{ "schema_version": "1.1.0", "report_id": "cr-2012-060", "source_sha256": "6adcfe67f2e195c0f6912db9a10d39f6293e414b71d3c37f9a046cb43caad7c1", "title": "Philippines: Technical Assistance Report on Road Map for a Pro-Growth and Equitable Tax System", "language": [ "English" ], "authors": [ { "name": "International Monetary Fund", "role": "indexed_institutional_author", "evidence": [ { "source": "imf_index_metadata" } ], "confidence": 1.0 }, { "name": "excises. To", "role": "prepared_by", "verbatim_statement": "the Department of Finance (DOF) still await discussion at the Congress. The present mission assessed the authorities‘ progress in implementing the FAD recommendations including the proposed reform bills on tax incentives and excises. To", "evidence": [ { "evidence_id": "ev-f5cbcafdb45cbbdc", "page": 8, "quote": "Prepared By\nthe Department of Finance (DOF) still await discussion at the\nCongress.\nThe present mission assessed the authorities‘ progress in implementing the FAD\nrecommendations including the proposed reform bills on tax incentives and excises. To", "source": "document" } ], "confidence": 0.82 } ], "countries": [ { "name": "Philippines", "formal_name": "Philippines", "iso3": "PHL", "evidence": [ { "source": "imf_index_metadata" } ], "confidence": 1.0 } ], "dates": [ { "type": "publication", "start": "2016-12-31", "end": "2016-12-31", "precision": "day", "verbatim": "2016-12-31", "evidence": [ { "source": "imf_publication_url" } ], "confidence": 0.98 }, { "type": "imf_index_date", "start": "2012-03-19", "end": "2012-03-19", "precision": "day", "verbatim": "2012-03-19T04:00:00Z", "evidence": [ { "source": "imf_index_metadata" } ], "confidence": 1.0 }, { "type": "date_mention", "start": "2001-01-29", "end": "2001-01-29", "precision": "day", "verbatim": "January 29, 2001", "evidence": [ { "evidence_id": "ev-b2cd1e319726a882", "page": 1, "quote": "January 29, 2001", "source": "document" } ], "confidence": 0.65 }, { "type": "mission_or_report_range", "start": "2011-09-06", "end": "2011-09-19", "precision": "day", "verbatim": "September 6–19, 2011", "evidence": [ { "evidence_id": "ev-781fcc6207fc6b63", "page": 6, "quote": "September 6–19, 2011", "source": "document" } ], "confidence": 0.8 } ], "metadata": { "series": [ "IMF Staff Country Reports" ], "series_volume_no": "Country Report No. 2012/060", "doi": [], "isbn": [], "subjects": [ "Tax incentives", "Excises", "Corporate income tax", "Income and capital gains taxes", "Revenue administration", "Taxes" ], "topics": [ "Fiscal policy and management|Taxes|Tax incentives ", " Fiscal policy and management|Taxes ", " Fiscal policy and management ", " Fiscal policy and management|Taxes|Consumption taxes|Excises ", " Fiscal policy and management|Taxes|Consumption taxes ", " Fiscal policy and management|Taxes ", " Fiscal policy and management ", " Fiscal policy and management|Taxes|Income and capital gains taxes|Corporate income tax ", " Fiscal policy and management|Taxes|Income and capital gains taxes ", " Fiscal policy and management|Taxes ", " Fiscal policy and management ", " Fiscal policy and management|Taxes|Income and capital gains taxes ", " Fiscal policy and management|Taxes ", " Fiscal policy and management ", " Fiscal policy and management|Revenue administration ", " Fiscal policy and management ", " Fiscal policy and management|Taxes ", " Fiscal policy and management ", " Fund operations|IMF lending|Charges ", " Fund operations|IMF lending ", " Fund operations ", " Fund operations|IMF lending|Charges|Service charges ", " Fund operations|IMF lending|Charges ", " Fund operations|IMF lending ", " Fund operations ", " Fund operations|Capacity development|Capacity development delivery ", " Fund operations|Capacity development ", " Fund operations" ], "keywords": [ "ISCR,CR,excise tax,tax rate,tax burden,income tax,tax revenue,withholding tax,gross sales,flat rate,taxable income,tax system,excise rate,Excises,Tax incentives,Corporate income tax,Income and capital gains taxes,Global" ], "description_indexed": "The Technical Assistance Report on the Philippines’ road map for a pro-growth and equitable tax system is examined. Tax revenue has declined over the last decade in the Philippines owing to generous and expanding tax incentives, tariff rate reduction, deteriorating tax compliance caused by ineffective and inefficient revenue administration, and a gradual erosion of excise revenue owing to nonindexation. One of the key reasons for providing tax incentives in the Philippines is concern that the country needs to be competitive with other countries in the region to attract foreign direct investment.", "authoring_departments": [ { "name": "Fiscal Affairs Department", "evidence": [ { "evidence_id": "ev-d49cbb43d42d3500", "page": 2, "quote": "Fiscal Affairs Department", "source": "document" } ], "confidence": 0.9 } ], "source_page_url": "https://www.imf.org/en/publications/cr/issues/2016/12/31/philippines-technical-assistance-report-on-road-map-for-a-pro-growth-and-equitable-tax-system-25786", "source_pdf_url": "https://www.imf.org/external/pubs/ft/scr/2012/cr1260.pdf", "page_count": 71, "interim_extraction_method": "pymupdf4llm+pymupdf-layout", "needs_ocr_pages": [] }, "observations": [ { "text": "The views expressed in this document are those of the staff team and do not necessarily reflect the views of the government of Philippines or the Executive Board of the IMF.", "verbatim": "The views expressed in this document are those of the staff team and do not necessarily reflect the views of the government of Philippines or the Executive Board of the IMF.", "topic": null, "severity": null, "evidence": [ { "evidence_id": "ev-a89a3ce4d9e4f802", "page": 1, "quote": "The views expressed in this document are those of the staff team and do not necessarily reflect the views of the government of Philippines or the Executive Board of the IMF.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0001" }, { "text": "It consists of an Executive Summary and the following seven chapters: (1) Introduction and Progress in Tax Reform; (2) Tax Incentives; (3) Other Corporate Income Tax Issues; (4) Excise Taxes; (5) Personal Income Tax; (6) Mining Taxation; and (7) Road Map for Tax Reform.", "verbatim": "It consists of an Executive Summary and the following seven chapters: (1) Introduction and Progress in Tax Reform; (2) Tax Incentives; (3) Other Corporate Income Tax Issues; (4) Excise Taxes; (5) Personal Income Tax; (6) Mining Taxation; and (7) Road Map for Tax Reform.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-6a659a517e82de32", "page": 6, "quote": "It consists of an Executive Summary and the following seven chapters: (1) Introduction and Progress in Tax Reform; (2) Tax Incentives; (3) Other Corporate Income Tax Issues; (4) Excise Taxes; (5) Personal Income Tax; (6) Mining Taxation; and (7) Road Map for Tax Reform.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0002" }, { "text": "The mission‘s assessment and key issues in implementing tax reform plans are as follows: (Recommendations by the 2010 mission on VAT and taxation of the financial sector are still valid and the mission found no new issues to add.)", "verbatim": "The mission‘s assessment and key issues in implementing tax reform plans are as follows: (Recommendations by the 2010 mission on VAT and taxation of the financial sector are still valid and the mission found no new issues to add.)", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-65e31541099fae32", "page": 8, "quote": "The mission‘s assessment and key issues in implementing tax reform plans are as follows: (Recommendations by the 2010 mission on VAT and taxation of the financial sector are still valid and the mission found no new issues to add.)", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0003" }, { "text": "The present mission assessed the authorities‘ progress in implementing the FAD recommendations including the proposed reform bills on tax incentives and excises.", "verbatim": "The present mission assessed the authorities‘ progress in implementing the FAD recommendations including the proposed reform bills on tax incentives and excises.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-96e895fb348f306d", "page": 8, "quote": "The present mission assessed the authorities‘ progress in implementing the FAD recommendations including the proposed reform bills on tax incentives and excises.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0004" }, { "text": "Progress Made in Implementing the 2010 FAD Mission Recommendations", "verbatim": "Progress Made in Implementing the 2010 FAD Mission Recommendations", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-0e6ab505516ab64f", "page": 12, "quote": "Progress Made in Implementing the 2010 FAD Mission Recommendations", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0005" }, { "text": "Tax revenue has declined over the last decade in the Philippines due to generous and expanding tax incentives, tariff rate reduction, deteriorating tax compliance caused by ineffective and inefficient revenue administration, and a gradual erosion of excise revenue due to non-indexation.", "verbatim": "Tax revenue has declined over the last decade in the Philippines due to generous and expanding tax incentives, tariff rate reduction, deteriorating tax compliance caused by ineffective and inefficient revenue administration, and a gradual erosion of excise revenue due to non-indexation.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-96ac3f2f57b9ba09", "page": 12, "quote": "Tax revenue has declined over the last decade in the Philippines due to generous and expanding tax incentives, tariff rate reduction, deteriorating tax compliance caused by ineffective and inefficient revenue administration, and a gradual erosion of excise revenue due to non-indexation.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0006" }, { "text": "The focus since the election has not been on introducing new taxes or increasing existing ones, but on enhancing collection by reforming tax administration.", "verbatim": "The focus since the election has not been on introducing new taxes or increasing existing ones, but on enhancing collection by reforming tax administration.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-4f8166a60c9885c7", "page": 12, "quote": "The focus since the election has not been on introducing new taxes or increasing existing ones, but on enhancing collection by reforming tax administration.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0007" }, { "text": "The mission found progress in the following areas.", "verbatim": "The mission found progress in the following areas.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-b5bf7c53fdde8b8d", "page": 12, "quote": "The mission found progress in the following areas.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0008" }, { "text": "While the Philippines government aims to increase the tax-to-GDP ratio to 16 percent of GDP, which is 3.4 percent higher than that in 2010, the tax administration reform has not registered an increase in revenue, though some slight progress has been made in recent months.", "verbatim": "While the Philippines government aims to increase the tax-to-GDP ratio to 16 percent of GDP, which is 3.4 percent higher than that in 2010, the tax administration reform has not registered an increase in revenue, though some slight progress has been made in recent months.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-aba77574c7488a93", "page": 12, "quote": "While the Philippines government aims to increase the tax-to-GDP ratio to 16 percent of GDP, which is 3.4 percent higher than that in 2010, the tax administration reform has not registered an increase in revenue, though some slight progress has been made in recent months.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0009" }, { "text": "Most of the bills do not include the indexation to inflation.", "verbatim": "Most of the bills do not include the indexation to inflation.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-7220f414b0089378", "page": 13, "quote": "Most of the bills do not include the indexation to inflation.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0010" }, { "text": "However, revenue would be the same in the short term if the Philippines adopts all FAD recommendations on the VAT.", "verbatim": "However, revenue would be the same in the short term if the Philippines adopts all FAD recommendations on the VAT.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-5ea1b5fa43473143", "page": 14, "quote": "However, revenue would be the same in the short term if the Philippines adopts all FAD recommendations on the VAT.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0011" }, { "text": "However, the present mission recommends a unified 20 percent rate, which is the current rate on interest from deposits or bonds with a maturity of less than three years.", "verbatim": "However, the present mission recommends a unified 20 percent rate, which is the current rate on interest from deposits or bonds with a maturity of less than three years.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-d9c10825e1a3b527", "page": 14, "quote": "However, the present mission recommends a unified 20 percent rate, which is the current rate on interest from deposits or bonds with a maturity of less than three years.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0012" }, { "text": "The present mission does not think the recommendation is a viable option given the current fiscal condition and income inequity in the Philippines, though it is desirable to align the top PIT rate with the CIT rate in the longer term.", "verbatim": "The present mission does not think the recommendation is a viable option given the current fiscal condition and income inequity in the Philippines, though it is desirable to align the top PIT rate with the CIT rate in the longer term.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-c8aecc5985b3702c", "page": 14, "quote": "The present mission does not think the recommendation is a viable option given the current fiscal condition and income inequity in the Philippines, though it is desirable to align the top PIT rate with the CIT rate in the longer term.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0013" }, { "text": "While the main lines of the World Bank recommendations are similar to those of the 2010 mission, the present mission found that their views on some matters differ from ours.", "verbatim": "While the main lines of the World Bank recommendations are similar to those of the 2010 mission, the present mission found that their views on some matters differ from ours.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-52404414d490df22", "page": 14, "quote": "While the main lines of the World Bank recommendations are similar to those of the 2010 mission, the present mission found that their views on some matters differ from ours.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0014" }, { "text": "As to the VAT and taxation of the financial sector, the mission found the previous recommendations are valid and has nothing to add.", "verbatim": "As to the VAT and taxation of the financial sector, the mission found the previous recommendations are valid and has nothing to add.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-9a5981fd63bcdc17", "page": 15, "quote": "As to the VAT and taxation of the financial sector, the mission found the previous recommendations are valid and has nothing to add.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0015" }, { "text": "Numerous studies and reports, including those of previous FAD tax policy missions in 2001 and 2010, have found that the existing regime is very generous and unnecessarily complex.", "verbatim": "Numerous studies and reports, including those of previous FAD tax policy missions in 2001 and 2010, have found that the existing regime is very generous and unnecessarily complex.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-10ab3d8bf2251f5f", "page": 15, "quote": "Numerous studies and reports, including those of previous FAD tax policy missions in 2001 and 2010, have found that the existing regime is very generous and unnecessarily complex.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0016" }, { "text": "Of particular concern are tax holidays and reduced tax rates, which are among the most ineffective forms of tax incentives.", "verbatim": "Of particular concern are tax holidays and reduced tax rates, which are among the most ineffective forms of tax incentives.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-391671bfc9d0978d", "page": 15, "quote": "Of particular concern are tax holidays and reduced tax rates, which are among the most ineffective forms of tax incentives.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0017" }, { "text": "There are, however, a number of bills currently before Congress seeking to rationalize incentives.", "verbatim": "There are, however, a number of bills currently before Congress seeking to rationalize incentives.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-f151e75d7d573c86", "page": 15, "quote": "There are, however, a number of bills currently before Congress seeking to rationalize incentives.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0018" }, { "text": "This aide memoire explains the mission‘s new findings on and analysis of tax incentives, other CIT issues, excises, and PIT, and mining taxation, (of which the mission conducted a preliminary review).", "verbatim": "This aide memoire explains the mission‘s new findings on and analysis of tax incentives, other CIT issues, excises, and PIT, and mining taxation, (of which the mission conducted a preliminary review).", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-46bf5f159b24e337", "page": 15, "quote": "This aide memoire explains the mission‘s new findings on and analysis of tax incentives, other CIT issues, excises, and PIT, and mining taxation, (of which the mission conducted a preliminary review).", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0019" }, { "text": "There is insufficient data available to obtain an accurate estimate of the cost of tax incentives in the Philippines.", "verbatim": "There is insufficient data available to obtain an accurate estimate of the cost of tax incentives in the Philippines.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-625c3ff5b1763c04", "page": 16, "quote": "There is insufficient data available to obtain an accurate estimate of the cost of tax incentives in the Philippines.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0020" }, { "text": "These include: (1) the provision of incentives by multiple agencies (and multiple laws) which creates unnecessary competition between agencies and zones and is confusing for investors; (2) multiple incentive agencies also mean that a significant number of resources are involved in providing essentially the same services; (3) the monitoring of investors‘ compliance with incentive conditions appears to be weak; and (4) the limited involvement of the DOF in decisions to grant investment incentives results in an absence of fiscal discipline.", "verbatim": "These include: (1) the provision of incentives by multiple agencies (and multiple laws) which creates unnecessary competition between agencies and zones and is confusing for investors; (2) multiple incentive agencies also mean that a significant number of resources are involved in providing essentially the same services; (3) the monitoring of investors‘ compliance with incentive conditions appears to be weak; and (4) the limited involvement of the DOF in decisions to grant investment incentives results in an absence of fiscal discipline.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-bc41c77dc50dfbc3", "page": 16, "quote": "These include: (1) the provision of incentives by multiple agencies (and multiple laws) which creates unnecessary competition between agencies and zones and is confusing for investors; (2) multiple incentive agencies also mean that a significant number of resources are involved in providing essentially the same services; (3) the monitoring of investors‘ compliance with incentive conditions appears to be weak; and (4) the limited involvement of the DOF in decisions to grant investment incentives results in an absence of fiscal discipline.