NOVEMBER 2017


       GOVERNANCE NOTES
                                                         No.4                                                                     APRIL 2019
                                                                                                                                       No.15

        Domestic Resource Mobilization Community of Practice



PAKISTAN CUSTOMS: MOBILIZING DOMESTIC
REVENUES FOR ECONOMIC DEVELOPMENT
Prepared by Anna Custers and Richard Sutherland, Governance Global Practice


The government depends on the ability of Pakistan Customs to           A MODERN CUSTOMS
play a significant role in mobilizing domestic revenues, which         In most countries, the customs administration performs at least
contribute to the country’s economic development. However,             four basic functions. Firstly, it collects revenue for the government,
the predominant focus on the agency’s revenue objective                a function which has traditionally been prioritized by many
appears to constrain its utilization of facilitation measures          developing countries because import duties are “easy” to collect.
that are necessary to expand trade and help the country                Secondly, it protects domestic producers and provides supply chain
develop. This Governance Note explores pathways Pakistan               security. Thirdly, it plays a key role in facilitating legitimate trade
Customs may take to facilitate trade without compromising its          through the timely release of goods at the borders. Finally, customs
collection of payable duties and taxes. It proposes three reform       protects societies by preventing the importation of prohibited,
options for consideration: enhancing the risk management               dangerous, and unsafe goods (Wulf and Sokol 2005).
system; improving pre- and post-clearance facilities; and              	 The responsibilities of customs are evolving. The fast-growing
contributing to the broadening of the tax base. Taken together,        and increasingly competitive global environment demands
implementing these reforms could accelerate the advancement            gradually more effective and efficient border control without
of Pakistan Customs, building on its relatively strong cargo           compromising the cross-border movement of goods. Consequently,
management and revenue control capabilities.                           the challenge is how to manage the increased volume of trade
                                                                       while safeguarding revenue, protecting infant and local industries,
OVERVIEW                                                               ensuring border security and compliance, and facilitating trade at
Domestic resource mobilization (DRM) is vitally important to           the lowest possible cost to the budget and trading community.
Pakistan today. Fiscal and current account pressures have              To respond to this increasingly globalized environment, a modern
widened substantially, and tax revenues are on the priority reform     customs agency “must organize itself to be a trade facilitator in a
agenda (World Bank 2017). While Pakistan’s ratio of tax to gross       rapidly changing world, as well as an efficient provider of revenues”
domestic product (GDP) rose steadily to 12.5 percent (FY17) — a        (Wulf and Sokol 2005).
significant 3 percentage points above the earlier 9.5 percent          	 Yet, most customs and finance ministries across low- and
(FY11) — it is still well below the 15 percent tax-to-GDP ratio that   middle-income countries often consider whether there is a trade-
is thought to be critical in meeting the basic needs of citizens and   off between revenue collection and trade facilitation (Raballand et
businesses (Gaspar, Jaramillo, and Wingender 2016). Customs            al. 2009). Revenue control is often guaranteed through systematic
revenues account for more than 45 percent of overall tax revenues      inspections and checkpoints, relying heavily on physically
and are essential for Pakistan’s effort to increase its DRM.           controlling the cargo. When excessive, this control in turn negatively
	 Reliance on customs for revenue collection, however, impacts         impacts trade facilitation by increasing the dwell time and costs for
the business environment. The World Bank Group’s 2019 Doing            traders. It may also introduce corruption into the system through
Business Report ranked Pakistan 136 out of 190 economies for           multiple contact points. Reducing physical control of cargo — which
ease at doing business and 142 for trading across borders. As this     would facilitate trade — on the other hand is perceived to reduce
Governance Note will show, customs relies heavily on controls          control on revenue collection.
such as physical examinations that appear to affect the general        	 The perceived trade-off is influenced by the relatively low
business climate in Pakistan. While a trade-off is perceived           administrative capacity and low compliance environment
between reducing controls to facilitate trade and increasing           typical of developing countries. In these countries, tax systems
revenue collection, ample examples show this hypothetical              are characterized by a persistent and high reliance on indirect
trade-off does not exist in developing countries. It is possible to    taxation as opposed to direct taxation, with an important role
drastically reduce controls and generate more revenues at the          for trade taxes and collection at the border. As a rationale for
same time. This note will offer concrete suggestions for Pakistan      border tax collection, trade taxes are considered “revenue-efficient”
Customs to achieve this dual goal.                                     when administrative capacity is constrained and compliance is


