The NTCA also offers cooperative compliance with tax practitioners who serve large businesses and SMEs.150 These cooperative compliance arrangements are concluded between the NTCA and tax practitioners.151 The arrangements enable the NTCA to reduce the level of supervision on participating taxpayers, for example through conducting a limited number of randomly selected audits.152 To determine the suitability of tax practitioners for co-operative compliance arrangements, the NTCA considers whether there is mutual trust, transparency, understanding as well as an appropriate level of co-operation and delivery of outcomes.

3.53 The NTCA considers the horizontal monitoring program a success as the tax returns submitted by taxpayers under the program have been more accurate than those not under the program. Nevertheless, the NTCA has noted that improvements can be made to the program as, to date, only 140,000 SMEs (through approximately 350 tax service providers, including two of the Big 4 accounting firms) participate in Horizontal Monitoring.153

3.54 A key advantage of cooperative compliance to the taxpayer is that relevant tax risks and positions can be discussed and the NTCA’s views obtained efficiently. Its disadvantages are said to include the fact that the approach taken may depend on the individual tax inspector in the absence of objective criteria that are yet to be developed.154

3.55 In the Netherlands, there is no legally imposed regulatory scheme for tax practitioners. However, there are two strong private organisations that impose strict rules on their members, the de Nederlandse Orde van Belastingadviseurs (The Dutch Order of Tax Advisors) and de Nederlandse Federatie van Belastingconsulenten (The Dutch Federation of Tax Consultants).155 There are also organisations such as the Samenwerkende Registeraccountantants en Accountants-administratieconsulenten (SRA), an association of accountancy firms that specialise in the SME sector, which set professional standards and oversee the quality of the work of their members. It has been noted that this model would be difficult for other countries to follow as it relies on time and tradition.156

Technological and future developments

3.56 A few years ago, the NTCA sought to invest in its future and explored how Big Data could be used to complement its compliance activities. Insights gained from analytics and opening up data sources were considered in conjunction with AI and machine learning. In 2017, the NTCA commenced a project to digitise processes that had previously been paper based. These new processes are being designed to reduce the need for manual input in low-risk tasks.

3.57 In the Netherlands, income tax returns can only be lodged electronically.157 Individual taxpayers, with simple tax affairs, are presented with a largely pre-filled income tax return. If they agree with the pre-filled information, they can sign the document electronically and submit it. Pre-fill is not currently available for business taxpayers or individual taxpayers with more complex affairs.158 The NTCA is currently looking to work with software developers to enable pre-filling of tax returns for SMEs.159

3.58 The NTCA is also examining possible uses of AI in virtual assistance, dialogue support and cognitive search which would enable its website to respond to specific questions rather than search terms. The use of virtual assistance is also available to NTCA staff.

3.59 In addition to the work on AI, the NTCA is also undertaking proofs of concept on potential uses of blockchain technology, particularly in relation to payroll tax. One such project involves enabling employers and employees to execute ‘smart contracts’ held on the blockchain.160 The NTCA uses the data transmitted on the blockchain to calculate and collect the tax owing and then allocate the net payment to the employee. This approach effectively removes the involvement of the employer once the contracts are finalised.161 The NTCA is also offering funding to start-ups to explore other uses of blockchain on their behalf.162

3.60 The NTCA and the tax profession, including accountants, software providers and bookkeepers, have recently developed a joint online platform called ‘Secure Online’. The platform aims to improve knowledge sharing amongst members of the tax profession.163

Sweden

The role of tax professionals

3.61 The role of tax professionals in Sweden, similar to those in other Scandinavian countries, is not typical to that in most OECD jurisdictions. The number of taxpayers that seek assistance of a tax agent is low. The Skatteverket or Swedish Tax Agency (STA) notes that the main type of assistance sought by businesses is bookkeeping support.

3.62 Approximately 78 per cent of income tax returns and 89 per cent of VAT returns are lodged electronically with the STA. The STA provides individual taxpayers with completely prefilled income tax returns. Recent statistics show that approximately 76 per cent of individual taxpayers make no changes to their prefilled income tax returns, preferring to accept the information from the STA. Deductions are possible although the threshold for such claims is high (10,000 Swedish Krona or approximately AUD $1,571) and taxpayers are required to demonstrate that the expenses are directly related to earnings.164

Technological and future developments

3.63 The STA foresees that in the future more Swedish businesses will be able to get electronical assistance for bookkeeping and taxation purposes. The STA plans to support the development of digital and automated communications by developing APIs so other parties can connect to their systems.