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0021" }, { "text": "[11] The World Bank is currently undertaking a project to estimate the cost of tax expenditures in the Philippines, but its findings are not yet available.", "verbatim": "[11] The World Bank is currently undertaking a project to estimate the cost of tax expenditures in the Philippines, but its findings are not yet available.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-d339da870ce87caa", "page": 16, "quote": "[11] The World Bank is currently undertaking a project to estimate the cost of tax expenditures in the Philippines, but its findings are not yet available.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0022" }, { "text": "Despite the generous incentives offered by the Philippines, growth in FDI has remained lower than its neighbors, suggesting that other factors may be more relevant in deciding whether to invest in the country.", "verbatim": "Despite the generous incentives offered by the Philippines, growth in FDI has remained lower than its neighbors, suggesting that other factors may be more relevant in deciding whether to invest in the country.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-91adb6a73eb3ce9a", "page": 17, "quote": "Despite the generous incentives offered by the Philippines, growth in FDI has remained lower than its neighbors, suggesting that other factors may be more relevant in deciding whether to invest in the country.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0023" }, { "text": "However, if the preferred option was not considered feasible then the 2010 report recommended rationalizing tax incentives, with a smaller reduction in the CIT rate.", "verbatim": "However, if the preferred option was not considered feasible then the 2010 report recommended rationalizing tax incentives, with a smaller reduction in the CIT rate.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-cd98a693e12013d6", "page": 17, "quote": "However, if the preferred option was not considered feasible then the 2010 report recommended rationalizing tax incentives, with a smaller reduction in the CIT rate.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0024" }, { "text": "However, it was also noted that the Philippines has regional competitive advantages, including the age, quality, and education of its workforce, and the widespread use of the English language.", "verbatim": "However, it was also noted that the Philippines has regional competitive advantages, including the age, quality, and education of its workforce, and the widespread use of the English language.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-2d966cd58bf0120a", "page": 17, "quote": "However, it was also noted that the Philippines has regional competitive advantages, including the age, quality, and education of its workforce, and the widespread use of the English language.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0025" }, { "text": "[12] Some of the non-tax factors raised with the mission as being deterrents to FDI were lack of adequate infrastructure, power costs, poor legal environment (including land ownership and labor laws), and difficulties in doing business.", "verbatim": "[12] Some of the non-tax factors raised with the mission as being deterrents to FDI were lack of adequate infrastructure, power costs, poor legal environment (including land ownership and labor laws), and difficulties in doing business.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-dc890172e73112c7", "page": 17, "quote": "[12] Some of the non-tax factors raised with the mission as being deterrents to FDI were lack of adequate infrastructure, power costs, poor legal environment (including land ownership and labor laws), and difficulties in doing business.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0026" }, { "text": "[13] A concern was raised with the mission that providing incentives may be an attempt to offset the non-tax factors, without adequately addressing the non-tax constraints.", "verbatim": "[13] A concern was raised with the mission that providing incentives may be an attempt to offset the non-tax factors, without adequately addressing the non-tax constraints.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-08eb4c3c1d487dc7", "page": 17, "quote": "[13] A concern was raised with the mission that providing incentives may be an attempt to offset the non-tax factors, without adequately addressing the non-tax constraints.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0027" }, { "text": "practice, however, the allowance of a lower tax rate (5 percent of GIE) for an indefinite time period is more generous—the maximum period for incentives in almost all countries in the region is 15 years, with most being less than 10 years.", "verbatim": "practice, however, the allowance of a lower tax rate (5 percent of GIE) for an indefinite time period is more generous—the maximum period for incentives in almost all countries in the region is 15 years, with most being less than 10 years.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-6d136abcf8958d35", "page": 17, "quote": "practice, however, the allowance of a lower tax rate (5 percent of GIE) for an indefinite time period is more generous—the maximum period for incentives in almost all countries in the region is 15 years, with most being less than 10 years.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0028" }, { "text": "However, the report suggested that the tax on GIE could be removed once the BIR, BOC, and local government administrations have improved to an extent that there is little difference between the levels of service provided within zones and outside zones.", "verbatim": "However, the report suggested that the tax on GIE could be removed once the BIR, BOC, and local government administrations have improved to an extent that there is little difference between the levels of service provided within zones and outside zones.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-4f7430bbbf162fc9", "page": 18, "quote": "However, the report suggested that the tax on GIE could be removed once the BIR, BOC, and local government administrations have improved to an extent that there is little difference between the levels of service provided within zones and outside zones.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0029" }, { "text": "[14] It argued that retaining the tax on GIE allowed companies access to the simplified administration available in the PEZA zones (that is, streamlined administration with limited or no dealings with the BIR, BOC and local governments), while collecting more revenue from these firms.", "verbatim": "[14] It argued that retaining the tax on GIE allowed companies access to the simplified administration available in the PEZA zones (that is, streamlined administration with limited or no dealings with the BIR, BOC and local governments), while collecting more revenue from these firms.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-3dcca5565e0ebf0a", "page": 18, "quote": "[14] It argued that retaining the tax on GIE allowed companies access to the simplified administration available in the PEZA zones (that is, streamlined administration with limited or no dealings with the BIR, BOC and local governments), while collecting more revenue from these firms.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0030" }, { "text": "As shown in Appendix II, most countries in the region do not provide incentives beyond 10 years.", "verbatim": "As shown in Appendix II, most countries in the region do not provide incentives beyond 10 years.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-b29dea0625f33fd1", "page": 20, "quote": "As shown in Appendix II, most countries in the region do not provide incentives beyond 10 years.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0031" }, { "text": "There are, however, a number of further improvements that could be made to the regime proposed by the DOF.", "verbatim": "There are, however, a number of further improvements that could be made to the regime proposed by the DOF.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-f88513ed7e6dbd70", "page": 20, "quote": "There are, however, a number of further improvements that could be made to the regime proposed by the DOF.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0032" }, { "text": "17 The effective rate is calculated as the proposed 25 percent CIT rate plus 10 percent on the after-tax profits available for distribution (i.e., 10 percent of 75).", "verbatim": "17 The effective rate is calculated as the proposed 25 percent CIT rate plus 10 percent on the after-tax profits available for distribution (i.e., 10 percent of 75).", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-16cee16fc0397800", "page": 22, "quote": "17 The effective rate is calculated as the proposed 25 percent CIT rate plus 10 percent on the after-tax profits available for distribution (i.e., 10 percent of 75).", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0033" }, { "text": "However, the fiscal position is unlikely to be able to support a reduction if there is not a significant rationalization of incentives.", "verbatim": "However, the fiscal position is unlikely to be able to support a reduction if there is not a significant rationalization of incentives.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-39edd45786d867f4", "page": 22, "quote": "However, the fiscal position is unlikely to be able to support a reduction if there is not a significant rationalization of incentives.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0034" }, { "text": "It was suggested that a CIT rate cut may be pro-rich and anti-poor, however there are a number of reasons why this is not the case.", "verbatim": "It was suggested that a CIT rate cut may be pro-rich and anti-poor, however there are a number of reasons why this is not the case.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-1a4480029eda76f7", "page": 22, "quote": "It was suggested that a CIT rate cut may be pro-rich and anti-poor, however there are a number of reasons why this is not the case.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0035" }, { "text": "Second, even with a rate cut to 25 percent, the effective tax on CIT profits distributed to shareholders is 32.5 percent (that is the CIT rate plus the 10 percent dividend withholding tax), which is still higher than the existing top PIT rate.", "verbatim": "Second, even with a rate cut to 25 percent, the effective tax on CIT profits distributed to shareholders is 32.5 percent (that is the CIT rate plus the 10 percent dividend withholding tax), which is still higher than the existing top PIT rate.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-cc87fa9762fa2791", "page": 22, "quote": "Second, even with a rate cut to 25 percent, the effective tax on CIT profits distributed to shareholders is 32.5 percent (that is the CIT rate plus the 10 percent dividend withholding tax), which is still higher than the existing top PIT rate.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0036" }, { "text": "While the CIT rate was reduced in 2009, a further decrease may be necessary to remain regionally competitive.", "verbatim": "While the CIT rate was reduced in 2009, a further decrease may be necessary to remain regionally competitive.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-fee8872edaca680a", "page": 22, "quote": "While the CIT rate was reduced in 2009, a further decrease may be necessary to remain regionally competitive.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0037" }, { "text": "[18] A cooperative is exempt from all taxes (including income tax, VAT and import duties) if its business transactions are with members only, or it transacts with non-members and its accumulated reserves and undivided net savings (effectively its share capital) are less than PHP10 million.", "verbatim": "[18] A cooperative is exempt from all taxes (including income tax, VAT and import duties) if its business transactions are with members only, or it transacts with non-members and its accumulated reserves and undivided net savings (effectively its share capital) are less than PHP10 million.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-5959304a99b31d4a", "page": 23, "quote": "[18] A cooperative is exempt from all taxes (including income tax, VAT and import duties) if its business transactions are with members only, or it transacts with non-members and its accumulated reserves and undivided net savings (effectively its share capital) are less than PHP10 million.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0038" }, { "text": "[19] If the cooperative exceeds the PHP10 million threshold it may be taxed on its business with non-members, although there are further exemptions for agricultural cooperatives, certain credit cooperatives, and for cooperatives where each member‘s contribution to share capital does not exceed PHP15,000.", "verbatim": "[19] If the cooperative exceeds the PHP10 million threshold it may be taxed on its business with non-members, although there are further exemptions for agricultural cooperatives, certain credit cooperatives, and for cooperatives where each member‘s contribution to share capital does not exceed PHP15,000.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-77bafa96ba933b4f", "page": 23, "quote": "[19] If the cooperative exceeds the PHP10 million threshold it may be taxed on its business with non-members, although there are further exemptions for agricultural cooperatives, certain credit cooperatives, and for cooperatives where each member‘s contribution to share capital does not exceed PHP15,000.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0039" }, { "text": "It is also difficult for the BIR to effectively monitor cooperatives, including the level of non-member transactions.", "verbatim": "It is also difficult for the BIR to effectively monitor cooperatives, including the level of non-member transactions.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-998fc4e22d4a69c9", "page": 24, "quote": "It is also difficult for the BIR to effectively monitor cooperatives, including the level of non-member transactions.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0040" }, { "text": "Gains on real estate that has not been used in the business of a corporation are subject to a 6 percent final income tax.", "verbatim": "Gains on real estate that has not been used in the business of a corporation are subject to a 6 percent final income tax.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-efc86c5cb217b35d", "page": 25, "quote": "Gains on real estate that has not been used in the business of a corporation are subject to a 6 percent final income tax.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0041" }, { "text": "While the Philippines’ relatively high CIT rate may induce a multinational enterprise (MNE) to shift its income from the Philippines to overseas jurisdictions, transactions with related parties which enjoy income tax holidays and other tax incentives could have the most serious transfer pricing risks.", "verbatim": "While the Philippines’ relatively high CIT rate may induce a multinational enterprise (MNE) to shift its income from the Philippines to overseas jurisdictions, transactions with related parties which enjoy income tax holidays and other tax incentives could have the most serious transfer pricing risks.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-cfe4fc0d0f6b1311", "page": 25, "quote": "While the Philippines’ relatively high CIT rate may induce a multinational enterprise (MNE) to shift its income from the Philippines to overseas jurisdictions, transactions with related parties which enjoy income tax holidays and other tax incentives could have the most serious transfer pricing risks.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0042" }, { "text": "21 Section 34 (B) (2) (b) of the NIRC denies deduction of interest on a loan between family member, but does not apply an inter-company loan.", "verbatim": "21 Section 34 (B) (2) (b) of the NIRC denies deduction of interest on a loan between family member, but does not apply an inter-company loan.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-192bc7a11441c281", "page": 26, "quote": "21 Section 34 (B) (2) (b) of the NIRC denies deduction of interest on a loan between family member, but does not apply an inter-company loan.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0043" }, { "text": "The current CIT return form does not include information on related parties, so the BIR has difficulties in focusing on such a transaction.", "verbatim": "The current CIT return form does not include information on related parties, so the BIR has difficulties in focusing on such a transaction.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-aa058698dd7f31ac", "page": 26, "quote": "The current CIT return form does not include information on related parties, so the BIR has difficulties in focusing on such a transaction.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0044" }, { "text": "[24] However, under the current incentive regime, the thin capitalization rule", "verbatim": "[24] However, under the current incentive regime, the thin capitalization rule", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-9477a97de87b1557", "page": 26, "quote": "[24] However, under the current incentive regime, the thin capitalization rule", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0045" }, { "text": "28 As the current Philippines-Switzerland DTA does not have a provision for exchange of information.", "verbatim": "28 As the current Philippines-Switzerland DTA does not have a provision for exchange of information.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-6fec0481af92b698", "page": 27, "quote": "28 As the current Philippines-Switzerland DTA does not have a provision for exchange of information.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0046" }, { "text": "The decline in excise taxes are because of a lack of indexation of the specific taxes on tobacco and alcoholic products, use of old prices in classifying such products and reduction in excise on petroleum products.", "verbatim": "The decline in excise taxes are because of a lack of indexation of the specific taxes on tobacco and alcoholic products, use of old prices in classifying such products and reduction in excise on petroleum products.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-0221b882c20ab1af", "page": 28, "quote": "The decline in excise taxes are because of a lack of indexation of the specific taxes on tobacco and alcoholic products, use of old prices in classifying such products and reduction in excise on petroleum products.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0047" }, { "text": "This way taxes on the consumers of tobacco and alcoholic products do not have to be increased significantly and the authorities are given longer to phase in all necessary adjustments.", "verbatim": "This way taxes on the consumers of tobacco and alcoholic products do not have to be increased significantly and the authorities are given longer to phase in all necessary adjustments.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-035adb50d69ffe5f", "page": 28, "quote": "This way taxes on the consumers of tobacco and alcoholic products do not have to be increased significantly and the authorities are given longer to phase in all necessary adjustments.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0048" }, { "text": "However, in an imperfectly competitive market – a much more common phenomenon – quality levels between similar excisable products, such as cigarettes, differ widely.", "verbatim": "However, in an imperfectly competitive market – a much more common phenomenon – quality levels between similar excisable products, such as cigarettes, differ widely.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-30d23c57b9d78a17", "page": 30, "quote": "However, in an imperfectly competitive market – a much more common phenomenon – quality levels between similar excisable products, such as cigarettes, differ widely.