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                                                                                                                                                                     No.15



deemed low because information about the tax base is readily                                     is widely recognized that many aspects of interest to customs
observable and controllable.1 Large leakages of revenue might result                             cannot be detected through the traditional singular examination
from reliance on the domestic market for taxation when the                                       of all (or a majority of) customs declarations. Moreover, to
administrative capacity of tax authorities is limited and taxpayers                              uncover indiscretions such as valuation verification, fiscal evasion,
are noncompliant.                                                                                smuggling, and customs fraud, it is often necessary to examine a
     In this context, trade facilitation measures offered by customs,                            trader’s entire international trading pattern as well as domestic
for instance under a reform program, could be interpreted as                                     transactions.
loosening controls and lead to a reduction of information critical to                            	 Consequently, measures such as advance rulings, authorized
tax collection. This is particularly the case when no strong domestic                            economic operators, risk management, and post-clearance
tax net is present. As a result, national treasuries might not be                                audits are needed more and more to not only speed up clearance
willing to endorse this kind of reform because of the uncertainties                              procedures and reduce the need for physical inspections (especially
it might impose on revenue collection. A similar trade-off is unlikely                           for low-risk traders), but also to increase the likelihood of detecting
to be perceived in high compliance, high administrative capacity                                 fraud (UNCTAD 2016). If properly implemented, administrative
environments. In these environments, the majority of the revenue                                 measures like these could preserve revenue and concurrently
collection occurs in the domestic market while borders have the                                  facilitate trade by reducing the time and cost to comply with border
primary role of securing the country and facilitating licit trade.                               requirements.
     Ample evidence exists, however, that this perceived trade-off
between revenue collection and trade facilitation does not exist                                 SITUATIONAL ANALYSIS
in developing countries. For example, in Madagascar, a fragile                                   Current Role of Pakistan Customs in DRM
economy and the world’s fifth poorest country, declarations cleared                              A decomposition of historical public revenue data reveals a
through the red channel (physical inspections) were reduced from                                 persistent reliance on customs to collect a sizable portion of
60 percent to 20 percent and, in the meantime, revenues increased                                taxes in Pakistan. Table 1 shows that customs-collected revenue
drastically. This increase in tax revenue was driven by trade volume,                            constitutes a substantial portion of Pakistan’s total tax revenue.
with a reduction in average delays, an increase in the number                                    For the last decade, duties and taxes collected at the country’s
of import declarations, and greater tax revenue per declaration                                  borders represented over 40 percent of national revenue on
(Raballand et al. 2017).                                                                         average. This observation is consistent with trends in other
     It is possible, therefore, for customs in developing countries to                           countries at comparable levels of development. For example, the
collect substantial revenue and simultaneously implement trade                                   customs administrations for middle-income countries in Africa
facilitation measures. While for developing countries the revenue                                similarly collect over 40 percent of government revenue on average.
function continues to be by far the most important customs                                       However, the average contributions of customs to tax revenue in
function, it is possible to become more efficient at it and facilitate                           the South and Southeast Asia region is lower, at an average of 27
trade. Considering the ever-expanding global environment, it                                     percent (see figure 1).


    Table 1. Customs Revenue as a Percentage of Total Tax
    Revenue, FY2010–17

     Fiscal         Duty          Sales Tax on            Income Tax                Additional   Regulatory     Excise      Other     Total Customs         Total Tax
      Year                          Imports               Withholding               Sales Tax      Duty                                  Revenue            Revenue
                     (%)               (%)                    (%)                      (%)          (%)           (%)        (%)            (%)           (PRe, millions)

    2010–11         12.0               20.9                     5.0                    0.2           0.3          2.4        2.9           43.7             1,327,384

    2011–12          11.9               24.6                    5.5                    0.7           0.2          2.5        2.3           47.5             1,558,013

    2012–13         10.4               20.4                     5.6                    0.9           0.2          1.8        2.7            42.1            1,882,694

    2013–14         10.5                23.2                    6.4                     1.1          0.2          2.0        2.6           46.0             1,939,424

    2014–15          11.3              22.9                     6.4                     1.1          1.0          0.9        3.9           47.6             2,254,531

    2015–16         11.8                24.3                    6.8                     1.1          1.8          0.4        5.2            51.4            2,589,979

    2016–17          11.5               21.2                   6.1%                    1.0           2.0          0.3        5.2           47.3             3,112,472

Source: Data from Pakistan Customs, Federal Board of Revenue, 2017.