3.64 The STA also intends to utilise AI and RPA to improve its services in the future although it acknowledges that in order to implement these technological changes, staff with the appropriate skillsets such as mathematics and data analytics will need to be recruited.165

3.65 The STA has developed e-services for tax compliance and has released APIs for third party software developers to provide software that connects with those e-services.166 The STA has been collaborating with a range of software developers to enhance the quality of lodgments and the data that it receives. For example, it has been working with software developers to better integrate SME bookkeeping software with lodgment services that feed into its systems.167 Such collaboration is expected to reduce the cost of the STA maintaining and developing its own software.168

3.66 In relation to system stability and outages, the STA indicated that although it is rare for it to experience system outages, it does provide compensation if it has caused direct financial loss. The compensation scheme is enshrined in legislation and STA compensation decisions are reviewable by the courts.169

3.67 The STA is also considering a project to convert tax legislation into a machine-readable format, enabling decisions to issue automatically without any judgment having to be exercised by STA employees.170 This will involve examining opportunities to simplify the legislation and its requirements.

Finland

The role of tax professionals

3.68 Similar to Sweden, individual taxpayers in Finland do not generally need to use the services of tax professionals. However, Finland’s revenue authority, Vero Skatt (VS) estimates that approximately 75 to 80 per cent of the SMEs are using the services of tax professionals.171

3.69 VS does not currently have a register of tax professionals. However they expect that in the first half of 2019, they would have implemented a system for the authorisation and registration of tax professionals.172

Technological and future developments

3.70 The main objective of VS, along with all other Finnish government agencies, is to digitise the service offerings to the community.173 Since 2013, VS has been conducting a major program to improve the flexibility of its tax processes, tax legislation and to replace its 70 current IT applications with one core application, namely FAST GenTax.174 This program was introduced after discovering that its IT maintenance costs were increasing whilst performance was not improving. The program is currently on schedule to be completed by 2019.175

3.71 VS expects that having one core application will result in significant simplification, increased work productivity, reduced system maintenance costs and shorter implementation timeframes.176 VS has delivered extensive training to explain to its staff the reasons for changes being made and how their daily work would be impacted.177

3.72 In addition to implementing GenTax, VS is also replacing almost all eServices with one off-the-shelf solution called MyTax.178

3.73 As part of the nationwide imperative to digitise, several other programs are being implemented across all government agencies. These programs include:179

  • X-Road which exchanges information between basic registers maintained by government agencies;
  • ‘Suomi.fi’ messages for communicating securely with other government agencies; and
  • ‘Suomi.fi’ eAuthorisations which enables corporations to authorise certain individuals to act on their behalf.

3.74 The VS also seeks to foster cooperative relationships with software developers through ongoing consultation and meetings180 as well as an online portal and mailbox to respond to questions.181

3.75 The VS also expects that by 2020, it would be digitally accessible to all taxpayers at all times including being a single point of access through which taxpayers can view and change their tax information as well as offering services such as income tax registrations, real time VAT data collection and online payment functions.182

Estonia

The role of tax professionals

3.76 Estonia’s tax administration, the Estonian Tax and Customs Board (ETCB) indicates that individual taxpayers are generally able to perform tax operations without the assistance of tax professionals. However, the services of tax professionals are used when more complicated processes are involved.183

3.77 The electronic lodgment of income tax returns has been mandated in Estonia since the 1990s.184 In 2015, a survey of taxpayers indicated that 95 per cent of all tax returns were filed online.185 It is estimated that the average taxpayer only requires three minutes to file their income tax return as they are only required to confirm that the information within the return is correct and add information where necessary.186

3.78 An automated accounting software called ‘e-Financials’ has also been developed for SMEs by the Centre of Registers and Information Systems (also known as RIK) within the Ministry of Justice.187 The software consists of five modules: settlements, accounting, reporting, personnel and settings modules. The accounting module is a key part of the software which enables SMEs to execute transfers, keep a logbook and a general ledger, check balances and calculate fixed assets.188

Technological and future developments

3.79 Since the 1990’s, Estonia has invested heavily in digitalisation. The transformation that has occurred since then has been driven by Estonia’s vision to achieve a modern, paperless, efficient and forward-thinking government.189

3.80 The provision of digital services in Estonia relies on the following three interdependent pillars:190

  • X-Road is a single shared platform that links all databases and services from different government departments and private sector organisations along with internet banking through the largest Estonian banks. Each registry has an authorised owner who is responsible for its maintenance and security.
  • Electronic ID enables all users to identify themselves using digital signatures to access services from the public and private sectors.
  • Platforms which provide access to more than 800 services, leveraging off X-Road. All individuals can view who has accessed their data and why, as there is an audit trail of all access and change to the data.