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0049" }, { "text": "Because the tax per cigarette is fixed, manufacturers can reap the benefits of investments in product differentiation with a smaller price increase (improved quality and greater diversity).", "verbatim": "Because the tax per cigarette is fixed, manufacturers can reap the benefits of investments in product differentiation with a smaller price increase (improved quality and greater diversity).", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-4ebf2689568d7678", "page": 31, "quote": "Because the tax per cigarette is fixed, manufacturers can reap the benefits of investments in product differentiation with a smaller price increase (improved quality and greater diversity).", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0050" }, { "text": "However, quality can be strongly influenced by the counterbalancing forces of specific and ad valorem taxes and therefore deviate from its optimal level (i.e., the quality that would exist as a market outcome in the absence of excises).", "verbatim": "However, quality can be strongly influenced by the counterbalancing forces of specific and ad valorem taxes and therefore deviate from its optimal level (i.e., the quality that would exist as a market outcome in the absence of excises).", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-2646e34303ab2259", "page": 32, "quote": "However, quality can be strongly influenced by the counterbalancing forces of specific and ad valorem taxes and therefore deviate from its optimal level (i.e., the quality that would exist as a market outcome in the absence of excises).", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0051" }, { "text": "However, the impact on product quality is a key concern regarding the efficiency of excise tax policy (Delipalla and Keen, 2006).", "verbatim": "However, the impact on product quality is a key concern regarding the efficiency of excise tax policy (Delipalla and Keen, 2006).", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-790a30dff357edb6", "page": 32, "quote": "However, the impact on product quality is a key concern regarding the efficiency of excise tax policy (Delipalla and Keen, 2006).", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0052" }, { "text": "[32] Limited administrative capacity in many countries may also play a role in the choice of the best tax mix for revenue raising purposes.", "verbatim": "[32] Limited administrative capacity in many countries may also play a role in the choice of the best tax mix for revenue raising purposes.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-c26b2e2d41d71452", "page": 32, "quote": "[32] Limited administrative capacity in many countries may also play a role in the choice of the best tax mix for revenue raising purposes.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0053" }, { "text": "Earmarking is considered ―irrelevant,‖ because the marginal expenditure decision remains firmly in the hands of the budgetary authorities.", "verbatim": "Earmarking is considered ―irrelevant,‖ because the marginal expenditure decision remains firmly in the hands of the budgetary authorities.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-f43d9c46c8ad157b", "page": 33, "quote": "Earmarking is considered ―irrelevant,‖ because the marginal expenditure decision remains firmly in the hands of the budgetary authorities.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0054" }, { "text": "However, earmarking generates budget inefficiencies because it prevents allocation of budget expenditures to their best use.", "verbatim": "However, earmarking generates budget inefficiencies because it prevents allocation of budget expenditures to their best use.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-49f4c5ff816d1e7d", "page": 33, "quote": "However, earmarking generates budget inefficiencies because it prevents allocation of budget expenditures to their best use.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0055" }, { "text": "The case for earmarking, even if the benefit rationale is quite strong, remains tenuous at best.", "verbatim": "The case for earmarking, even if the benefit rationale is quite strong, remains tenuous at best.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-4f5cf8dcbf94c8cb", "page": 33, "quote": "The case for earmarking, even if the benefit rationale is quite strong, remains tenuous at best.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0056" }, { "text": "However, many of the jobs that are counted in estimates of the economic contribution of tobacco are far from dependent on tobacco, but rather involve tobacco in some limited way, often indirectly (e.g.", "verbatim": "However, many of the jobs that are counted in estimates of the economic contribution of tobacco are far from dependent on tobacco, but rather involve tobacco in some limited way, often indirectly (e.g.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-51e5aa3f7ee3d714", "page": 36, "quote": "However, many of the jobs that are counted in estimates of the economic contribution of tobacco are far from dependent on tobacco, but rather involve tobacco in some limited way, often indirectly (e.g.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0057" }, { "text": "In most countries, employment in tobacco dependent sectors has been falling over time as farming techniques have improved and as tobacco product manufacturers have adopted new, more capital intensive production methods.", "verbatim": "In most countries, employment in tobacco dependent sectors has been falling over time as farming techniques have improved and as tobacco product manufacturers have adopted new, more capital intensive production methods.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-18ae0ab45d8a1bff", "page": 37, "quote": "In most countries, employment in tobacco dependent sectors has been falling over time as farming techniques have improved and as tobacco product manufacturers have adopted new, more capital intensive production methods.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0058" }, { "text": "Increases in tobacco taxes or implementation of other tobacco control measures do not lead to net job losses; in many countries, such efforts result in net increases in jobs as spending is shifted to more labor intensive goods and services.", "verbatim": "Increases in tobacco taxes or implementation of other tobacco control measures do not lead to net job losses; in many countries, such efforts result in net increases in jobs as spending is shifted to more labor intensive goods and services.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-5ab0ea2882a07ebd", "page": 37, "quote": "Increases in tobacco taxes or implementation of other tobacco control measures do not lead to net job losses; in many countries, such efforts result in net increases in jobs as spending is shifted to more labor intensive goods and services.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0059" }, { "text": "However, given the current trend in global demand, higher taxes and other tobacco control measures are not likely to result in a sharp drop in demand in the short run, but rather a slowing of the increase in the near term followed by slowly falling demand in the longer term.", "verbatim": "However, given the current trend in global demand, higher taxes and other tobacco control measures are not likely to result in a sharp drop in demand in the short run, but rather a slowing of the increase in the near term followed by slowly falling demand in the longer term.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-5ac10c003775e3ed", "page": 38, "quote": "However, given the current trend in global demand, higher taxes and other tobacco control measures are not likely to result in a sharp drop in demand in the short run, but rather a slowing of the increase in the near term followed by slowly falling demand in the longer term.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0060" }, { "text": "In Turkey, for example, the government sponsored ―alternative crop program‖ that was implemented in anticipation of the privatization of the country‘s cigarette monopoly has proven effective in moving many tobacco farmers to other crops.", "verbatim": "In Turkey, for example, the government sponsored ―alternative crop program‖ that was implemented in anticipation of the privatization of the country‘s cigarette monopoly has proven effective in moving many tobacco farmers to other crops.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-0168deaf2dea59c3", "page": 38, "quote": "In Turkey, for example, the government sponsored ―alternative crop program‖ that was implemented in anticipation of the privatization of the country‘s cigarette monopoly has proven effective in moving many tobacco farmers to other crops.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0061" }, { "text": "Furthermore, the new structure does not differentiate between domestic and imported brands with same alcohol content.", "verbatim": "Furthermore, the new structure does not differentiate between domestic and imported brands with same alcohol content.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-779f1cad6d18773d", "page": 40, "quote": "Furthermore, the new structure does not differentiate between domestic and imported brands with same alcohol content.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0062" }, { "text": "However, this approach will harmonize excise rates along the alcohol content of the beverages.", "verbatim": "However, this approach will harmonize excise rates along the alcohol content of the beverages.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-05470a17413dabcc", "page": 40, "quote": "However, this approach will harmonize excise rates along the alcohol content of the beverages.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0063" }, { "text": "However, given the volume and the increase in the usage, it can be a significant source of revenue with no or very little distortionary effects.", "verbatim": "However, given the volume and the increase in the usage, it can be a significant source of revenue with no or very little distortionary effects.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-16b0e42c1ede2e7f", "page": 41, "quote": "However, given the volume and the increase in the usage, it can be a significant source of revenue with no or very little distortionary effects.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0064" }, { "text": "However, some countries do have specific charges on mobile services on the grounds that the revenues obtained from mobile services can be used to further expand the network, therefore, welfare increasing as in the case of UK.", "verbatim": "However, some countries do have specific charges on mobile services on the grounds that the revenues obtained from mobile services can be used to further expand the network, therefore, welfare increasing as in the case of UK.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-2fdd2141977faf84", "page": 42, "quote": "However, some countries do have specific charges on mobile services on the grounds that the revenues obtained from mobile services can be used to further expand the network, therefore, welfare increasing as in the case of UK.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0065" }, { "text": "Three issues have to be considered in the taxation of mobile telecommunications services: (1) abnormal profits to the operators because of limited spectrum; (2) positive externalities benefiting existing users as the networks expand; and (3) complex pricing schemes by the operating companies that make the tax base difficult to define .", "verbatim": "Three issues have to be considered in the taxation of mobile telecommunications services: (1) abnormal profits to the operators because of limited spectrum; (2) positive externalities benefiting existing users as the networks expand; and (3) complex pricing schemes by the operating companies that make the tax base difficult to define .", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-c0d4644fca69f895", "page": 42, "quote": "Three issues have to be considered in the taxation of mobile telecommunications services: (1) abnormal profits to the operators because of limited spectrum; (2) positive externalities benefiting existing users as the networks expand; and (3) complex pricing schemes by the operating companies that make the tax base difficult to define .", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0066" }, { "text": "The PIT rate schedule has not changed since 1997, while the personal allowance was increased to PHP50,000 in 2008.", "verbatim": "The PIT rate schedule has not changed since 1997, while the personal allowance was increased to PHP50,000 in 2008.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-87838636a803f049", "page": 43, "quote": "The PIT rate schedule has not changed since 1997, while the personal allowance was increased to PHP50,000 in 2008.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0067" }, { "text": "(Table 14) It is desirable to index the rate schedule to inflation accumulated since 1997 in order to retain the progressivity of the tax system in the medium term once the data, which would enable the simulation of the revenue impact of such a policy change, become available.", "verbatim": "(Table 14) It is desirable to index the rate schedule to inflation accumulated since 1997 in order to retain the progressivity of the tax system in the medium term once the data, which would enable the simulation of the revenue impact of such a policy change, become available.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-39adc14aea6eb962", "page": 44, "quote": "(Table 14) It is desirable to index the rate schedule to inflation accumulated since 1997 in order to retain the progressivity of the tax system in the medium term once the data, which would enable the simulation of the revenue impact of such a policy change, become available.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0068" }, { "text": "While the OSD may reduce costs of the self-employed in calculating taxable income, the self-employed whose allowable deductions are limited and whose sales are large enough to afford to calculate taxable income could benefit from the OSD.", "verbatim": "While the OSD may reduce costs of the self-employed in calculating taxable income, the self-employed whose allowable deductions are limited and whose sales are large enough to afford to calculate taxable income could benefit from the OSD.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-1e4c203eb1e33b52", "page": 46, "quote": "While the OSD may reduce costs of the self-employed in calculating taxable income, the self-employed whose allowable deductions are limited and whose sales are large enough to afford to calculate taxable income could benefit from the OSD.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0069" }, { "text": "[45] However, while the withholding tax applies to a wide range of payments made by a company, when a payer is an individual, the withholding tax only applies to payments made in connection with the payer‘s trade or business.", "verbatim": "[45] However, while the withholding tax applies to a wide range of payments made by a company, when a payer is an individual, the withholding tax only applies to payments made in connection with the payer‘s trade or business.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-7d1437a835f0197f", "page": 46, "quote": "[45] However, while the withholding tax applies to a wide range of payments made by a company, when a payer is an individual, the withholding tax only applies to payments made in connection with the payer‘s trade or business.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0070" }, { "text": "However, in the short-term, as the majority of individuals whose income is subject to the top tax rate are those with wage income, a risk that taxpayers will arbitrage the difference between the top PIT rate and CIT rate by incorporating his or her business would not be so imminent even if the CIT rate is reduced further.", "verbatim": "However, in the short-term, as the majority of individuals whose income is subject to the top tax rate are those with wage income, a risk that taxpayers will arbitrage the difference between the top PIT rate and CIT rate by incorporating his or her business would not be so imminent even if the CIT rate is reduced further.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-6175133f08f7592d", "page": 47, "quote": "However, in the short-term, as the majority of individuals whose income is subject to the top tax rate are those with wage income, a risk that taxpayers will arbitrage the difference between the top PIT rate and CIT rate by incorporating his or her business would not be so imminent even if the CIT rate is reduced further.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0071" }, { "text": "However, the current rule does not set any limit for remittances that are exempt from the PIT.", "verbatim": "However, the current rule does not set any limit for remittances that are exempt from the PIT.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-d8a6a9dbee51c485", "page": 48, "quote": "However, the current rule does not set any limit for remittances that are exempt from the PIT.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0072" }, { "text": "Given the seemingly high royalty and excise rates, the current regime does not adequately capture high rents that may occur as evidenced by the low revenue yield.", "verbatim": "Given the seemingly high royalty and excise rates, the current regime does not adequately capture high rents that may occur as evidenced by the low revenue yield.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-4491276b981bf305", "page": 49, "quote": "Given the seemingly high royalty and excise rates, the current regime does not adequately capture high rents that may occur as evidenced by the low revenue yield.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0073" }, { "text": "53 The bearer of the exchange rate risk is not specified in the mining act however, the government is expected to compensate the companies in case of a large currency depreciation.", "verbatim": "53 The bearer of the exchange rate risk is not specified in the mining act however, the government is expected to compensate the companies in case of a large currency depreciation.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-28a8ad15218fa009", "page": 50, "quote": "53 The bearer of the exchange rate risk is not specified in the mining act however, the government is expected to compensate the companies in case of a large currency depreciation.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0074" }, { "text": "However, it is often difficult for the tax administration to establish just what services the management fees cover and whether the charges for these services are arm‘s length.", "verbatim": "However, it is often difficult for the tax administration to establish just what services the management fees cover and whether the charges for these services are arm‘s length.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-38c7ca9d5d147089", "page": 51, "quote": "However, it is often difficult for the tax administration to establish just what services the management fees cover and whether the charges for these services are arm‘s length.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0075" }, { "text": "The fiscal regime does not include the basic features of a progressive system to capture rents.", "verbatim": "The fiscal regime does not include the basic features of a progressive system to capture rents.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-746dfd649c1e5bbf", "page": 51, "quote": "The fiscal regime does not include the basic features of a progressive system to capture rents.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0076" }, { "text": "[55] However, failed explorations and mines that require joint operations may be exempted from ring-fencing.", "verbatim": "[55] However, failed explorations and mines that require joint operations may be exempted from ring-fencing.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-83c649a871cce813", "page": 52, "quote": "[55] However, failed explorations and mines that require joint operations may be exempted from ring-fencing.