1
 Bachas, P., A. Jensen, and F. Tourek. “International Trade, Domestic Production
Networks, and Indirect Taxes: Evidence from Rwanda.” Unpublished manuscript, last
modified June 2018.
                                                                                                                                                                            2
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                                                                                                                                                                               No.15



Figure 1. Customs: A Global Snapshot




                                      SOUTH AMERICA,                                                                                                           FAR EAST, SOUTH AND
                                                                                                                           NORTH OF AFRICA,
                                      NORTH AMERICA,                  WEST AND                       EAST AND                                                    SOUTH EAST ASIA,
                                                                                                                              NEAR AND           EUROPE
                                     CENTRAL AMERICA                CENTRAL AFRICA                SOUTHERN AFRICA                                               AUSTRALASIA AND
                                                                                                                             MIDDLE EAST
                                    AND THE CARIBBEAN                                                                                                          THE PACIFIC ISLANDS

Number of Customs                              68.5                           1.2                          7.4                   6.1               171.7                92
Declarations
(million)                                      26.2                           0.1                          7.3                   1.7               97.2                115.7

Percentage of                                 85.2%                         85.5%                         92.7%                 100%              85.9%                91.6%
Electronic
Declarations                                  87.3%                         89.6%                         95.8%                 100%              91.9%               93.6%

Contribution of                                27.2%                        40.3%                         37.1%                 44.4%             25.8%                27.4%
Customs to Tax
Revenue

Source: WCO 2017.                                                                                                 import
Note: Reproduced with permission from WCO with the following disclaimer —
numbers are aggregate figures based exclusively on information provided by                                        export
members.



Pakistan’s Trading and Business Environments                                                                 underwent physical examinations that lasted 16 hours on average.
Strong dependency on customs-collected revenue is a concern                                                  Worse yet, few seizures were found through those inspections (less
for trade facilitation and thereby Pakistan’s business climate. The                                          than 2 percent), which suggests controls are ineffective. Import
2019 Doing Business Report ranked Pakistan at 142 out of 190                                                 values for the red channel were adjusted 18.4 percent of the time.2
economies for trading across borders, which was a significant                                                Moreover, pre- and post-clearance facilities or fast track channels
improvement in comparison to earlier years, but remains a                                                    are rarely utilized. Shortcomings in the execution of these and other
challenge. For example, it is more expensive, by more than 200                                               core functions are negatively affecting the regulatory environment
percent ($256), to comply with border requirements for importing                                             for businesses in Pakistan, as evidenced by its rank of 136 out of
when compared to more competitive neighboring economies such                                                 190 for ease of doing business.
as Singapore. Singapore only collects 15 percent of tax revenue at                                                In summary, Pakistan Customs’ apparent focus on revenue
the border and levies no customs duties (WCO 2017).                                                          control may be at the cost of trade facilitation. As figure 2
	 A deeper look reveals that the high transaction cost of                                                    illustrates, Pakistan is among those countries that are classified
trading with Pakistan corresponds with lengthy port-site                                                     in the upper-right quadrant of the graph, which all feature high
processes to which most shipments are subjected. For example,                                                customs-collected revenue relative to total tax revenue as well as
physical examinations are excessive, and documentary reviews                                                 low scores in trading across borders. In contrast, countries that rely
are numerous. During FY2016–17, about 46.9 percent of goods                                                  the least on customs-collected revenue also tend to be associated
declarations (GDs) were cleared through the red channel and                                                  with more efficient cross-border movement of goods.