3.81 The ETCB’s digital transformation and its usage of the above three pillars have been commended by many tax authorities around the world. For example, Estonia featured in first place in the 2016 Digital Public Services index of the European Commission’s Digital Progress Report.191

3.82 In 2008, the Estonian government began testing the benefits of blockchain, particularly in relation to cyber security. In 2012, blockchain was applied widely amongst government registries.192

3.83 In relation to APIs, in 2014, the ETCB launched a new strategy to address tax fraud which required each business transaction over £1,000 to be declared monthly by the relevant entities. To enable the transfer of information, an API that allows information to be exchanged between the company’s accounting software and the state’s tax system was developed.193

3.84 ETCB also has a solid cooperative relationship with several software developers. By involving software developers at an early stage, the ETCB can determine if concepts being considered are feasible and enter the development stage being better informed.194

Singapore

The role of tax professionals

3.85 The Inland Revenue Authority of Singapore (IRAS) values tax agents as its ‘partners in the administration of the Singapore tax system’.195 Their importance is due in part to the valuable insights they gain from the close relationships with their clients.196

3.86 Due to the common interest of ensuring tax compliance and facilitating business growth, the IRAS has established a framework for an enhanced relationship with tax agents that is mutually beneficial and balanced. It is built on openness, transparency and trust.197

3.87 The above principles are supported by the following strategies:198

  • profiling tax agents;
  • facilitating growth of tax agent competence;
  • improving communication and service; and
  • enhancing consultation and collaboration.

3.88 To achieve the goals under the enhanced relationship, the IRAS helps tax agents to deliver greater value to their clients by providing a one-stop platform that allows authorised tax agents to have an overview of their clients’ corporate tax matters, including the status of the clients’ tax returns and tax assessments, and to perform transactions on behalf of these clients. The IRAS has also created a webpage especially for tax agents to provide updated information about key changes in tax policy or administration rules. The IRAS actively consults tax agents in the ‘designing of policies, refining of rules and even crafting of legislation via surveys, consultations and focus group sessions’.199

3.89 In 2006, the IRAS in collaboration with the Big 4 accounting firms, the Institute of Singapore Chartered Accountants and the Law Society of Singapore established a Tax Academy to raise professional competency of the tax community by offering training programs, seminars and conferences on tax technical issues for tax professionals.200 To further support tax practitioners in this regard, in 2009, the IRAS set up a fund to subsidise the cost of attending such training programs.201 The fund has since been fully utilised, and was closed in 2013, at the end of its intended 5-year run.

3.90 An accreditation body for tax professionals, the Singapore Institute of Accredited Tax Professionals (SIATP), was established in 2010. It aims to raise the standards of tax practice in Singapore through accreditation and continuing professional education. The President of the Institute of Certified Public Accountants of Singapore and chairman of SIATP has stated that:

With more cross-border businesses and an increasingly complex tax environment, demand for highly-skilled tax professionals will increase. SIATP will play a vital role in ensuring tax professionals are equipped with the right skills, which is imperative in an increasingly globalised business environment.202

Technological and future developments

3.91 Between October 2014 and September 2016, the IRAS conducted a pilot for IBM Watson’s Virtual Assistant, Ask Jasmine. Ask Jasmine received a total of 123,699 questions from 48,667 conversations. Through natural language processing and cognitive capability, it was able to answer questions with higher variation than had been planned.203

3.92 Despite the benefits, including the overall improvement over other virtual assistants, significant effort was required to maintain content and to train Ask Jasmine. For example, due to the time difference between Singapore and the USA, where the IBM Watson maintenance team was located, there was a delay in servicing IRAS requests. As a result, during peak periods, IBM deployed local personnel to assist with urgent requests.

3.93 The IRAS also noted that during the pilot, there were noticeable improvements to the ability of Ask Jasmine to accurately answer questions. However, there were still limitations to its cognitive capabilities. For example, it did not have contextual memory and was therefore unable to recall the context of a previous question or conversation. Following the end of the pilot, the IRAS made the final decision to onboard Ask Jamie as part of the Whole-of-Government direction for public service agencies. The Whole-of-Government virtual assistant enabled IRAS to leverage common capabilities and retrieve answers from cross-agency knowledge bases for a more seamless experience for citizens.