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0077" }, { "text": "Neither a flat-rate royalty nor a profit tax (such as the CIT) will tax rents effectively, though they may partially do so .", "verbatim": "Neither a flat-rate royalty nor a profit tax (such as the CIT) will tax rents effectively, though they may partially do so .", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-0a6e7b88c9ad466e", "page": 53, "quote": "Neither a flat-rate royalty nor a profit tax (such as the CIT) will tax rents effectively, though they may partially do so .", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0078" }, { "text": "The R-Factor differs from the rate of return method in that it does not take explicit account of the time value of money.", "verbatim": "The R-Factor differs from the rate of return method in that it does not take explicit account of the time value of money.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-55b58a3ca4765dda", "page": 54, "quote": "The R-Factor differs from the rate of return method in that it does not take explicit account of the time value of money.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0079" }, { "text": "To determine the feasibility of any regime, the tax burden, the capture of the resource rent and the progressivity of the fiscal regime have to be evaluated for different types of mining activity such as gold, oil etc.", "verbatim": "To determine the feasibility of any regime, the tax burden, the capture of the resource rent and the progressivity of the fiscal regime have to be evaluated for different types of mining activity such as gold, oil etc.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-73ea98e84b964ad1", "page": 54, "quote": "To determine the feasibility of any regime, the tax burden, the capture of the resource rent and the progressivity of the fiscal regime have to be evaluated for different types of mining activity such as gold, oil etc.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0080" }, { "text": "When the ratio is less than one, payback has not been reached; as it grows to a greater multiple of one, the excess profit tax rate increases.", "verbatim": "When the ratio is less than one, payback has not been reached; as it grows to a greater multiple of one, the excess profit tax rate increases.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-b96e566c62f0d4ee", "page": 54, "quote": "When the ratio is less than one, payback has not been reached; as it grows to a greater multiple of one, the excess profit tax rate increases.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0081" }, { "text": "Whether the ratio increases quickly or slowly does not matter in the calculation, the same excess profit tax rate is still triggered.", "verbatim": "Whether the ratio increases quickly or slowly does not matter in the calculation, the same excess profit tax rate is still triggered.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-fff0a700271f604e", "page": 54, "quote": "Whether the ratio increases quickly or slowly does not matter in the calculation, the same excess profit tax rate is still triggered.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0082" }, { "text": "Three commonly used royalty options can be considered in moving to a mining fiscal regime consistent with international practice and progressive.", "verbatim": "Three commonly used royalty options can be considered in moving to a mining fiscal regime consistent with international practice and progressive.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-7b47da69a6deb93d", "page": 55, "quote": "Three commonly used royalty options can be considered in moving to a mining fiscal regime consistent with international practice and progressive.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0083" }, { "text": "While most countries levy flat-rate ad valorem royalties on the major minerals, a common form of a progressive royalty is a sliding scale royalty with rates that vary by the market price of the mineral.", "verbatim": "While most countries levy flat-rate ad valorem royalties on the major minerals, a common form of a progressive royalty is a sliding scale royalty with rates that vary by the market price of the mineral.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-94727ef1d1d0745f", "page": 55, "quote": "While most countries levy flat-rate ad valorem royalties on the major minerals, a common form of a progressive royalty is a sliding scale royalty with rates that vary by the market price of the mineral.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0084" }, { "text": "Alternatively, adopting a variable royalty rate depending on the ratio of EBIT to sales value would introduce progressivity into the royalty scheme enabling the government to capture some of the excess profits in times on high commodity prices.", "verbatim": "Alternatively, adopting a variable royalty rate depending on the ratio of EBIT to sales value would introduce progressivity into the royalty scheme enabling the government to capture some of the excess profits in times on high commodity prices.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-611f2b97ddc89e20", "page": 56, "quote": "Alternatively, adopting a variable royalty rate depending on the ratio of EBIT to sales value would introduce progressivity into the royalty scheme enabling the government to capture some of the excess profits in times on high commodity prices.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0085" }, { "text": "Differences in tax rules may give MNEs an opportunity for exploring tax arbitrage planning; however, it would increase the costs in doing business.", "verbatim": "Differences in tax rules may give MNEs an opportunity for exploring tax arbitrage planning; however, it would increase the costs in doing business.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-39161f47f7060799", "page": 57, "quote": "Differences in tax rules may give MNEs an opportunity for exploring tax arbitrage planning; however, it would increase the costs in doing business.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0086" }, { "text": "Given the current level of tax administration and taxpayers’ morale, it is unlikely that a tax system solely based on a taxpayer’s voluntary compliance would work effectively.", "verbatim": "Given the current level of tax administration and taxpayers’ morale, it is unlikely that a tax system solely based on a taxpayer’s voluntary compliance would work effectively.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-71e1d072f04e7e6c", "page": 58, "quote": "Given the current level of tax administration and taxpayers’ morale, it is unlikely that a tax system solely based on a taxpayer’s voluntary compliance would work effectively.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0087" }, { "text": "The effectiveness is also a key in using a tax system as measures to achieve policy objectives.", "verbatim": "The effectiveness is also a key in using a tax system as measures to achieve policy objectives.", "topic": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "severity": null, "evidence": [ { "evidence_id": "ev-16f00cb7a54df877", "page": 58, "quote": "The effectiveness is also a key in using a tax system as measures to achieve policy objectives.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0088" }, { "text": "100% [exploration costs] 5% [gold] plus price-based Gross revenue 25% 10 years straight line progressive royalty", "verbatim": "100% [exploration costs] 5% [gold] plus price-based Gross revenue 25% 10 years straight line progressive royalty", "topic": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "severity": null, "evidence": [ { "evidence_id": "ev-ee5f20293a5472ad", "page": 68, "quote": "100% [exploration costs] 5% [gold] plus price-based Gross revenue 25% 10 years straight line progressive royalty", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0089" }, { "text": "100% straight line over effective WA: net Australia Royalty + CIT WA: 2.5% [gold] 29% 4/ asset life (15-20 years for most revenues [gold] mining development) 2/", "verbatim": "100% straight line over effective WA: net Australia Royalty + CIT WA: 2.5% [gold] 29% 4/ asset life (15-20 years for most revenues [gold] mining development) 2/", "topic": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "severity": null, "evidence": [ { "evidence_id": "ev-58cd10b056c6859f", "page": 68, "quote": "100% straight line over effective WA: net Australia Royalty + CIT WA: 2.5% [gold] 29% 4/ asset life (15-20 years for most revenues [gold] mining development) 2/", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0090" }, { "text": "40% straight line first year; 20% Sierra Leone Royalty + CIT 4% [gold] Net revenue 37.5% Exempt … Indefinite None 10% 15% Assumed none in declining balance remaining years […] FARI model.", "verbatim": "40% straight line first year; 20% Sierra Leone Royalty + CIT 4% [gold] Net revenue 37.5% Exempt … Indefinite None 10% 15% Assumed none in declining balance remaining years […] FARI model.", "topic": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "severity": null, "evidence": [ { "evidence_id": "ev-324ca1286f5a2225", "page": 68, "quote": "40% straight line first year; 20% Sierra Leone Royalty + CIT 4% [gold] Net revenue 37.5% Exempt … Indefinite None 10% 15% Assumed none in declining balance remaining years […] FARI model.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0091" }, { "text": "2/ In royalty and tax systems, the investor receives 100 percent of revenues remaining after royalties for recovery of costs.", "verbatim": "2/ In royalty and tax systems, the investor receives 100 percent of revenues remaining after royalties for recovery of costs.", "topic": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "severity": null, "evidence": [ { "evidence_id": "ev-0cf63805ef63efc4", "page": 69, "quote": "2/ In royalty and tax systems, the investor receives 100 percent of revenues remaining after royalties for recovery of costs.", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0092" }, { "text": "Baqir, 2008, ―Investment Incentives and Effective Tax Rates", "verbatim": "Baqir, 2008, ―Investment Incentives and Effective Tax Rates", "topic": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "severity": null, "evidence": [ { "evidence_id": "ev-26f43ad362ce8953", "page": 70, "quote": "Baqir, 2008, ―Investment Incentives and Effective Tax Rates", "source": "document" } ], "confidence": 0.62, "extraction_method": "diagnostic_signal_sentence", "review_status": "unreviewed", "observation_id": "cr-2012-060-obs-0093" } ], "recommendations": [ { "text": "This mission agrees that a unified withholding rate should be applied as the current reduced or zero withholding tax on interest income derived from deposits with long maturity or those in foreign currency benefits mainly wealthy households.", "verbatim": "This mission agrees that a unified withholding rate should be applied as the current reduced or zero withholding tax on interest income derived from deposits with long maturity or those in foreign currency benefits mainly wealthy households.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-ab94c1f02f5a4bdb", "page": 14, "quote": "This mission agrees that a unified withholding rate should be applied as the current reduced or zero withholding tax on interest income derived from deposits with long maturity or those in foreign currency benefits mainly wealthy households.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0001" }, { "text": "VAT : The World Bank did not recommend that VAT on capital inputs should be fully", "verbatim": "VAT : The World Bank did not recommend that VAT on capital inputs should be fully", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-ab85d80bfc9fbe03", "page": 14, "quote": "VAT : The World Bank did not recommend that VAT on capital inputs should be fully", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0002" }, { "text": "Withholding tax on interest : The World Bank recommended that a unified 18 percent", "verbatim": "Withholding tax on interest : The World Bank recommended that a unified 18 percent", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-4096bbb01b4ce237", "page": 14, "quote": "Withholding tax on interest : The World Bank recommended that a unified 18 percent", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0003" }, { "text": "withholding tax should be applied to interest.", "verbatim": "withholding tax should be applied to interest.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-3ea0870c03cb9e80", "page": 14, "quote": "withholding tax should be applied to interest.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0004" }, { "text": "Without repeating the analysis of the 2010 mission, it is worth emphasizing some of the arguments against incentives including: (1) they involve a loss of current and future revenue which usually means that taxes must be higher in other activities which harms economic efficiency and compliance, and causes inequities; (2) tax incentives by their nature", "verbatim": "Without repeating the analysis of the 2010 mission, it is worth emphasizing some of the arguments against incentives including: (1) they involve a loss of current and future revenue which usually means that taxes must be higher in other activities which harms economic efficiency and compliance, and causes inequities; (2) tax incentives by their nature", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-b7be5c9003421e95", "page": 15, "quote": "Without repeating the analysis of the 2010 mission, it is worth emphasizing some of the arguments against incentives including: (1) they involve a loss of current and future revenue which usually means that taxes must be higher in other activities which harms economic efficiency and compliance, and causes inequities; (2) tax incentives by their nature", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0005" }, { "text": "One of the key reasons for providing tax incentives in the Philippines is the concern that the country needs to be competitive with other countries in the region in order to attract Foreign Direct Investment (FDI).", "verbatim": "One of the key reasons for providing tax incentives in the Philippines is the concern that the country needs to be competitive with other countries in the region in order to attract Foreign Direct Investment (FDI).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-65405da29182f99c", "page": 16, "quote": "One of the key reasons for providing tax incentives in the Philippines is the concern that the country needs to be competitive with other countries in the region in order to attract Foreign Direct Investment (FDI).", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0006" }, { "text": "An exporter must export at least 70 percent exporter must export at least 30 percent of production, and if this is not met the of production, and if the exports are exemption is lost.", "verbatim": "An exporter must export at least 70 percent exporter must export at least 30 percent of production, and if this is not met the of production, and if the exports are exemption is lost.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-1901d9ebb0073c4e", "page": 19, "quote": "An exporter must export at least 70 percent exporter must export at least 30 percent of production, and if this is not met the of production, and if the exports are exemption is lost.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0007" }, { "text": "incentive must be apportioned.", "verbatim": "incentive must be apportioned.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-987ec6a4384f79ac", "page": 19, "quote": "incentive must be apportioned.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0008" }, { "text": "In order to align existing firms with the regime offered to new firms, and to reduce the forgone revenue, it is recommended that, if legally possible, the incentives provided to existing investors be grandfathered.", "verbatim": "In order to align existing firms with the regime offered to new firms, and to reduce the forgone revenue, it is recommended that, if legally possible, the incentives provided to existing investors be grandfathered.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-0b218756f6579466", "page": 20, "quote": "In order to align existing firms with the regime offered to new firms, and to reduce the forgone revenue, it is recommended that, if legally possible, the incentives provided to existing investors be grandfathered.", "source": "document" } ], "confidence": 0.92, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "explicit_attributed_statement", "explicitness": "explicit", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0009" }, { "text": "Consideration should also be given to increasing the rate of tax on GIE to 7.5 percent, as recommended by the recent World Bank mission.", "verbatim": "Consideration should also be given to increasing the rate of tax on GIE to 7.5 percent, as recommended by the recent World Bank mission.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-d7a10dc0eca95b8c", "page": 20, "quote": "Consideration should also be given to increasing the rate of tax on GIE to 7.5 percent, as recommended by the recent World Bank mission.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0010" }, { "text": "Consideration should be given to providing taxpayers with only two rate options: an income tax holiday followed by a tax on GIE; or the tax on GIE.", "verbatim": "Consideration should be given to providing taxpayers with only two rate options: an income tax holiday followed by a tax on GIE; or the tax on GIE.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-57d814d2442b6039", "page": 20, "quote": "Consideration should be given to providing taxpayers with only two rate options: an income tax holiday followed by a tax on GIE; or the tax on GIE.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0011" }, { "text": "In the long term, the DOF should be the sole organization responsible for drafting legislation on tax incentives.", "verbatim": "In the long term, the DOF should be the sole organization responsible for drafting legislation on tax incentives.", "actor": null, "priority": null, "timeframe": "long term", "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-a83962787bbafa34", "page": 20, "quote": "In the long term, the DOF should be the sole organization responsible for drafting legislation on tax incentives.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0012" }, { "text": "Once that objective is achieved—or at least enough opportunity given to do so-- the incentive should cease.", "verbatim": "Once that objective is achieved—or at least enough opportunity given to do so-- the incentive should cease.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-6658a2493a974883", "page": 20, "quote": "Once that objective is achieved—or at least enough opportunity given to do so-- the incentive should cease.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0013" }, { "text": "The monitoring of tax expenditures by the DOF and having the incentives in a single law are consistent with the recommendations of the 2010 mission and should make the system simpler and more transparent.", "verbatim": "The monitoring of tax expenditures by the DOF and having the incentives in a single law are consistent with the recommendations of the 2010 mission and should make the system simpler and more transparent.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-7f521949cc50871e", "page": 20, "quote": "The monitoring of tax expenditures by the DOF and having the incentives in a single law are consistent with the recommendations of the 2010 mission and should make the system simpler and more transparent.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0014" }, { "text": "The period for providing incentives is still too long and should be reduced.", "verbatim": "The period for providing incentives is still too long and should be reduced.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-24ee036b79e741e5", "page": 20, "quote": "The period for providing incentives is still too long and should be reduced.