2
  Adjusting import values signals weak compliance by traders through under invoicing. It also acts as a
distortionary measure to trade facilitation when valuation rulings are complex and outdated, as is the
case in Pakistan.                                                                                                                                                                     3
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                                                                                                                                                                                                                                                                      No.15



     Figure 2. Association Between Customs-Collected Revenue and
     Facilitating Trade Across Borders

                                                                                                                                                                                                                                                   Income
                                               80                                                                                                                                                                                                       High Income
                                                                                                                                                                  Comoros                                                                               Low Income

                                                                                                    Kosovo                                                                           Uganda                                                             Lower-Middle Income
                                                                                        Moldova                                                                  Mozambique
                                                                                                                                                                                                                                                        Upper-Middle Income
                                               70




                                               60

                                                                                                                                 Haiti
Revenue Collection by Customs in Tax Revenue




                                                                                                                                                                              Togo
                                                                                                                                                                                                        Samoa
                                                                                                                                 Fiji                    Belize
                                               50                                                                                                                      Cambodia
                                                                                                                                                                                         Guinea-Bissau
                                                                                                                                                                                                                       Guinea
                                                                                                                                                           Tonga
                                                                             Serbia                                                                                                            Madagascar
                                                                                                                                                                                                                                Afghanistan
                                                                          Bulgaria                                                                                                              Guyana
                                                                                                                          Mauritius
                                               40                                                                                                                           Paraguay
                                                                                                       Jordan
                                                                                                                                 Nepal       Mali                                                                          Pakistan
                                                                                                                                                                                                          Zimbabwe
                                                                                                                                     Costa Rica
                                                                                      Switzerland
                                                                                                                   Mexico
                                                                                                                                             Rwanda                                       Senegal
                                               30                                                                                                                        Malawi
                                                                                                                Israel
                                                                                         Greece                                                        Tunisia                                           Zambia                         Cameroon
                                                               Poland                                                                                                Mongolia
                                                                                        Finland                          Chile
                                                                                                                                                                                                         Uruguay
                                                     France                    Bhutan                                Thailand
                                                                                                                                                                                          South Africa          Maldives
                                               20              Spain                         Panama
                                                                                                                                                                                       Benin
                                                                                      Singapore                             Turkey

                                                                                           Canada
                                                                                                                                                                  Indonesia                                                Bangladesh
                                                                                                        Ireland
                                               10              Netherlands

                                                    Romania                                Germany                                                                                             Brazil

                                                                        Lithuania                                                                   Australia

                                                       Italy                                        United States                                                                                                                     Angola
                                               0                        Sweden



                                                       0                     20               40                  60                    80                100                 120               140                 160               180

                                                                                                                                     Trading across Borders

     Sources: WCO 2017; World Bank Group 2017 Doing Business Indicators.
     Note: While more recent Doing Business results are available, for purposes of
     comparison, 2017 results are used.


     To better understand what effective levers for reform may be to                                                                                                  decades ago, taxes on dutiable goods constituted a significant
     improve trade facilitation without losing revenue, it is useful to                                                                                               portion of total revenue, about 44 percent in 1990.3 In stark
     examine why the two outcomes of relatively high collection of                                                                                                    contrast, duties (including regulatory duties) represented less
     revenue at the border and poor trade facilitation are emerging.                                                                                                  than 13.5 percent of tax revenue in FY2016–17 (see table 1). This
     	 At least three underlying factors are identified. Firstly,                                                                                                     figure is average for the country’s level of development.
     Pakistan Customs continues to play a key role in DRM, albeit                                                                                                         Notwithstanding the sharp decline in import duties as a
     tariffs are reducing. Administering taxes at the border is easy,                                                                                                 share of revenue, Pakistan Customs collects a sizable portion
     comparatively. Consistent with international trends, Pakistan                                                                                                    of noncustoms and sales taxes at the border — nearly 30
     is reducing its reliance on import duties to boost trade. Three                                                                                                  percent). Imports appear to be used as a convenient “tax