3.94 To mitigate risks of cyber security, hacks and identify theft, a number of measures have been implemented204 including Digital IDs for individuals and businesses. A further authentication system has been implemented for certain services such as tax filing that are considered more sensitive.205 Another initiative is the use of text-mining techniques to analyse emails from taxpayers to assist in pre-empting or reducing contact with IRAS as well as improve service delivery for taxpayers.206

3.95 In 2016, the IRAS organised a Hackathon as part of the Government’s agenda to adopt a more citizen-centric approach when providing public services. The Hackathon brought about the coming together of start-ups, developers, tax and accounting professionals, industry experts, students and IRAS’ staff to ‘co-create new solutions to deliver taxpayer-centred experiences for SMEs, the self-employed and individual taxpayers’.207

3.96 In light of the importance of accounting software in helping businesses comply with their tax obligations, the IRAS has maintained an Accounting Software Register (ASR) on its website. Software developers are able to apply to IRAS to have their accounting software listed on the ASR by demonstrating that their software meets a set of IRAS’ technical requirements.208

3.97 In an attempt to improve staff productivity, the IRAS has also recently piloted the use of robotics to automate manually intensive processes.209

Russian Federation

The role of tax professionals

3.98 In Russia, individual taxpayers are only required to lodge an income tax return if they have to declare non-employment income or if they are claiming tax deductions.210

3.99 Over 97 per cent of all tax and 100 per cent of VAT returns are lodged electronically with the Russian Federal Tax Service (FTS).211 Since the early-2000s, many business taxpayers have been utilising commercial off-the-shelf accounting software to file their own tax returns.212

Technological and future developments

3.100 Since 2010, a ‘digital first’ strategy has been more rigorously pursued by the FTS.213 A key initiative has been the development of a central database which uses a common structure for all taxpayers and links them into relevant systems. In 2011 the FTS conducted a study on the issues inhibiting communication with taxpayers. The results helped it to adapt its communication strategy.214

3.101 In December 2012, inspired by the work of the OECD Forum on Tax Administration on horizontal monitoring, the FTS introduced a horizontal monitoring pilot. In relation to the value of the pilot, a Deputy Commissioner of the FTS said:

The pilot projects on Horizontal Monitoring evidence the fact that the tax authorities are ready for constructive cooperation with taxpayers. Such cooperation will contribute to the improvement of Russia’s attractiveness for international investors. Application of the Horizontal Monitoring approach will lead to the development of a culture of paying taxes and lead to a reduction of tax disputes. The tax authorities will be able to react promptly to uncertain issues in tax legislation and make the procedure of tax calculation and payment more convenient for taxpayers.

The pre-litigation methods of tax dispute resolution have proven their effectiveness: since 2009 the total amount of tax litigation cases has declined annually by 15-20%, while the number of cases won by the tax authorities has increased. The Russian tax authorities are ready to apply, in practice, enhanced relationship mechanisms that are used in many OECD countries.215

3.102 As part of the pilot, the FTS signed agreements with large taxpayers including a leading energy company, the largest telecommunications group and one of the largest power-generating companies. The pilot focused on developing enhanced relationships between the FTS and taxpayers based on transparency, trust and cooperation.216

3.103 A key innovation of the FTS has been the implementation of a system which enables the monitoring of VAT compliance on a nationwide basis in real time. The system is ‘based on automatic cross-matching of all VAT paid with all VAT claimed across all transacting parties.’217 The system enables the FTS to ‘zoom-in’ on particular transactions or VAT taxpayers to automatically identify related tax risks and to initiate a VAT audit where necessary. The system also enables the FTS to monitor the performance of tax inspectors and their respective local and regional offices.218

3.104 The implementation of the above system was made possible following legislative amendments which mandated the digital lodgment of all VAT returns, VAT invoices and ledgers as well as the construction of new information technology infrastructure in the form of data processing centres.219 In 2014, 2015 and 2016, the FTS reported increases in VAT collection of 16.8 per cent, 12.4 per cent and 8.5 per cent, respectively.