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0015" }, { "text": "This regime, together with a reduction in the CIT rate, should enhance make the Philippines‘ attractiveness to investors.", "verbatim": "This regime, together with a reduction in the CIT rate, should enhance make the Philippines‘ attractiveness to investors.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-e0263bb7207f4dd2", "page": 21, "quote": "This regime, together with a reduction in the CIT rate, should enhance make the Philippines‘ attractiveness to investors.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0016" }, { "text": "While the narrowing of the activities eligible for incentives is a positive step, effort should be made to ensure the list of activities under the Investment Priorities Plan (IPP) is also reduced.", "verbatim": "While the narrowing of the activities eligible for incentives is a positive step, effort should be made to ensure the list of activities under the Investment Priorities Plan (IPP) is also reduced.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-e2055386ce46a2d4", "page": 21, "quote": "While the narrowing of the activities eligible for incentives is a positive step, effort should be made to ensure the list of activities under the Investment Priorities Plan (IPP) is also reduced.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0017" }, { "text": "This increased investment should lead to greater employment opportunities, which should benefit all Filipinos, including the poor.", "verbatim": "This increased investment should lead to greater employment opportunities, which should benefit all Filipinos, including the poor.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-6f515bb374bb60ca", "page": 22, "quote": "This increased investment should lead to greater employment opportunities, which should benefit all Filipinos, including the poor.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0018" }, { "text": "19 Membership of cooperatives is limited to natural persons and there must be at least 15 members, with no member holding more than 10 percent of the share capital.", "verbatim": "19 Membership of cooperatives is limited to natural persons and there must be at least 15 members, with no member holding more than 10 percent of the share capital.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-d4319b27716fe39e", "page": 23, "quote": "19 Membership of cooperatives is limited to natural persons and there must be at least 15 members, with no member holding more than 10 percent of the share capital.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0019" }, { "text": "Most cooperatives are conducting business activities in the same manner as other commercial enterprises, and therefore should be taxed in a similar manner.", "verbatim": "Most cooperatives are conducting business activities in the same manner as other commercial enterprises, and therefore should be taxed in a similar manner.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-fdbaccb3f3dbe3a7", "page": 24, "quote": "Most cooperatives are conducting business activities in the same manner as other commercial enterprises, and therefore should be taxed in a similar manner.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0020" }, { "text": "The taxes that should apply are income tax (at the cooperative level at the CIT rate), VAT, and import duties.", "verbatim": "The taxes that should apply are income tax (at the cooperative level at the CIT rate), VAT, and import duties.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-dabc569f45edbd86", "page": 24, "quote": "The taxes that should apply are income tax (at the cooperative level at the CIT rate), VAT, and import duties.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0021" }, { "text": "22 A different ratio should apply to financial institutions whose business consists in borrowing and lending and which typically operate at much higher debt levels than other businesses.", "verbatim": "22 A different ratio should apply to financial institutions whose business consists in borrowing and lending and which typically operate at much higher debt levels than other businesses.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-b3204a0aebd727a9", "page": 26, "quote": "22 A different ratio should apply to financial institutions whose business consists in borrowing and lending and which typically operate at much higher debt levels than other businesses.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0022" }, { "text": "[21] To counter this practice, the tax rule needs to deny deductions for interest in defined cases.", "verbatim": "[21] To counter this practice, the tax rule needs to deny deductions for interest in defined cases.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-7ede9fb07dca0003", "page": 26, "quote": "[21] To counter this practice, the tax rule needs to deny deductions for interest in defined cases.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0023" }, { "text": "[22] In setting the appropriate financial ratios, data on funding by Philippine companies should be examined in order to minimize the risk of interfering in legitimate business activities.", "verbatim": "[22] In setting the appropriate financial ratios, data on funding by Philippine companies should be examined in order to minimize the risk of interfering in legitimate business activities.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-efed741a713de0c6", "page": 26, "quote": "[22] In setting the appropriate financial ratios, data on funding by Philippine companies should be examined in order to minimize the risk of interfering in legitimate business activities.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0024" }, { "text": "However, the BIR still cannot access the bank accounts for its own needs to combat tax evasion and avoidance .", "verbatim": "However, the BIR still cannot access the bank accounts for its own needs to combat tax evasion and avoidance .", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-5abab353ab85c89a", "page": 27, "quote": "However, the BIR still cannot access the bank accounts for its own needs to combat tax evasion and avoidance .", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0025" }, { "text": "The BIR should utilize the Philippines’ extensive DTA network [27] to tackle tax evasion or avoidance using overseas banks by the Philippine taxpayers.", "verbatim": "The BIR should utilize the Philippines’ extensive DTA network [27] to tackle tax evasion or avoidance using overseas banks by the Philippine taxpayers.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-002b122c5d22dff5", "page": 27, "quote": "The BIR should utilize the Philippines’ extensive DTA network [27] to tackle tax evasion or avoidance using overseas banks by the Philippine taxpayers.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0026" }, { "text": "This contradictory rule that bank secrecy is lifted only for foreign governments‘ needs should be changed.", "verbatim": "This contradictory rule that bank secrecy is lifted only for foreign governments‘ needs should be changed.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-8739f4e9d6ca2e98", "page": 27, "quote": "This contradictory rule that bank secrecy is lifted only for foreign governments‘ needs should be changed.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0027" }, { "text": "The mission recommends a gradual approach in implementing excise tax adjustment.", "verbatim": "The mission recommends a gradual approach in implementing excise tax adjustment.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-3c7236b0c5c53c29", "page": 28, "quote": "The mission recommends a gradual approach in implementing excise tax adjustment.", "source": "document" } ], "confidence": 0.92, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "explicit_attributed_statement", "explicitness": "explicit", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0028" }, { "text": "Excises should be increased within a timeframe of three years in order to bring the share of excise taxes in GDP to their 1997 levels.", "verbatim": "Excises should be increased within a timeframe of three years in order to bring the share of excise taxes in GDP to their 1997 levels.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-5588b518382d38ce", "page": 28, "quote": "Excises should be increased within a timeframe of three years in order to bring the share of excise taxes in GDP to their 1997 levels.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0029" }, { "text": "Many excise rates need to be increased in order to increase the overall tax to GDP ratio.", "verbatim": "Many excise rates need to be increased in order to increase the overall tax to GDP ratio.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-dea10f9d6690ea43", "page": 28, "quote": "Many excise rates need to be increased in order to increase the overall tax to GDP ratio.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0030" }, { "text": "29 An argument could be made that the specific tax rate for unfiltered cigarettes should actually be higher than filtered cigarettes, as the health risks and associated costs imposed on the health care system are higher.", "verbatim": "29 An argument could be made that the specific tax rate for unfiltered cigarettes should actually be higher than filtered cigarettes, as the health risks and associated costs imposed on the health care system are higher.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-6176ff10f0d361a9", "page": 30, "quote": "29 An argument could be made that the specific tax rate for unfiltered cigarettes should actually be higher than filtered cigarettes, as the health risks and associated costs imposed on the health care system are higher.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0031" }, { "text": "Accordingly, a rational tax structure should be based on tobacco content, not relative values.", "verbatim": "Accordingly, a rational tax structure should be based on tobacco content, not relative values.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-fb978d627c296bc8", "page": 30, "quote": "Accordingly, a rational tax structure should be based on tobacco content, not relative values.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0032" }, { "text": "As the tobacco content for cigarettes, both filtered and unfiltered, tends to be the same, averaging around one gram per stick, the rate for these two products should be the same.", "verbatim": "As the tobacco content for cigarettes, both filtered and unfiltered, tends to be the same, averaging around one gram per stick, the rate for these two products should be the same.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-1940543fcbf01c92", "page": 30, "quote": "As the tobacco content for cigarettes, both filtered and unfiltered, tends to be the same, averaging around one gram per stick, the rate for these two products should be the same.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0033" }, { "text": "A good tax system should minimize distortion of economic choices, including quality of the product.", "verbatim": "A good tax system should minimize distortion of economic choices, including quality of the product.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-c936b3ca72b4bb79", "page": 32, "quote": "A good tax system should minimize distortion of economic choices, including quality of the product.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0034" }, { "text": "An optimal tax system should therefore use both taxes in a way that would leave quality unchanged, compared to the hypothetical ―no-excise‖ world.", "verbatim": "An optimal tax system should therefore use both taxes in a way that would leave quality unchanged, compared to the hypothetical ―no-excise‖ world.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-8a3ba47a989198a3", "page": 32, "quote": "An optimal tax system should therefore use both taxes in a way that would leave quality unchanged, compared to the hypothetical ―no-excise‖ world.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0035" }, { "text": "DOF should consider alternative phase-in options of the new excise rates in order to avoid brand switching and minimize illegal trade of tobacco products.", "verbatim": "DOF should consider alternative phase-in options of the new excise rates in order to avoid brand switching and minimize illegal trade of tobacco products.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-276023606e2d5ff2", "page": 35, "quote": "DOF should consider alternative phase-in options of the new excise rates in order to avoid brand switching and minimize illegal trade of tobacco products.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0036" }, { "text": "The rate increase proposed by DOF is consistent with the excises in the region; however, phasing-in should not trigger contrabanding and counterfeiting of cigarettes.", "verbatim": "The rate increase proposed by DOF is consistent with the excises in the region; however, phasing-in should not trigger contrabanding and counterfeiting of cigarettes.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-0e71e440a37db801", "page": 35, "quote": "The rate increase proposed by DOF is consistent with the excises in the region; however, phasing-in should not trigger contrabanding and counterfeiting of cigarettes.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0037" }, { "text": "Future indexation should maintain a specific excise rate such that the share of the excise in the price remains over 50 percent and gradually increases to 70 percent as recommended by the WHO.", "verbatim": "Future indexation should maintain a specific excise rate such that the share of the excise in the price remains over 50 percent and gradually increases to 70 percent as recommended by the WHO.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-4e60e3d32b6bb23a", "page": 36, "quote": "Future indexation should maintain a specific excise rate such that the share of the excise in the price remains over 50 percent and gradually increases to 70 percent as recommended by the WHO.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0038" }, { "text": "So, DOF should aim to reach the tobacco excise-GDP ratio of 1997 by 2014.", "verbatim": "So, DOF should aim to reach the tobacco excise-GDP ratio of 1997 by 2014.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-7d2357c7630dc66b", "page": 36, "quote": "So, DOF should aim to reach the tobacco excise-GDP ratio of 1997 by 2014.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0039" }, { "text": "The adjustments to the specific rates after 2014 should be based on the CPI rather than an index of tobacco products as proposed by the DOF.", "verbatim": "The adjustments to the specific rates after 2014 should be based on the CPI rather than an index of tobacco products as proposed by the DOF.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-86e86781b7c9feb5", "page": 36, "quote": "The adjustments to the specific rates after 2014 should be based on the CPI rather than an index of tobacco products as proposed by the DOF.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0040" }, { "text": "Rising incomes and population growth should offset any negative impact on employment (Jacobs, et al., 2000).", "verbatim": "Rising incomes and population growth should offset any negative impact on employment (Jacobs, et al., 2000).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-3b719b3c91997a21", "page": 37, "quote": "Rising incomes and population growth should offset any negative impact on employment (Jacobs, et al., 2000).", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0041" }, { "text": "The new excise taxes on alcoholic beverages should be set according to alcohol", "verbatim": "The new excise taxes on alcoholic beverages should be set according to alcohol", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-70c373262571a6de", "page": 40, "quote": "The new excise taxes on alcoholic beverages should be set according to alcohol", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0042" }, { "text": "In order to increase the tax to GDP ratio, and reduce the extent of increases in excise on products like petroleum, tobacco and alcoholic products, authorities should look into the possibility of taxing mobile phone communications at a very low rate per call.", "verbatim": "In order to increase the tax to GDP ratio, and reduce the extent of increases in excise on products like petroleum, tobacco and alcoholic products, authorities should look into the possibility of taxing mobile phone communications at a very low rate per call.", "actor": null, "priority": "low", "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-0328db8a61cd2ccb", "page": 41, "quote": "In order to increase the tax to GDP ratio, and reduce the extent of increases in excise on products like petroleum, tobacco and alcoholic products, authorities should look into the possibility of taxing mobile phone communications at a very low rate per call.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0043" }, { "text": "The specific rate on gasoline should be increased from its current levels after phasing", "verbatim": "The specific rate on gasoline should be increased from its current levels after phasing", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-b610067e9952b965", "page": 41, "quote": "The specific rate on gasoline should be increased from its current levels after phasing", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0044" }, { "text": "Dual withholding rates based on the current year‘s income of a recipient needs to be reviewed in order to reduce compliance costs of withholding agents.", "verbatim": "Dual withholding rates based on the current year‘s income of a recipient needs to be reviewed in order to reduce compliance costs of withholding agents.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-c2d23f9f95f732f6", "page": 46, "quote": "Dual withholding rates based on the current year‘s income of a recipient needs to be reviewed in order to reduce compliance costs of withholding agents.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0045" }, { "text": "Given the level of income inequity in the Philippines, [48] reducing the top PIT rate to 25 percent as the World Bank recommended would compromise progressivity and needs to be considered carefully as a part of a comprehensive tax reform plan.", "verbatim": "Given the level of income inequity in the Philippines, [48] reducing the top PIT rate to 25 percent as the World Bank recommended would compromise progressivity and needs to be considered carefully as a part of a comprehensive tax reform plan.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-471c57996b916142", "page": 47, "quote": "Given the level of income inequity in the Philippines, [48] reducing the top PIT rate to 25 percent as the World Bank recommended would compromise progressivity and needs to be considered carefully as a part of a comprehensive tax reform plan.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0046" }, { "text": "The World Bank mission recommended that the top PIT rate be aligned with the CIT rate to reduce arbitrage opportunities between the PIT and CIT regimes.", "verbatim": "The World Bank mission recommended that the top PIT rate be aligned with the CIT rate to reduce arbitrage opportunities between the PIT and CIT regimes.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-e996df4314743c52", "page": 47, "quote": "The World Bank mission recommended that the top PIT rate be aligned with the CIT rate to reduce arbitrage opportunities between the PIT and CIT regimes.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0047" }, { "text": "Considering that the average amount of remittance per worker in 2010 is about US$2,600 per year, a ceiling that is high enough not to affect legitimate remittances by OCWs or OFWs, say US$25,000 per year, should be set.", "verbatim": "Considering that the average amount of remittance per worker in 2010 is about US$2,600 per year, a ceiling that is high enough not to affect legitimate remittances by OCWs or OFWs, say US$25,000 per year, should be set.", "actor": null, "priority": "high", "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-05a85df988ef70ff", "page": 48, "quote": "Considering that the average amount of remittance per worker in 2010 is about US$2,600 per year, a ceiling that is high enough not to affect legitimate remittances by OCWs or OFWs, say US$25,000 per year, should be set.