     3
                   World Bank Open Data, accessed at https://data.worldbank.org/.

                                                                                                                                                                                                                                                                              4
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                     handle.” More generally, Pakistan relies disproportionally on tax           assessed and paid, regardless of whether this causes delays in the
                     collection from federal sources as compared to the provinces,               release of imports (Wulf and Sokol 2005).
                     which are responsible for sales tax on services and have been               	 Thirdly, the focus on preserving revenue and physically
                     underperforming on this front.4 This implies that the pressure to           controlling goods occurs against a background of significant
                     collect taxes from customs duties, federal sales taxes on goods,            increases in volumes of trade. The World Bank estimated that
                     and personal income tax is very high compared to provincial sales           Pakistan’s Import Volume Index increased by about 50 percent
                     taxes on services.                                                          between 2002 and 2014. Correspondingly, the number of
                          Given a relative weak ability to tax goods and people in the           import and export GDs increased by 41 percent and 64 percent,
                     domestic market, a large share of this responsibility to collect tax        respectively, between 2010/11 and 2016/17, whereas the value
                     revenue has shifted to customs. Since imported goods cannot                 per goods declaration has risen by 14 percent and 17 percent,
                     be landed until liable duties and taxes are paid, border taxes —            respectively.
                     whether in the form of import duties, sales tax, or income tax —
                     are relatively easy to collect and difficult to avoid. Consequently,        Achievements and the Remaining Challenges
                     customs has been consistently collecting more than 40 percent               Pakistan Customs uses a robust information technology (IT)
                     of total tax revenue (figure 3). This reliance on indirect taxation         system to cope with growing trade volumes and ensure its
                     at the border, however, has increased the burden on imports as              focus on protecting revenue through maximum cargo control.
                     illustrated by the Doing Business indicator.                                Since its introduction in 2011, the Web-Based One Customs
                                                                                                 (WeBOC) system has significantly improved the efficiency and
                     Figure 3. Customs Collection as a Percentage of Total Revenue,              effectiveness of customs operations in Pakistan, eliminating some
                     FY2000/01 to FY2016/17                                                      of the most vulnerable points of a manual system. An automated
                                                                                                 selectivity system helps the Customs office manage the growing
                              0,7
                                                                                                 volumes of trade, which accounts for more than 1.8 million of
Share of total FBR revenue




                              0,6                                                                processed GDs annually (1 million for imports and 0.8 million for
                              0,5                                                                exports).
                              0,4
                                                                                                 While the current risk management system (RMS) does enable
                              0,3                                                                customs to identify which GDs to examine and which to release,
                              0,2                                                                risk–based targeting of suspect consignments is limited. A key
                               0,1
                                                                                                 issue is that the RMS is not very efficient at identifying (major)
                                                                                                 misclassifications, misdeclarations, or threats to sanctity and
                                0
                                                                                                 security of international supply chains. For example, in addition
                                20 /09
                                20 /03

                                20 /04

                               20 05



                                20 /07

                                20 08
                                20 /01




                                20 /10
                                20 02




                                20 /06




                                                                                                 to the high proportion of GDs selected for examination, the
                                20 16
                                20 13

                                20 4

                                20 15



                                        7
                                20 11

                                20 2




                                     /1
                                     /1
                                      /




                                    /1
                                     /
                                     /




                                     /



                                     /



                                     /

                                     /
                                   00




                                  08
                                  06




                                  09
                                  03

                                  04
                                  02




                                  07
                                  01




                                  10




                                  16
                                  13



                                  15
                                  14
                                  12
                                  05