3.105 In February 2017, the FTS commenced transition to mandatory online cash registers. Cash registers, used by organisations or individual entrepreneurs, transmit sales information, in real time, directly to the FTS and upload it to its data processing centres. The receipt can be provided to the customer electronically or in paper form.220 It is a legislative requirement that each of these receipts has a scannable QR-code which enables taxpayers to verify the transaction by comparing it to the FTS’ records.221

United States of America

The role of tax professionals

3.106 The principal national revenue authority in the USA is the Internal Revenue Service (IRS). There is presently little regulatory oversight of tax agents or tax preparers, as they are known. Accordingly, regardless of education, knowledge or experience, any person can offer tax return preparation services. As a direct result, it has been commented that millions of incorrect or inaccurate income tax returns are lodged each year.222 Recent attempts of the IRS to expand its regulation of non-professional tax preparers have been short-lived. In Loving v IRS,223 the court concluded that the IRS had limited statutory authority to regulate non-professional tax preparers.224

Technological and future developments

3.107 The IRS’ ‘Future State’ plan aims to improve its ability to enhance and expand services for all taxpayers over the next five years and beyond. Consistent with developments in the majority of OECD countries, the IRS wants to decrease the time and effort required by taxpayers and tax professionals to interact with it.225

3.108 In support of providing its citizens with free lodgment services, the IRS has partnered with the Free File Alliance, a non-profit coalition of leading tax software companies. Approximately 70 per cent of taxpayers are eligible to use Free File.226 The IRS’s website provides links to each of these free file software providers’ websites as well as a ‘Free File Software Lookup Tool’ to determine which software a taxpayer will be eligible to use.227

3.109 Some commentators have observed, however, that the uptake of the Free File options has been low with only approximately 3 per cent of all eligible lodgments being made through these programs since 2003.228 Furthermore, limited awareness by taxpayers eligible to use these free options and the difficulties associated with locating them have also contributed to low adoption rates. It has also been observed that in entering the agreement with the Free File Alliance, the IRS has effectively been prevented from developing its own free software offerings or to explore opportunities to pre-fill and push returns to taxpayers.229 The IRS also invites software developers to register with them. To register, software developers are required to complete an online account and then apply to become an authorised provider if they anticipate filing more than 11 of certain forms during a calendar year.230 The process to become an authorised provider involves the IRS conducting a suitability check, which may include tax compliance, credit and criminal background checks on each person listed in the application as well as the relevant entity.231

3.110 Academics in the USA have urged Congress to regulate tax preparation software companies. They argue that this would ‘lead to more accurate tax returns, protect taxpayers, and ensure a fairer and more efficient tax system’.232 They note that at present, apart from the IRS’ minor verification requirements such as requiring software companies to update tax rates and calculations, tax return software companies are largely granted free rein. Generally, the IRS does not test to ensure that guidance provided by tax return preparation software companies is accurate.233

3.111 Despite the focus on the expansion of online services, the IRS believes that in the future it will be important to maintain a human element. Accordingly, the IRS Commissioner has stated that ‘while technology and new service options are important parts of Future State, you can’t overlook the continuing need to have in-person service available to taxpayers over the phone and in-person’.234 The National Taxpayer Advocate (NTA) has also highlighted the potential inappropriate outcomes resulting from automation noting that:

… as IRS employees rely more heavily on computer programs to flag returns for audit or to waive penalties for reasonable cause, they are losing the ability to discern when the programs have made a mistake. For example, she said, the IRS tested employees in a case in which a penalty should have been waived for reasonable cause although the computer program determined that it should not have been, and none of the participating employees were able to identify cases in which the penalty clearly should have been waived under the applicable regulations or case law.235

South Africa

The role of tax professionals

3.112 The South African Revenue Service (SARS) is the national revenue agency for South Africa. Tax practitioners in South Africa provide a range of advisory and lodgment services to their clients. SARS has stated that it ‘places great value on a healthy professional relationship with Tax Practitioners who are key in providing a service to our clients the taxpayers’ and has therefore committed to:236

  • engaging with practitioners continuously and constructively;
  • providing access and channels to practitioners;
  • specific service offerings to registered practitioners; and
  • providing specific communications for practitioners.

3.113 SARS provides a range of services to tax practitioners who are listed on its website together with the appropriate channel through which those services may be accessed.237

3.114 Similar to Australia, tax practitioners in South Africa are required to be registered. All individuals who provide advice or assist others with lodgment under relevant tax legislation are required to be registered with both the SARS238 and a Recognised Controlling Body (RCB).239

3.115 The requirement to register with both the SARS and an RCB was intended to give effect to a ‘framework that will make sure that tax practitioners are properly qualified and that a mechanism is available, both to taxpayers and SARS, to address misconduct.’240

3.116 All RCBs are required to maintain minimum qualifications and experience requirements, continuing professional development (CPD) requirements, a code of ethics and conduct as well as disciplinary processes and procedures.241 The latter is particularly important as any complaints (including those from the SARS itself) regarding the conduct of a tax practitioner are made to, and investigated by, the RCB under its own rules.242