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0048" }, { "text": "The refluxed money could have been income that should have been but was not taxed in the Philippines.", "verbatim": "The refluxed money could have been income that should have been but was not taxed in the Philippines.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-f3101f6d6f153907", "page": 48, "quote": "The refluxed money could have been income that should have been but was not taxed in the Philippines.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0049" }, { "text": "While the workers must be registered with the Philippine Overseas Employment Administration (POEA) with a valid Overseas Employment Certificate (OEC), the current unlimited tax-free treatment may open a way for the wealthy to return their overseas money to the Philippines without being taxed in disguise of OCWs or OFWs.", "verbatim": "While the workers must be registered with the Philippine Overseas Employment Administration (POEA) with a valid Overseas Employment Certificate (OEC), the current unlimited tax-free treatment may open a way for the wealthy to return their overseas money to the Philippines without being taxed in disguise of OCWs or OFWs.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-01b6ec7fa02cb8e8", "page": 48, "quote": "While the workers must be registered with the Philippine Overseas Employment Administration (POEA) with a valid Overseas Employment Certificate (OEC), the current unlimited tax-free treatment may open a way for the wealthy to return their overseas money to the Philippines without being taxed in disguise of OCWs or OFWs.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0050" }, { "text": "However, the loss carry forward period should be considered short for cost recovery.", "verbatim": "However, the loss carry forward period should be considered short for cost recovery.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-fd5ea48e55546eaa", "page": 50, "quote": "However, the loss carry forward period should be considered short for cost recovery.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0051" }, { "text": "Should a foreign investor determine that it is economically the best choice to have a local partner, it would do so.", "verbatim": "Should a foreign investor determine that it is economically the best choice to have a local partner, it would do so.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-58c0d88b0c659543", "page": 50, "quote": "Should a foreign investor determine that it is economically the best choice to have a local partner, it would do so.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0052" }, { "text": "A separate section on mining taxation should be introduced in the Corporate Tax Chapter of the NIRC.", "verbatim": "A separate section on mining taxation should be introduced in the Corporate Tax Chapter of the NIRC.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-313467dab1447dd0", "page": 51, "quote": "A separate section on mining taxation should be introduced in the Corporate Tax Chapter of the NIRC.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0053" }, { "text": "Given the importance of the mining sector and the need to protect government revenue, management fees, say in excess of 2 percent of revenue, are in many countries disallowed as a business expense (A separate mining section in Chapter IV of the National Internal Revenue Code (NIRC) on tax corporations could include this a special rule).", "verbatim": "Given the importance of the mining sector and the need to protect government revenue, management fees, say in excess of 2 percent of revenue, are in many countries disallowed as a business expense (A separate mining section in Chapter IV of the National Internal Revenue Code (NIRC) on tax corporations could include this a special rule).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-3eb0385cf98a7372", "page": 51, "quote": "Given the importance of the mining sector and the need to protect government revenue, management fees, say in excess of 2 percent of revenue, are in many countries disallowed as a business expense (A separate mining section in Chapter IV of the National Internal Revenue Code (NIRC) on tax corporations could include this a special rule).", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0054" }, { "text": "To avoid income shifting, transfer price rules applicable to all taxpayers should be enforced for mining companies as well.", "verbatim": "To avoid income shifting, transfer price rules applicable to all taxpayers should be enforced for mining companies as well.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-f1b65a481c0ae4e9", "page": 51, "quote": "To avoid income shifting, transfer price rules applicable to all taxpayers should be enforced for mining companies as well.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0055" }, { "text": "In general, expenses at Mine B incurred by a company already producing at Mine A should not be deductible against income from Mine A.", "verbatim": "In general, expenses at Mine B incurred by a company already producing at Mine A should not be deductible against income from Mine A.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-2f0b48e40871de6b", "page": 52, "quote": "In general, expenses at Mine B incurred by a company already producing at Mine A should not be deductible against income from Mine A.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0056" }, { "text": "Tax accounts for the CIT and any surcharge should be ring-fenced by mining license.", "verbatim": "Tax accounts for the CIT and any surcharge should be ring-fenced by mining license.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-56c47975f1f3f1e9", "page": 52, "quote": "Tax accounts for the CIT and any surcharge should be ring-fenced by mining license.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0057" }, { "text": "Some instruments may work better than others in capturing supernormal profits, and some may be quite distorting and should be rejected although they may be used in certain countries.", "verbatim": "Some instruments may work better than others in capturing supernormal profits, and some may be quite distorting and should be rejected although they may be used in certain countries.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-9e9cad98d3fb0fa5", "page": 53, "quote": "Some instruments may work better than others in capturing supernormal profits, and some may be quite distorting and should be rejected although they may be used in certain countries.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0058" }, { "text": "The key design features of a mining fiscal regime should have the following characteristics :", "verbatim": "The key design features of a mining fiscal regime should have the following characteristics :", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-66190f96512a914d", "page": 53, "quote": "The key design features of a mining fiscal regime should have the following characteristics :", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0059" }, { "text": "Over the long-term, migration towards the tax surcharge on cash flow method (or profit-based) is recommended.", "verbatim": "Over the long-term, migration towards the tax surcharge on cash flow method (or profit-based) is recommended.", "actor": null, "priority": null, "timeframe": "long-term", "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-0f64472702c56501", "page": 54, "quote": "Over the long-term, migration towards the tax surcharge on cash flow method (or profit-based) is recommended.", "source": "document" } ], "confidence": 0.92, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "explicit_attributed_statement", "explicitness": "explicit", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0060" }, { "text": "If the goal is to capture a share of supernormal profits, the tax base should be some measure of profits and not sales or turnover .", "verbatim": "If the goal is to capture a share of supernormal profits, the tax base should be some measure of profits and not sales or turnover .", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-b25dbb5d24030238", "page": 54, "quote": "If the goal is to capture a share of supernormal profits, the tax base should be some measure of profits and not sales or turnover .", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0061" }, { "text": "As with all taxes, the administrative capacity must exist to monitor closely production volumes, sales and their respective fair market values .", "verbatim": "As with all taxes, the administrative capacity must exist to monitor closely production volumes, sales and their respective fair market values .", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-e8883bc0f521194e", "page": 56, "quote": "As with all taxes, the administrative capacity must exist to monitor closely production volumes, sales and their respective fair market values .", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0062" }, { "text": "If a single royalty rate is used, there is no need to determine the amount of minerals contained in the product sold (e.g., concentrate).", "verbatim": "If a single royalty rate is used, there is no need to determine the amount of minerals contained in the product sold (e.g., concentrate).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-39c8eb0e6cd118da", "page": 56, "quote": "If a single royalty rate is used, there is no need to determine the amount of minerals contained in the product sold (e.g., concentrate).", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0063" }, { "text": "The specific rate expressed in pesos per ton or unit should however annually be adjusted with CPI to keep the royalty rate constant in real terms.", "verbatim": "The specific rate expressed in pesos per ton or unit should however annually be adjusted with CPI to keep the royalty rate constant in real terms.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-53212a1d88330993", "page": 56, "quote": "The specific rate expressed in pesos per ton or unit should however annually be adjusted with CPI to keep the royalty rate constant in real terms.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0064" }, { "text": "As a strong political will is indispensable in realizing tax reform, a road map for tax reform needs to be based on political timelines.", "verbatim": "As a strong political will is indispensable in realizing tax reform, a road map for tax reform needs to be based on political timelines.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-4b6ab0de17f63878", "page": 58, "quote": "As a strong political will is indispensable in realizing tax reform, a road map for tax reform needs to be based on political timelines.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0065" }, { "text": "At least, tax provisions that are prone to abuse should be changed.", "verbatim": "At least, tax provisions that are prone to abuse should be changed.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-1787b8322eddd527", "page": 58, "quote": "At least, tax provisions that are prone to abuse should be changed.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0066" }, { "text": "In reforming the issues that require prudent consideration (e.g., excise on mobile communications) and supporting data (e.g., restructuring a PIT rate schedule), or the issues that need to be addressed comprehensively, a rough-and-ready approach should be avoided.", "verbatim": "In reforming the issues that require prudent consideration (e.g., excise on mobile communications) and supporting data (e.g., restructuring a PIT rate schedule), or the issues that need to be addressed comprehensively, a rough-and-ready approach should be avoided.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-4c38c29732586ad3", "page": 58, "quote": "In reforming the issues that require prudent consideration (e.g., excise on mobile communications) and supporting data (e.g., restructuring a PIT rate schedule), or the issues that need to be addressed comprehensively, a rough-and-ready approach should be avoided.", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0067" }, { "text": "While the tax system may not be a primary cause of the inequity, tax provisions that unduly benefit the wealthy should be changed (e.g., exemption or reduced tax rate on capital gains from sales of shares or interest on bank deposits with long maturity).", "verbatim": "While the tax system may not be a primary cause of the inequity, tax provisions that unduly benefit the wealthy should be changed (e.g., exemption or reduced tax rate on capital gains from sales of shares or interest on bank deposits with long maturity).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Kiyoshi Nakayama, Selcuk Caner, and Peter Mullins November 2011", "evidence": [ { "evidence_id": "ev-d65c6b45d4cd8783", "page": 58, "quote": "While the tax system may not be a primary cause of the inequity, tax provisions that unduly benefit the wealthy should be changed (e.g., exemption or reduced tax rate on capital gains from sales of shares or interest on bank deposits with long maturity).", "source": "document" } ], "confidence": 0.65, "extraction_method": "explicit_recommendation_modal", "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "explicitness": "implicit_candidate", "confidence_tier": "medium", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0068" }, { "text": "A reform plan for tax incentives should be announced before the end of 2010, for implementation over the medium term.", "verbatim": "A reform plan for tax incentives should be announced before the end of 2010, for implementation over the medium term.", "actor": null, "priority": "medium", "timeframe": "medium term", "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-2201decdb065aa14", "page": 61, "quote": "A reform plan for tax incentives should be announced before the end of 2010, for implementation over the medium term.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0069" }, { "text": "Ensure the incentives are available to for all eligible taxpayers.", "verbatim": "Ensure the incentives are available to for all eligible taxpayers.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-0b7b9c5f9efa513d", "page": 61, "quote": "Ensure the incentives are available to for all eligible taxpayers.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0070" }, { "text": "Increase the loss carry forward period to 5 years.", "verbatim": "Increase the loss carry forward period to 5 years.", "actor": null, "priority": null, "timeframe": "5 years", "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-85d915b68b5af6c6", "page": 61, "quote": "Increase the loss carry forward period to 5 years.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0071" }, { "text": "Reduce the CIT rate to between 20–25 percent.", "verbatim": "Reduce the CIT rate to between 20–25 percent.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-4667424ac604812d", "page": 61, "quote": "Reduce the CIT rate to between 20–25 percent.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0072" }, { "text": "To avoid sharp revenue decline, phasing of the CIT rate reduction should be considered.", "verbatim": "To avoid sharp revenue decline, phasing of the CIT rate reduction should be considered.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-54e67613e4bb1945", "page": 61, "quote": "To avoid sharp revenue decline, phasing of the CIT rate reduction should be considered.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0073" }, { "text": "If incentives are to be granted for investment, then provide accelerated depreciation or investment tax credits—specified in terms of proportionate rates on the amount of investment in the targeted activities or locations—that reward the actual act of investment; and", "verbatim": "If incentives are to be granted for investment, then provide accelerated depreciation or investment tax credits—specified in terms of proportionate rates on the amount of investment in the targeted activities or locations—that reward the actual act of investment; and", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-d70c52371c4fda0c", "page": 61, "quote": "If incentives are to be granted for investment, then provide accelerated depreciation or investment tax credits—specified in terms of proportionate rates on the amount of investment in the targeted activities or locations—that reward the actual act of investment; and", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0074" }, { "text": "In special economic zones, do not provide income tax incentives but restrict incentives to exemptions for import duties and zero-rating VAT on exports— removing the current VAT zero-rating for suppliers to zones—and limit the zones to designated areas which can be closely monitored (this does not limit the provision of other non-tax incentives such as waiver of fees or provision of infrastructure or services).", "verbatim": "In special economic zones, do not provide income tax incentives but restrict incentives to exemptions for import duties and zero-rating VAT on exports— removing the current VAT zero-rating for suppliers to zones—and limit the zones to designated areas which can be closely monitored (this does not limit the provision of other non-tax incentives such as waiver of fees or provision of infrastructure or services).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-e70d0f13c99e2eff", "page": 61, "quote": "In special economic zones, do not provide income tax incentives but restrict incentives to exemptions for import duties and zero-rating VAT on exports— removing the current VAT zero-rating for suppliers to zones—and limit the zones to designated areas which can be closely monitored (this does not limit the provision of other non-tax incentives such as waiver of fees or provision of infrastructure or services).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0075" }, { "text": "Limit tax holidays to a few very specific investments/sectors, with clear criteria and a duration of no more than 5 years in total (with no extensions).", "verbatim": "Limit tax holidays to a few very specific investments/sectors, with clear criteria and a duration of no more than 5 years in total (with no extensions).", "actor": null, "priority": null, "timeframe": "5 years", "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-c345deab7945591e", "page": 61, "quote": "Limit tax holidays to a few very specific investments/sectors, with clear criteria and a duration of no more than 5 years in total (with no extensions).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0076" }, { "text": "Remove all tax holidays and the 5 percent gross income tax—grandfathering existing investors for those incentives which are time-bound, and phasing out those incentives which are not time-bound within a reasonable time frame.", "verbatim": "Remove all tax holidays and the 5 percent gross income tax—grandfathering existing investors for those incentives which are time-bound, and phasing out those incentives which are not time-bound within a reasonable time frame.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-db7d7eadd30f35cf", "page": 61, "quote": "Remove all tax holidays and the 5 percent gross income tax—grandfathering existing investors for those incentives which are time-bound, and phasing out those incentives which are not time-bound within a reasonable time frame.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0077" }, { "text": "Remove the 5 percent gross income tax; apply the standard corporate income tax when tax holidays expire.", "verbatim": "Remove the 5 percent gross income tax; apply the standard corporate income tax when tax holidays expire.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-8cd5201b08bfedb3", "page": 61, "quote": "Remove the 5 percent gross income tax; apply the standard corporate income tax when tax holidays expire.