                                  11
                                20




                                                                                                 RMS does not guide examiners to be more targeted with their
                     Source: Data from Pakistan Customs, Federal Board of Revenue (FBR), 2017.   inspections, as it lacks a complete risk profiling for all authorized
                                                                                                 operators. The result of this is a low number of seizures (less than
                       Secondly, Pakistan Customs relies heavily on excessive physical           2 percent). In addition, no annual post-clearance audit plan is in
                       controls to safeguard revenues. The focus and frequency                   place to systematize the detection of misdeclarations post entry
                       of control mechanisms seem geared toward minimizing                       into the country.
                       undervaluation. For instance, Pakistan Customs adjusted the
                       aggregate value of self-declared taxes and duties by 18.4 percent         More generally, Customs has not exploited the full potential
                       for GDs that were cleared through the red channel in FY2016–17.           of WeBOC, as it still relies heavily on high levels of physical
                       These adjustments yielded 1.91 percent in additional revenue for          examinations and revenue-biased controls. For example, WeBOC
                       the Federal Board of Revenue — PRe 59,530,359,831, which is               is typically applied only after goods have arrived in the country,
                       equivalent to $567 million. Similarly, in the same period, 20.6           and it does not permit pre-arrival clearance. Added to this, no
                       percent of GDs were processed through the yellow channel                  mechanisms are in place to migrate from physical to post-
                       wherein the declared amount of duty and taxes was raised by               clearance control. In addition, there is limited use of data mining
                       3.54 percent, amounting to PRe 7,963,290,903 ($75.8 million).5            and exchange of electronic information with other public agencies
                       These high rates of physical and documentary inspection delay             to draw up risk profiles. As a result, the prospect of preparing
                       the clearance of goods and are also cumbersome, expensive                 relevant and comprehensive profiles is greatly reduced.
                       activities to engage in, particularly when trade volume is high.
                       Like other customs at this level, it seems a control mentality has        REFORM OPTIONS AND RELATED POLICY CHANGES
                       permeated in Pakistan Customs that ensures that all duties are            A few observations can be made. First, reforming customs is

                      4
                             World Bank Open Data, accessed at https://data.worldbank.org/.
                      5
                             Based on interviews with Pakistan Customs officials.
                                                                                                                                                                         5
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 central to boosting domestic revenue mobilization in Pakistan.                                pre- and post-clearance mechanisms, the second reform priority,
 Historically, reforms in customs have been realized by focusing                               by shifting the focus of information flows from goods (i.e., the
 on its revenue collection function. While this focus has ensured                              Harmonized System [HS] of Coding) to the tracing of operators and
 that customs collection as a portion of revenue remained stable                               their behavior, including their association to HS codes.
 over time, this approach has had its implications for the business                                Important to note here is that RMS improvement will not
 environment.                                                                                  imply trade facilitation for all. Rather, it will imply a more effective,
 	 The central question Pakistan Customs faces today is how                                    targeted facilitation for those who comply, while applying
 to continue to generate revenue while improving its role in                                   effective enforcement measures to fraudulent operators. Over
 facilitating trade. International experiences provide examples of                             time, this will help customs create a positive feedback loop with
 several ways to do this. More specifically, three reasonable reform                           compliant operators, building trust and encouraging and rewarding
 options are to: (i) enhance the RMS, (ii) improve pre- and post-                              compliance through facilitating trade. A trusted trader program,
 clearance capabilities, and (iii) contribute to broadening the tax                            allowing pre- and post-clearance facilities for compliant traders,
 base. Taken together, these three reform options should enable                                would be a first step in the direction of a positive feedback loop.
 Pakistan Customs to achieve the next level of maturity, building
 on its relatively strong base of goods and revenue control. Table 2                           The second reform priority is to strengthen pre- and post-
 provides an overview of the sequencing that may be pursued for                                clearance facilities and enforcement capabilities. Post-release
 the aforementioned administrative reforms.                                                    control and audit regimes represent the safety net for the entire
                                                                                               facilitation approach. In this regime, traders can clear their goods
 Table 2. Sequence of Proposed Reform Priorities for Pakistan                                  without inspection upon arrival, but audits take place post-
 Customs                                                                                       clearance and can be done at the aggregate firm level, rather
                                                                                               than at the single GD level. Audit and enforcement capabilities are
           First Priority                  Second Priority                    Third Priority   one of the most effective trade facilitation strategies available to
           Enhancing the risk              Improving                          Broadening the   border agencies. It can enable the immediate release of imported
           management                      clearance facilities               tax base         cargo but ensure compliance through the subsequent use of
           system                                                                              audit-based regulatory controls. Pakistan Customs has the
                                                                                               institutional set-up in place to facilitate pre-clearance, but further
           Strong laws and clearly established processes
                                                                                               effort is required to expand utilization and robustness of such
Enablers