Technological and future developments

3.117 The main technological offering from the SARS is eFiling:

… a free, online process for the submission of returns and declarations and other related services, for more information visit the 
eFiling Services page. This free service allows taxpayers, tax practitioners and businesses to 
register free of charge and submit returns and declarations, make payments and perform a number of other interactions with SARS in a secure online environment.
243

3.118 The eFiling system provides a range of different services for tax practitioners which are not necessary for individual taxpayers.244 Additionally, the SARS has also released two linked pieces of software aimed at assisting employers deal with a range of obligations including payroll as well as for taxpayers and intermediaries to report dividend transaction data.245

3.119 SARS has stated that ‘the eFiling service is on par with international standards, being comparable with services offered in the USA, Australia, Singapore, Ireland, Chile and France’.246 Furthermore, SARS has indicated that as eFiling matures, it intends to expand the services that are able to be offered on that platform.247


106 OECD, Technologies for better tax administration: A practical guide for revenue bodies (2016) pp 36-41.

107 Inland Revenue Department (IRD), Future Role of Tax Agents - Towards a New Tax Administration Act (undated) <http://www.taxpolicy.ird.govt.nz>.

108 Ibid.

109 OECD, Tax Administration 2015: Comparative information on OECD and other advanced and emerging economies (2015) p 272.

110 IRD, Tax agents – List of tax agents (undated) <http://www.ird.govt.nz>.

111 Ibid.

112 Above n 107

113 Ibid.

114 Ibid.

115 IRD, Business transformation – about business transformation (2 August 2017) <https://www.ird.govt.nz>.

116 Ibid.

117 IRD, July 2017 Transformation Update – Implementing Stage 2 of the future revenue system (July 2017) p 20.

118 IRD, Transforming Inland Revenue (2016) <www.ird.govt.nz>.

119 IRD, Communication with the IGT (10 November 2017).

120 IRD, Transforming Inland Revenue (2015) <www.ird.govt.nz>.

121 IRD, Software developers – New to working with us (2 June 2017) <https://www.ird.govt.nz>.

122 IRD, Individual Income Tax (2010) <http://www.ird.govt.nz>.

123 IRD, Communication with the IGT (10 November 2017).

124 Above n 117, p 19.

125 IRD, Business transformation (30 Aug 2017) <http://www.ird.govt.nz/transformation>.

126 KPMG, Inland Revenue – Independent Quality & Technical Assurance – Business Transformation Programme (August 2015).

127 Above n 107.

128 IRD, Making Tax Simpler - Towards a New Tax Administration Act – A Government Discussion Document (November 2015) p 65.

129 IRD, Towards a New Tax Administration Act – Overview (undated) <https://taxpolicy.ird.govt.nz>.

130 Above n 117, p 15.

131 Ibid, pp 16-17.

132 Above n 73, p 61.

133 GOV.UK, HMRC Strategy 2017 (undated) <https://www.gov.uk/>.

134 GOV.UK, HMRC: the standard for agents (undated) <https://www.gov.uk/>.

135 Jim Harra, Q&A: HMRC’s plans on working with tax agents (4 March 2015) 1253 Tax Journal <https://www.taxjournal.com>.

136 Chartered Professional Accountants Canada (CPA Canada), CRA and CPA Canada sign framework agreement to enhance working relationship (26 November 2014) <https://www.cpacanada.ca>.

137 Above n 73, p 100; CRA, Framework Agreement – Canada Revenue Agency and Chartered Professional Accountants of Canada (11 December 2014) <http://www.cra-arc.gc.ca/taxprofessionals/>.

138 CRA, What’s new for tax professionals (undated) <https://www.canada.ca>.

139 Above n 109, p 273.

140 CRA, Summary of the Corporate Business Plan 2017-18 to 2019-20 (10 March 2017) p 5.

141 Ibid, p 23.

142 Treasury Board of Canada Secretariat of Canada, Government of Canada, API Strategy Enabling a Digital Service Revolution with Canada’s Vision for Government as a Platform (Draft for Discussion April 2017).

143 EFILE is an automated service that allows approved tax preparation service providers and discounters to send individual income tax return information to the Canada Revenue Agency (CRA) directly from EFILE–certified tax preparation software.

144 CRA, About Auto-fill my return (2017) <https://www.canada.ca/>.

145 NETFILE is an electronic tax-filing service that allows you to send your individual income tax and benefit return directly to the Canada Revenue Agency (CRA) using the Internet and a NETFILE-certified software product.