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0078" }, { "text": "Two options are possible, with a preference for the first:", "verbatim": "Two options are possible, with a preference for the first:", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-738c14099833dae7", "page": 61, "quote": "Two options are possible, with a preference for the first:", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0079" }, { "text": "Clarify the application of excise taxes on imported goods by specifying that the customs duty is included in the base of ad-valorem excises.", "verbatim": "Clarify the application of excise taxes on imported goods by specifying that the customs duty is included in the base of ad-valorem excises.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-282fea517d4b9247", "page": 62, "quote": "Clarify the application of excise taxes on imported goods by specifying that the customs duty is included in the base of ad-valorem excises.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0080" }, { "text": "Ensure the DOF has a strong role in the granting of incentives, such as by being a member of the board of the approving agency, and ensure that the revenue costs of any new incentives are estimated.", "verbatim": "Ensure the DOF has a strong role in the granting of incentives, such as by being a member of the board of the approving agency, and ensure that the revenue costs of any new incentives are estimated.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-b33bee8b863505a7", "page": 62, "quote": "Ensure the DOF has a strong role in the granting of incentives, such as by being a member of the board of the approving agency, and ensure that the revenue costs of any new incentives are estimated.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0081" }, { "text": "Announce in the next budget that exemptions that target directly individuals (e.g., the recently enacted senior citizens exemption and boy scouts exemption) will be reviewed in three years to determine whether they have achieved their objectives in helping low-income seniors and developing boy scouts, and at what cost.", "verbatim": "Announce in the next budget that exemptions that target directly individuals (e.g., the recently enacted senior citizens exemption and boy scouts exemption) will be reviewed in three years to determine whether they have achieved their objectives in helping low-income seniors and developing boy scouts, and at what cost.", "actor": null, "priority": "low", "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-326ce87b13ac5296", "page": 62, "quote": "Announce in the next budget that exemptions that target directly individuals (e.g., the recently enacted senior citizens exemption and boy scouts exemption) will be reviewed in three years to determine whether they have achieved their objectives in helping low-income seniors and developing boy scouts, and at what cost.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0082" }, { "text": "Authorize only one agency to grant tax incentives; once granted, the ongoing monitoring of the incentives would be the responsibility of the BIR and BOC.", "verbatim": "Authorize only one agency to grant tax incentives; once granted, the ongoing monitoring of the incentives would be the responsibility of the BIR and BOC.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-66ec195f704a16d7", "page": 62, "quote": "Authorize only one agency to grant tax incentives; once granted, the ongoing monitoring of the incentives would be the responsibility of the BIR and BOC.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0083" }, { "text": "Cigars, chewing and other bulk tobacco could be taxed at different rates based on units (for cigars) and kilograms (for other tobacco products).", "verbatim": "Cigars, chewing and other bulk tobacco could be taxed at different rates based on units (for cigars) and kilograms (for other tobacco products).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-375c0c0026d36c13", "page": 62, "quote": "Cigars, chewing and other bulk tobacco could be taxed at different rates based on units (for cigars) and kilograms (for other tobacco products).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0084" }, { "text": "Eliminate the practice of price categorization of cigarettes, and set specific rates (per unit or pack) to reach a certain revenue target (starting at the lower end of the most popular cigarettes, and gradually increasing the rates to meet the revenue target in the medium-term).", "verbatim": "Eliminate the practice of price categorization of cigarettes, and set specific rates (per unit or pack) to reach a certain revenue target (starting at the lower end of the most popular cigarettes, and gradually increasing the rates to meet the revenue target in the medium-term).", "actor": null, "priority": "medium", "timeframe": "medium-term", "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-76bdb2d7ef3cf657", "page": 62, "quote": "Eliminate the practice of price categorization of cigarettes, and set specific rates (per unit or pack) to reach a certain revenue target (starting at the lower end of the most popular cigarettes, and gradually increasing the rates to meet the revenue target in the medium-term).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0085" }, { "text": "Grandfather existing investors for those incentives which are time-bound, and phase out those incentives which are not time-bound within a reasonable time frame.", "verbatim": "Grandfather existing investors for those incentives which are time-bound, and phase out those incentives which are not time-bound within a reasonable time frame.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-627b5f3ae1ea36c6", "page": 62, "quote": "Grandfather existing investors for those incentives which are time-bound, and phase out those incentives which are not time-bound within a reasonable time frame.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0086" }, { "text": "Impose a sunset clause for all incentive laws, of no more than 5 years, to ensure the incentives are achieving the purpose for which they were introduced.", "verbatim": "Impose a sunset clause for all incentive laws, of no more than 5 years, to ensure the incentives are achieving the purpose for which they were introduced.", "actor": null, "priority": null, "timeframe": "5 years", "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-263c8a7a1532c335", "page": 21, "quote": "The incentive laws should all include a sunset clause, of no more than 5 years, to ensure the incentives are achieving the purpose for which they were introduced.", "source": "document" }, { "evidence_id": "ev-3e0f4d4e595ca787", "page": 62, "quote": "Impose a sunset clause for all incentive laws, of no more than 5 years, to ensure the incentives are achieving the purpose for which they were introduced.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0087" }, { "text": "Legislate that the laws granting incentives be maintained in one law, preferably the National Internal Revenue Code (NIRC); and", "verbatim": "Legislate that the laws granting incentives be maintained in one law, preferably the National Internal Revenue Code (NIRC); and", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-612f114327431e01", "page": 62, "quote": "Legislate that the laws granting incentives be maintained in one law, preferably the National Internal Revenue Code (NIRC); and", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0088" }, { "text": "Restrict tax incentives in special economic zones to exemptions for import duties (that is, no income tax exemptions)—removing the current VAT zero-rating for suppliers to zones—and limit the zones to designated areas which are able to be closely monitored.", "verbatim": "Restrict tax incentives in special economic zones to exemptions for import duties (that is, no income tax exemptions)—removing the current VAT zero-rating for suppliers to zones—and limit the zones to designated areas which are able to be closely monitored.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-bc3f7a8e95464e97", "page": 62, "quote": "Restrict tax incentives in special economic zones to exemptions for import duties (that is, no income tax exemptions)—removing the current VAT zero-rating for suppliers to zones—and limit the zones to designated areas which are able to be closely monitored.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0089" }, { "text": "Align the lower interest withholding tax rates on FCDUs and those dependent on the period to maturity with the standard interest withholding tax rate, but phase the alignment over a number of years.", "verbatim": "Align the lower interest withholding tax rates on FCDUs and those dependent on the period to maturity with the standard interest withholding tax rate, but phase the alignment over a number of years.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-cac32a754f89841e", "page": 63, "quote": "Align the lower interest withholding tax rates on FCDUs and those dependent on the period to maturity with the standard interest withholding tax rate, but phase the alignment over a number of years.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0090" }, { "text": "Provide for full and automatic indexation of specific tax rates in the law.", "verbatim": "Provide for full and automatic indexation of specific tax rates in the law.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-08338a63c0c485fc", "page": 63, "quote": "Provide for full and automatic indexation of specific tax rates in the law.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0091" }, { "text": "Such indexation should not call for Congress approval.", "verbatim": "Such indexation should not call for Congress approval.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-1387d04d2bbc2b99", "page": 63, "quote": "Such indexation should not call for Congress approval.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0092" }, { "text": "At a minimum, limit it to agricultural cooperatives.", "verbatim": "At a minimum, limit it to agricultural cooperatives.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-7626fefdea38e50c", "page": 63, "quote": "At a minimum, limit it to agricultural cooperatives.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0093" }, { "text": "Consider imposing the three higher rates on the full value of the automobile rather than on the excess relative to the previous price bracket, and adjust the rates downward to 15, 25, and 50 percent (on the same price structure).", "verbatim": "Consider imposing the three higher rates on the full value of the automobile rather than on the excess relative to the previous price bracket, and adjust the rates downward to 15, 25, and 50 percent (on the same price structure).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-9d449df85ae32a1a", "page": 63, "quote": "Consider imposing the three higher rates on the full value of the automobile rather than on the excess relative to the previous price bracket, and adjust the rates downward to 15, 25, and 50 percent (on the same price structure).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0094" }, { "text": "Eliminate price categorization and impose a three-rate specific structure based on alcohol content.", "verbatim": "Eliminate price categorization and impose a three-rate specific structure based on alcohol content.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-9b63ed6384f1f24b", "page": 63, "quote": "Eliminate price categorization and impose a three-rate specific structure based on alcohol content.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0095" }, { "text": "Eliminate the exemptions for cooperatives.", "verbatim": "Eliminate the exemptions for cooperatives.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-4ba18089ce3a05b5", "page": 63, "quote": "Eliminate the exemptions for cooperatives.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0096" }, { "text": "For example, alcohol products could be grouped into three categories: beer and the like; wine and the like, including sparkling wine; and other alcohol products (which would include distilled alcohol, cocktails and other bottled or non-bottled products).", "verbatim": "For example, alcohol products could be grouped into three categories: beer and the like; wine and the like, including sparkling wine; and other alcohol products (which would include distilled alcohol, cocktails and other bottled or non-bottled products).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-fc4f1a40fd087a82", "page": 63, "quote": "For example, alcohol products could be grouped into three categories: beer and the like; wine and the like, including sparkling wine; and other alcohol products (which would include distilled alcohol, cocktails and other bottled or non-bottled products).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0097" }, { "text": "Normalize tax rates at 5 pesos per liter for all gasoline and oil that are currently taxed.", "verbatim": "Normalize tax rates at 5 pesos per liter for all gasoline and oil that are currently taxed.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-91344b5de86b58cf", "page": 63, "quote": "Normalize tax rates at 5 pesos per liter for all gasoline and oil that are currently taxed.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0098" }, { "text": "Repeal the minimum wage earner exemption.", "verbatim": "Repeal the minimum wage earner exemption.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-3b5f3da36c4b418d", "page": 63, "quote": "Repeal the minimum wage earner exemption.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0099" }, { "text": "Set the lower tax rate at 5 percent instead of 2 percent.", "verbatim": "Set the lower tax rate at 5 percent instead of 2 percent.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-34951e4fce3c39eb", "page": 63, "quote": "Set the lower tax rate at 5 percent instead of 2 percent.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0100" }, { "text": "Tax kerosene, diesel, gas and LPG, and fuel oil at 3.5 pesos per liter.", "verbatim": "Tax kerosene, diesel, gas and LPG, and fuel oil at 3.5 pesos per liter.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-fecdd2d61413c0f2", "page": 63, "quote": "Tax kerosene, diesel, gas and LPG, and fuel oil at 3.5 pesos per liter.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0101" }, { "text": "Establish a proper VAT refund mechanism by estimating current outstanding excess VAT credits, and developing a plan to pay such credits.", "verbatim": "Establish a proper VAT refund mechanism by estimating current outstanding excess VAT credits, and developing a plan to pay such credits.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-e7dbed66663c82e4", "page": 64, "quote": "Establish a proper VAT refund mechanism by estimating current outstanding excess VAT credits, and developing a plan to pay such credits.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0102" }, { "text": "Review the adequacy of the current threshold in light of the size and sectoral distribution of the VAT population, and the capacities of the BIR.", "verbatim": "Review the adequacy of the current threshold in light of the size and sectoral distribution of the VAT population, and the capacities of the BIR.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-cde5c8e92840615c", "page": 64, "quote": "Review the adequacy of the current threshold in light of the size and sectoral distribution of the VAT population, and the capacities of the BIR.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0103" }, { "text": "The tax code should be the only law containing tax provisions.", "verbatim": "The tax code should be the only law containing tax provisions.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-166279081161a7b8", "page": 64, "quote": "The tax code should be the only law containing tax provisions.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0104" }, { "text": "Consider an increase in the threshold to between PHP3 and PHP5 million.", "verbatim": "Consider an increase in the threshold to between PHP3 and PHP5 million.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-c21547579f5d9330", "page": 64, "quote": "Consider an increase in the threshold to between PHP3 and PHP5 million.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0105" }, { "text": "Consider re-establishing full deductibility of VAT on capital inputs after a careful consideration of its impact on the cost of capital and its impact on VAT revenues.", "verbatim": "Consider re-establishing full deductibility of VAT on capital inputs after a careful consideration of its impact on the cost of capital and its impact on VAT revenues.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-0857dec154636101", "page": 64, "quote": "Consider re-establishing full deductibility of VAT on capital inputs after a careful consideration of its impact on the cost of capital and its impact on VAT revenues.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0106" }, { "text": "Eliminate all exemptions for inputs that go into the production of exempt final consumption goods (e.g., fertilizers and animal feed).", "verbatim": "Eliminate all exemptions for inputs that go into the production of exempt final consumption goods (e.g., fertilizers and animal feed).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-930712ddbf1218e5", "page": 64, "quote": "Eliminate all exemptions for inputs that go into the production of exempt final consumption goods (e.g., fertilizers and animal feed).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0107" }, { "text": "Eliminate the exemption for social housing.", "verbatim": "Eliminate the exemption for social housing.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-1f73de6310c2e0dc", "page": 64, "quote": "Eliminate the exemption for social housing.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0108" }, { "text": "Eliminate the provisions for zero-rating of transactions paid for in foreign currency (other than direct exports).", "verbatim": "Eliminate the provisions for zero-rating of transactions paid for in foreign currency (other than direct exports).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-3a47520668186e5b", "page": 64, "quote": "Eliminate the provisions for zero-rating of transactions paid for in foreign currency (other than direct exports).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0109" }, { "text": "Limit zero-rating to exports only, and eliminate zero-rating for supplies to exportoriented enterprises and free-zone enterprises.", "verbatim": "Limit zero-rating to exports only, and eliminate zero-rating for supplies to exportoriented enterprises and free-zone enterprises.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-6dfaf8e8fc2a0ed0", "page": 64, "quote": "Limit zero-rating to exports only, and eliminate zero-rating for supplies to exportoriented enterprises and free-zone enterprises.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0110" }, { "text": "Rationalize the DST rates on insurance products to 2 rates, with a distinction between life insurance and similar products, and property insurance and similar products.", "verbatim": "Rationalize the DST rates on insurance products to 2 rates, with a distinction between life insurance and similar products, and property insurance and similar products.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-2d1e778f8bff4356", "page": 64, "quote": "Rationalize the DST rates on insurance products to 2 rates, with a distinction between life insurance and similar products, and property insurance and similar products.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0111" }, { "text": "Remove the DST on original share issues.", "verbatim": "Remove the DST on original share issues.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-a0f1dec7cd210d84", "page": 64, "quote": "Remove the DST on original share issues.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0112" }, { "text": "Remove the DST on recurrent transactions such as bank checks, bonds, drafts and certificates of deposits.", "verbatim": "Remove the DST on recurrent transactions such as bank checks, bonds, drafts and certificates of deposits.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-0081d6821a01da1e", "page": 64, "quote": "Remove the DST on recurrent transactions such as bank checks, bonds, drafts and certificates of deposits.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0113" }, { "text": "Replace the different GRT rates applying to bank income with a single rate, of say 5 percent.", "verbatim": "Replace the different GRT rates applying to bank income with a single rate, of say 5 percent.