           Sufficient and competent workforce
                                                                                               facilities.
                                                                                                   Similarly, the institution has the basics in place to support
           Supportive and fully utilized information technology systems                        post-clearance audit (PCA) activities but lacks the capacity to
                                                                                               execute on a systematic basis. Ultimately, pre-clearance and PCA
                                                                                               should be designed to broaden auditors’ review of the trader’s
 The first reform priority is to enhance the RMS. A system                                     overall transactions and provide a clear indication of levels of
 focused on risk profiles of authorized operators (i.e., carriers,                             compliance with tax and regulatory requirements. In this context,
 brokers, and traders) will over time allow customs to ensure                                  strengthening the central RMS is critical to ensure there will not
 only those GDs posing noteworthy risk to revenue, safety,                                     be major revenue losses, as compliant traders and taxpayers will
 or security are selected for physical examination. Excessive                                  benefit from PCA controls.
 controls will need to be reduced, for example, by imposing a cap
 on the number of GDs selected for physical and documentary                                    Strengthening PCA should be accompanied by reforms to
 inspection. Simultaneously, enhanced capabilities to analyze                                  address the weaknesses of Inland Revenue.6 Typically, the value
 economic sectors along with improved feedback mechanisms                                      added tax (VAT) may be used as a safety net to safeguard against
 would contribute to enriching the RMS and its targeting of risky                              leakages in the domestic market. The VAT is charged on all
 transactions. The internal feedback mechanisms between the                                    domestic sales by registered firms, including imports (Keen 2008).
 RMS and the operational staff, especially the inspectors and                                  A mismatch between import records and VAT records can point
 appraisers, are critical for sound checks and balances about                                  the revenue administrations to leakages and address those in
 the performance of both: the central RMS and the expected                                     PCAs. For this mechanism to work, however, attention should be
 outcomes from the field.                                                                      paid to strengthening Inland Revenue’s capacity to administer
 	 An improved RMS will subsequently help customs manage                                       such taxes and conduct audits. Moreover, in a context of increased
 large volumes of trade more effectively while relying less on                                 green channel clearances and reduced border checks, effective
 physical and documentary inspections. In this way, the same (or                               administration of VAT will preserve public revenue since it is
 increased) trade volumes can be effectively managed while largely                             essentially a tax on the purchase of informal operators and on
 guaranteeing revenue collection. It would also facilitate effective                           their imports.

 6
     See Lopez-Calix and Touqueer (2013) and World Bank (2017) for a summary of prevailing
 weaknesses.
                                                                                                                                                                           6
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                                                                                                                                       No.15