146 Department of Finance Canada, Growing Canada’s Advantage in Artificial Intelligence (30 March 2017) <https://www.fin.gc.ca>.

147 Ibid.

148 Filipa Correia and Rudolf Reibel, Change of Climate in Taxation: Are You Prepared for Extended Responsibilities? (Report from the 6th CFE Professional Affairs Conference in Milan, 22 November 2013) p 270.

149 Ibid

150 Ibid.

151 Ibid.

152 Above n 73, pp 43-44.

153 Netherlands’ Tax and Customs Administration (NTCA), Communication with the IGT (18 December 2017). There are two variants of cooperative compliance (also called horizontal monitoring). They have same starting points: mutual trust between the taxpayer and the tax authorities, precise specification of each other's responsibilities, mutual understanding and transparency. In respect of very large companies, individual agreements (or convenants) are concluded. In this variant, the company itself is responsible for fiscal risk management and the correctness of the tax returns. As smaller companies are more dependent on the support of tax service providers for providing acceptable tax returns, these companies can make use of the tax service providers variant of horizontal supervision. The quality of the tax returns is then guaranteed by the tax service provider. Tax service providers must meet strict quality requirements to participate in this program. They determine which of their clients may wish and be entitled to participate in horizontal monitoring.

154 PwC, Doing Business in the Netherlands 2017 (2017) p 18.

155 Victor Thuronyi and Frans Vanistendael, ‘Regulation of Tax Professionals’ in Victor Thuronyi (ed), Tax Law Design and Drafting (International Monetary Fund, 1996) 1, p 3.

156 Ibid.

157 Belastingdienst, How to file a tax return (undated) <www.belastingdienst.nl>.

158 NTCA, Communication with the IGT (18 December 2017).

159 Above n 73, p 40.

160 Above n 33, pp 41-42.

161 Ibid.

162 NTCA, Communication with the IGT (18 December 2017).

163 Above n 73, pp 40, 71.

164 NTCA, Communication with the IGT (18 December 2017).

165 NTCA, Communication to IGT (7 September 2017).

166 NTCA, Communication to IGT, (7 September 2017 and 7 August 2018).

167 Above n 73, p 122.

168 NTCA, Communication to IGT (7 September 2017).

169 NTCA, Communication to IGT (18 December 2017).

170 NTCA, Communication to IGT (7 September 2017).

171 Vero Skatt, Communication to IGT (9 January 2018).

172 Vero Skatt, Communication to IGT (9 January 2018).

173 Amelia Schwanke, ‘Tax technology: A brave new world’ (23 August 2016) International Tax Review <http://www.internationaltaxreview.com>.

174 Vero Skatt, Communication to IGT (9 January 2018).

175 OECD, Tax Administration 2017: Comparative Information on OECD and other advanced and emerging economies (2017) p 49.

176 Ibid.

177 Ibid, p 50.

178 This product is different to the MyTax product that has been developed by the ATO.

179 Vero Skatt, Communication to IGT (9 January 2018).

180 Vero Skatt, Communication to IGT (9 January 2018).

181 Vero Skatt, Communication to IGT (9 January 2018).

182 Above n 173.

183 Estonian Tax and Customs Board (ETCB), Communication to IGT (15 December 2017).

184 Helen Margetts and Andre Naumann, Government as a Platform: What Can Estonia Show The World? (Research Paper, University of Oxford) p 13.

185 E-Estonia, e-Tax (undated) <https://e-estonia.com/solutions/business-and-finance/e-tax>.

186 Ibid.

187 eRIK Centre of Registers and Information Systems, e-Financials - About the service (unknown) <www.rik.ee>.

188 Ibid.

189 Ergo Ottoson, Monika Nikitina-Kalamee and Natalja Gurvits, ‘The role of Accountant in the Estonian Enterprise’ (2016) 5(2) Central European Business Review 47-56.

190 Above n 184, p 5.

191 Above n 189.

192 E-estonia, We have built a digital society and so can you (undated) <www.e-estonia.com>.

193 Dan Bogdanov, Marko Joemets, Sander Siim and Meril Vaht, How the Estonian Tax and Customs Board Evaluated a Tax Fraud Detection System Based on Secure Multi-party Computation (2015) <https://fc15.ifca.ai/preproceedings/paper_47.pdf>.

194 ETCB, Communication to IGT (15 December 2017).

195 Inland Revenue Authority of Singapore (IRAS), Enhanced IRAS-Tax Agent Relationship (17 August 2017) <https://www.iras.gov.sg&gt;.

196 Ibid.

197 Ibid.

198 Ibid.

199 Above n 195.

200 Tax Academy of Singapore, Mission and Corporate Goals (2015) <https://www.taxacademy.sg/about.html>.

201 IRAS, Annual Report 2008/09 (2009) p 8.

202 Dr Ernest Kan, Speech at the official launch of the Singapore Institute of Accredited Tax Professionals (7 May 2010) <www.iras.gov.sg>.

203 IRAS, communication to IGT (21 November 2017).

204 IRAS, communication to IGT (21 November 2017).

205 Above n 106, p 82.

206 OECD, Advanced Analytics for Better Tax Administration: Putting Data to Work (2016) p 27.

207 IRAS, IRAS Hackathon 2016 <http://upsingapore.com/events/iras-hackathon/>.

208 IRAS, Guide on Accounting Software (for Software Developers), <www.iras.gov.sg>.

209 Peter Green, ‘Talking to the OECD: Tech disruption in tax administration’ (2017) 28(5) International Tax Review 23.

210 Ibid.

211 Ibid.

212 Ibid.

213 Above n 210.

214 Ibid.

215 Sergei Arakelov quoted in Alexandra Lobova, ‘Horizontal monitoring pilot brings enhanced relationship to Russia’ (2013) 24(2) International Tax Review 16, 16.

216 Lobova, Ibid.

217 Above n 109, p 101.

218 Ibid.

219 Above n 109, p 101.

220 Schneider Group, The new law on transition to cash register equipment allows the tax authorities to track cash payments online – Newsletter (28 October 2016) p 1.

221 Above n 109, p 60.

222 Jay A Soled and Kathleen DeLaney Thomas, ‘Regulating Tax Return Preparation’ (2017) 57 Boston College Law Review 151, 152.

223 Loving v IRS, 742 F .3d.

224 Jamie Hopkins, Loving v. IRS’s Achilles’ Heel for Regulated Tax Advice? (2014) Virginia Tax Review 34, 191.

225 IRS, Tax Professionals Provide Insights on IRS Future State; Feedback Efforts Continue in 2017 as Online Account Shows Strong Early Use (21 December 2016). <https://www.irs.gov/newsroom>.

226 Free File Alliance, Free File (undated) <https://freefilealliance.org/>.

227 IRS, Free File Software Offers (undated) <https://apps.irs.gov/app/freeFile/jsp/index.jsp>.

228 Tik Root, ‘Why Are Millions Paying Online Tax Preparation Fees When They Don’t Need To?,’ ProPublica (18 June 2018) <https://www.propublica.org>.

229 Root, Ibid; ProPublica, Liz Day, ‘How the Maker of TurboTax Fought Free, Simple Tax Filing,’ ProPublica (26 March 2013) <https://www.propublica.org>.

230 IRS, E-File for Tax Professionals (2018) <https://www.irs.gov>.

231 IRS, Become an authorized e-file provider <www.irs.gov>.

232 Above n 222, p 152.

233 Above n 222, p 177.

234 IRS, Tax Professionals Provide Insights on IRS Future State; Feedback Efforts Continue in 2017 as Online Account Shows Strong Early Use (21 December 2016) <https://www.irs.gov/newsroom>.

235 Alexander Lewis, ‘Big Data could help tax authorities profile all taxpayers,’ Worldwide Tax Daily (4 May 2018).

236 South African Revenue Service (SARS), Welcome to the Tax Practitioners Webpage (1 June 2018) <http://www.sars.gov.za>.

237 SARS, Service offerings per channel for tax practitioners (undated) <http://www.sars.gov.za>.

238 Tax Administration Act 2011 (South Africa), ss 240 and 240A.

239 Tax Administration Act 2011 (South Africa), s 240A.

240 SARS, Controlling Bodies for Tax Practitioners (27 March 2018) <http://www.sars.gov.za>.

241 Tax Administration Act 2011 (South Africa), s 240A.

242 Tax Administration Act 2011 (South Africa), ss 241, 242, 243.

243 SARS eFiling, What is eFiling? <http://www.sarsefiling.co.za/AboutPage.aspx>.

244 See for example: SARS, Guide for Tax Practitioners on eFiling <www.sars.gov.za>.

245 SARS, E@syfile (8 August 2018) <www.sars.gov.za>.

246 SARS EFiling, About us – Services offered <www.sarsefiling.gov.za>.

247 Ibid.