Once improved RMS and PCA are being fully utilized, physical          shortcomings, point to an urgent need for customs to rehabilitate
inspections and documentary checks at the borders may be              its workforce and SOPs.
reduced. This will flow naturally from reforms to the RMS and             The WeBOC system is performing well on basic functions
PCA capacities. A well-designed RMS will allow customs to move        such as streamlining goods declarations. To support reforms, the
away from traditional time-costly clearance approaches to more        information it captures could be further exploited using business
effective trade facilitation strategies that enable the immediate     intelligence. For example, physical examination of goods could be
release of imported cargo. In addition, the adoption of pre-arrival   better directed by making more efficient use of trader histories,
clearance together with more intense use of PCA should help           average assessed values, correlations between declared weights
customs facilitate high volumes of cargo transactions in a timely     and goods, and so on. In addition, WeBOC’s functionality could be
manner while ensuring that traders maintain elevated levels of        enlarged to include better cargo management. All these activities
compliance. Together, these improvements will result in lower         are key to successful improvements of the RMS, audit, and
costs to the business community, while simultaneously promote         enforcement capabilities.
revenue generating activities through an improved business
climate. 
                                                                      Acknowledgments
The third reform priority is to contribute to broadening the          This note is part of the World Bank’s broader operational
tax base, linking traders into the domestic tax net through           engagement with Pakistan around revenue policy and
joint audits and joint registries between Customs and Inland          administration led by Raul Felix Junquera-Varela, lead public
Revenue. Rich trade data can be linked to business activities to      sector specialist; Jose Eduardo Gutierrez Ossio, senior public
bring traders into the domestic tax net, thus reducing informality    sector specialist; and Muhammad Waheed, senior economist.
in the domestic market. Take for example the transfer pricing (TP)
practices of multinational companies. Multinational companies         References
in Pakistan are responsible for about 60 percent of imports.          Gaspar, V., L. Jaramillo, and P. Wingender. 2016. “Tax Capacity and
Analyzing trade, sales, and income data in an integrated way          Growth: Is There a Tipping Point?” IMF Working Paper WP/16/234,
can better inform customs valuation and TP studies, as well           International Monetary Fund, Washington, DC. https://www.imf.
as contribute to improving capacity to detect avoidance and           org/external/pubs/ft/wp/2016/wp16234.pdf.
undervaluation. Ultimately, such enhancements will improve
compliance, reduce the tax gap, and thus increase revenue.            Keen, M. 2008. “VAT, Tariffs, and Withholding: Border Taxes and
Clearly, close collaboration between Customs and Inland Revenue       Informality in Developing Countries.” Journal of Public Economics
is critical for these reforms to be implemented successfully, and     92:1892–1906.
to avoid risking a loss in revenue collection.
                                                                      Lopez-Calix, J.R., and I. Touqueer. 2013. “Mobilizing Revenue.”
Overall Reform Context                                                Pakistan Policy Note 16, World Bank, Washington, DC. http://
It is important to highlight three cross-cutting components           documents.worldbank.org/curated/en/378401468074335833/
— strong laws and clearly established processes, competent            pdf/795830BRI0SASE0Box0377381B00PUBLIC0.pdf.
human resources (HR), and a supportive IT system — that
are critical enablers to facilitate this reform agenda. An HR         Raballand, G., J. Marteau, E. Mjekiqi, and T. Cantens. 2009. “Is
team that is well guided by clear strategic goals, standard           There Any Trade-Off Between Revenue Collection and Trade
operating procedures (SOPs), and streamlined business processes       Facilitation In Africa?” Research Committee Development
that are automated will ensure that reforms are consistently          Economics, Proceedings of the German Development Economics
implemented as necessary. However, strategic planning and             Conference, Frankfurt A.M. Accessed at: https://www.imf.org/
performance measurements are rarely used to direct customs            external/pubs/ft/wp/2016/wp16234.pdf.
operations. Secondly, while Pakistan Customs has a well-trained,
highly esteemed cadre that inhabits higher level functions, other     UNCTAD (United Nations Conference on Trade and Development).
staff could significantly benefit from additional, systematic         2016. Trade Facilitation and Development: Driving Trade
training. In addition, internal incentive structures for staff is     Competitiveness, Border Agency Effectiveness and Strengthened
important. Experience of other customs offices shows that             Governance. New York and Geneva: United Nations.     http://unctad.
inspector performance contracts that reward good performers           org/en/PublicationsLibrary/dtltlb2016d1_en.pdf.
(e.g., through merit rewards, training opportunities at home and
abroad, and accelerated career progression) and sanction poor
performers are effective (Raballand et al. 2017). Thirdly, critical
departments like PCA are under-resourced. These, among other



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WCO (World Customs Organization). 2017. Annual Report
2016–2017. Brussels, Belgium: WCO. http://www.wcoomd.org/-/
media/wco/public/global/pdf/media/annual-reports/annual-
report-2016_2017.pdf.

World Bank. 2017. Managing Risks for Sustained Growth:
Pakistan Development Update. Washington, DC: World
Bank Group. http://documents.worldbank.org/curated/
en/386771510146349984/Managing-risks-for-sustained-growth-
Pakistan-development-update.

World Bank Group. 2019. Doing Business 2019: Training for Jobs.
Washington, DC: World Bank. http://www.doingbusiness.org/
content/dam/doingBusiness/media/Annual-Reports/English/
DB2019-report_web-version.pdf. (Database accessed, Measuring
Business Regulations, http://www.doingbusiness.org/data/
exploreeconomies/pakistan.)

Wulf, L.D., and J.B. Sokol. 2005. Customs Modernization
Handbook. Washington, DC: World Bank. https://siteresources.
worldbank.org/INTEXPCOMNET/Resources/Customs_
Modernization_Handbook.pdf.




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