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-5828a665a685bf74", "page": 64, "quote": "Replace the different GRT rates applying to bank income with a single rate, of say 5 percent.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0114" }, { "text": "Terminate the practice of allowing trade in TCCs (as a first step towards the abolition of TCCs).", "verbatim": "Terminate the practice of allowing trade in TCCs (as a first step towards the abolition of TCCs).", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-d7e9c8691e2757fc", "page": 64, "quote": "Terminate the practice of allowing trade in TCCs (as a first step towards the abolition of TCCs).", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0115" }, { "text": "Terminate the practice of providing VAT exemptions or any other special treatment in other laws.", "verbatim": "Terminate the practice of providing VAT exemptions or any other special treatment in other laws.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-7272b306454082f0", "page": 64, "quote": "Terminate the practice of providing VAT exemptions or any other special treatment in other laws.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0116" }, { "text": "This requires a strong administrative mechanism to prevent the abuse of input tax credit claims—one option could be to limit the credit to large amounts and to taxpayers known by the tax administration and whose tax standing has been in order for at least three years.", "verbatim": "This requires a strong administrative mechanism to prevent the abuse of input tax credit claims—one option could be to limit the credit to large amounts and to taxpayers known by the tax administration and whose tax standing has been in order for at least three years.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-a827f1916f9d1895", "page": 64, "quote": "This requires a strong administrative mechanism to prevent the abuse of input tax credit claims—one option could be to limit the credit to large amounts and to taxpayers known by the tax administration and whose tax standing has been in order for at least three years.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0117" }, { "text": "Start with the lowest and highest brackets.", "verbatim": "Start with the lowest and highest brackets.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-08cc773124ba003d", "page": 65, "quote": "Start with the lowest and highest brackets.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0118" }, { "text": "The Philippines should move to either the TEE or EET model of pension taxation.", "verbatim": "The Philippines should move to either the TEE or EET model of pension taxation.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-63aea0517f166f78", "page": 65, "quote": "The Philippines should move to either the TEE or EET model of pension taxation.", "source": "document" } ], "confidence": 0.85, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "direct_action_in_recommendation_section", "explicitness": "direct_normative", "confidence_tier": "high", "in_conservative_set": true, "recommendation_id": "cr-2012-060-rec-0119" }, { "text": "Apply the standard CIT rate to FCDU interest income from residents (replacing the current 10 percent rate), and consider increasing the CIT rate on FCDU foreign source income.", "verbatim": "Apply the standard CIT rate to FCDU interest income from residents (replacing the current 10 percent rate), and consider increasing the CIT rate on FCDU foreign source income.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-c3ce3caaa13b0f65", "page": 65, "quote": "Apply the standard CIT rate to FCDU interest income from residents (replacing the current 10 percent rate), and consider increasing the CIT rate on FCDU foreign source income.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0120" }, { "text": "Consider lowering the ceiling for entertainment expenses and broadening the scope of withholding taxes on payments to the self-employed.", "verbatim": "Consider lowering the ceiling for entertainment expenses and broadening the scope of withholding taxes on payments to the self-employed.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-ce73d5fbf1a65e95", "page": 65, "quote": "Consider lowering the ceiling for entertainment expenses and broadening the scope of withholding taxes on payments to the self-employed.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0121" }, { "text": "Excise tax reform would raise revenue of 0.8 percent of GDP.", "verbatim": "Excise tax reform would raise revenue of 0.8 percent of GDP.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-4e0733b153bf5e8a", "page": 65, "quote": "Excise tax reform would raise revenue of 0.8 percent of GDP.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0122" }, { "text": "However, if there is a need for a revenue increase, VAT rate increase could be considered.", "verbatim": "However, if there is a need for a revenue increase, VAT rate increase could be considered.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-0c4df1b375ac4430", "page": 65, "quote": "However, if there is a need for a revenue increase, VAT rate increase could be considered.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0123" }, { "text": "Overhaul the tax rate schedule to reflect inflation since 1997.", "verbatim": "Overhaul the tax rate schedule to reflect inflation since 1997.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-9a31a95d45b2513f", "page": 65, "quote": "Overhaul the tax rate schedule to reflect inflation since 1997.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0124" }, { "text": "The present mission‘s recommended approach is to eliminate fiscal incentives accompanied by a reduction in the CIT rate.", "verbatim": "The present mission‘s recommended approach is to eliminate fiscal incentives accompanied by a reduction in the CIT rate.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-d42a9928a89b127e", "page": 65, "quote": "The present mission‘s recommended approach is to eliminate fiscal incentives accompanied by a reduction in the CIT rate.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0125" }, { "text": "The rationalization of fiscal incentives has the potential to raise around 1 percent of GDP.", "verbatim": "The rationalization of fiscal incentives has the potential to raise around 1 percent of GDP.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-63bc1de815c38965", "page": 65, "quote": "The rationalization of fiscal incentives has the potential to raise around 1 percent of GDP.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0126" }, { "text": "The reform of the VAT and PIT would be revenue neutral.", "verbatim": "The reform of the VAT and PIT would be revenue neutral.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-2f3d88a57f18e4d1", "page": 65, "quote": "The reform of the VAT and PIT would be revenue neutral.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0127" }, { "text": "These revenue estimates are indicative; the present mission strongly suggests that the authorities undertake more analytical work in this area.", "verbatim": "These revenue estimates are indicative; the present mission strongly suggests that the authorities undertake more analytical work in this area.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-cb41e523f01d01e0", "page": 65, "quote": "These revenue estimates are indicative; the present mission strongly suggests that the authorities undertake more analytical work in this area.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0128" }, { "text": "This will require the DOF, BIR, and BOC to ensure the availability of better statistical information in support for tax policy development.", "verbatim": "This will require the DOF, BIR, and BOC to ensure the availability of better statistical information in support for tax policy development.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-d78a5eb0c5988683", "page": 65, "quote": "This will require the DOF, BIR, and BOC to ensure the availability of better statistical information in support for tax policy development.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0129" }, { "text": "Under this approach, a reduction to around 21 percent would be revenue neutral, while a smaller reduction, to say 25 percent, would be revenue positive.", "verbatim": "Under this approach, a reduction to around 21 percent would be revenue neutral, while a smaller reduction, to say 25 percent, would be revenue positive.", "actor": null, "priority": null, "timeframe": null, "report_paragraph": null, "section": "Shaded parts are new recommendations. No specific timeline was proposed for mining measures.", "evidence": [ { "evidence_id": "ev-d50ea789180c66da", "page": 65, "quote": "Under this approach, a reduction to around 21 percent would be revenue neutral, while a smaller reduction, to say 25 percent, would be revenue positive.", "source": "document" } ], "confidence": 0.35, "extraction_method": "recommendation_section_sentence", "review_status": "unreviewed", "recommendation_type": "recommendation_section_context_candidate", "explicitness": "context_candidate", "confidence_tier": "low", "in_conservative_set": false, "recommendation_id": "cr-2012-060-rec-0130" } ], "observation_recommendation_links": [ { "observation_id": "cr-2012-060-obs-0012", "recommendation_id": "cr-2012-060-rec-0001", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-ab94c1f02f5a4bdb", "page": 14, "quote": "This mission agrees that a unified withholding rate should be applied as the current reduced or zero withholding tax on interest income derived from deposits with long maturity or those in foreign currency benefits mainly wealthy households.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0012", "recommendation_id": "cr-2012-060-rec-0003", "relation": "contextually_associated_with", "link_basis": "same_or_adjacent_page_lexical_similarity", "evidence": [ { "evidence_id": "ev-4096bbb01b4ce237", "page": 14, "quote": "Withholding tax on interest : The World Bank recommended that a unified 18 percent", "source": "document" } ], "confidence": 0.558, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0012", "recommendation_id": "cr-2012-060-rec-0004", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-3ea0870c03cb9e80", "page": 14, "quote": "withholding tax should be applied to interest.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0017", "recommendation_id": "cr-2012-060-rec-0005", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-b7be5c9003421e95", "page": 15, "quote": "Without repeating the analysis of the 2010 mission, it is worth emphasizing some of the arguments against incentives including: (1) they involve a loss of current and future revenue which usually means that taxes must be higher in other activities which harms economic efficiency and compliance, and causes inequities; (2) tax incentives by their nature", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0023", "recommendation_id": "cr-2012-060-rec-0006", "relation": "contextually_associated_with", "link_basis": "same_or_adjacent_page_lexical_similarity", "evidence": [ { "evidence_id": "ev-65405da29182f99c", "page": 16, "quote": "One of the key reasons for providing tax incentives in the Philippines is the concern that the country needs to be competitive with other countries in the region in order to attract Foreign Direct Investment (FDI).", "source": "document" } ], "confidence": 0.539, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0031", "recommendation_id": "cr-2012-060-rec-0013", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-6658a2493a974883", "page": 20, "quote": "Once that objective is achieved—or at least enough opportunity given to do so-- the incentive should cease.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0031", "recommendation_id": "cr-2012-060-rec-0015", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-24ee036b79e741e5", "page": 20, "quote": "The period for providing incentives is still too long and should be reduced.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0035", "recommendation_id": "cr-2012-060-rec-0018", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-6f515bb374bb60ca", "page": 22, "quote": "This increased investment should lead to greater employment opportunities, which should benefit all Filipinos, including the poor.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0036", "recommendation_id": "cr-2012-060-rec-0018", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-6f515bb374bb60ca", "page": 22, "quote": "This increased investment should lead to greater employment opportunities, which should benefit all Filipinos, including the poor.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0039", "recommendation_id": "cr-2012-060-rec-0019", "relation": "contextually_associated_with", "link_basis": "same_or_adjacent_page_lexical_similarity", "evidence": [ { "evidence_id": "ev-d4319b27716fe39e", "page": 23, "quote": "19 Membership of cooperatives is limited to natural persons and there must be at least 15 members, with no member holding more than 10 percent of the share capital.", "source": "document" } ], "confidence": 0.562, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0038", "recommendation_id": "cr-2012-060-rec-0021", "relation": "contextually_associated_with", "link_basis": "same_or_adjacent_page_lexical_similarity", "evidence": [ { "evidence_id": "ev-dabc569f45edbd86", "page": 24, "quote": "The taxes that should apply are income tax (at the cooperative level at the CIT rate), VAT, and import duties.", "source": "document" } ], "confidence": 0.619, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0048", "recommendation_id": "cr-2012-060-rec-0028", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-3c7236b0c5c53c29", "page": 28, "quote": "The mission recommends a gradual approach in implementing excise tax adjustment.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "explicit_attributed_statement", "recommendation_confidence_tier": "high", "conservative_recommendation": true }, { "observation_id": "cr-2012-060-obs-0048", "recommendation_id": "cr-2012-060-rec-0029", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-5588b518382d38ce", "page": 28, "quote": "Excises should be increased within a timeframe of three years in order to bring the share of excise taxes in GDP to their 1997 levels.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0047", "recommendation_id": "cr-2012-060-rec-0030", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-dea10f9d6690ea43", "page": 28, "quote": "Many excise rates need to be increased in order to increase the overall tax to GDP ratio.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0051", "recommendation_id": "cr-2012-060-rec-0034", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-c936b3ca72b4bb79", "page": 32, "quote": "A good tax system should minimize distortion of economic choices, including quality of the product.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0052", "recommendation_id": "cr-2012-060-rec-0034", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-c936b3ca72b4bb79", "page": 32, "quote": "A good tax system should minimize distortion of economic choices, including quality of the product.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0053", "recommendation_id": "cr-2012-060-rec-0034", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-c936b3ca72b4bb79", "page": 32, "quote": "A good tax system should minimize distortion of economic choices, including quality of the product.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0051", "recommendation_id": "cr-2012-060-rec-0035", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-8a3ba47a989198a3", "page": 32, "quote": "An optimal tax system should therefore use both taxes in a way that would leave quality unchanged, compared to the hypothetical ―no-excise‖ world.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0052", "recommendation_id": "cr-2012-060-rec-0035", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-8a3ba47a989198a3", "page": 32, "quote": "An optimal tax system should therefore use both taxes in a way that would leave quality unchanged, compared to the hypothetical ―no-excise‖ world.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0053", "recommendation_id": "cr-2012-060-rec-0035", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-8a3ba47a989198a3", "page": 32, "quote": "An optimal tax system should therefore use both taxes in a way that would leave quality unchanged, compared to the hypothetical ―no-excise‖ world.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0058", "recommendation_id": "cr-2012-060-rec-0041", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-3b719b3c91997a21", "page": 37, "quote": "Rising incomes and population growth should offset any negative impact on employment (Jacobs, et al., 2000).", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0063", "recommendation_id": "cr-2012-060-rec-0042", "relation": "contextually_associated_with", "link_basis": "same_or_adjacent_page_lexical_similarity", "evidence": [ { "evidence_id": "ev-70c373262571a6de", "page": 40, "quote": "The new excise taxes on alcoholic beverages should be set according to alcohol", "source": "document" } ], "confidence": 0.614, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0064", "recommendation_id": "cr-2012-060-rec-0043", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-0328db8a61cd2ccb", "page": 41, "quote": "In order to increase the tax to GDP ratio, and reduce the extent of increases in excise on products like petroleum, tobacco and alcoholic products, authorities should look into the possibility of taxing mobile phone communications at a very low rate per call.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0071", "recommendation_id": "cr-2012-060-rec-0046", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-471c57996b916142", "page": 47, "quote": "Given the level of income inequity in the Philippines, [48] reducing the top PIT rate to 25 percent as the World Bank recommended would compromise progressivity and needs to be considered carefully as a part of a comprehensive tax reform plan.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0071", "recommendation_id": "cr-2012-060-rec-0047", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-e996df4314743c52", "page": 47, "quote": "The World Bank mission recommended that the top PIT rate be aligned with the CIT rate to reduce arbitrage opportunities between the PIT and CIT regimes.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0072", "recommendation_id": "cr-2012-060-rec-0049", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-f3101f6d6f153907", "page": 48, "quote": "The refluxed money could have been income that should have been but was not taxed in the Philippines.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0072", "recommendation_id": "cr-2012-060-rec-0050", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-01b6ec7fa02cb8e8", "page": 48, "quote": "While the workers must be registered with the Philippine Overseas Employment Administration (POEA) with a valid Overseas Employment Certificate (OEC), the current unlimited tax-free treatment may open a way for the wealthy to return their overseas money to the Philippines without being taxed in disguise of OCWs or OFWs.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0075", "recommendation_id": "cr-2012-060-rec-0054", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-3eb0385cf98a7372", "page": 51, "quote": "Given the importance of the mining sector and the need to protect government revenue, management fees, say in excess of 2 percent of revenue, are in many countries disallowed as a business expense (A separate mining section in Chapter IV of the National Internal Revenue Code (NIRC) on tax corporations could include this a special rule).", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0075", "recommendation_id": "cr-2012-060-rec-0055", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-f1b65a481c0ae4e9", "page": 51, "quote": "To avoid income shifting, transfer price rules applicable to all taxpayers should be enforced for mining companies as well.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0077", "recommendation_id": "cr-2012-060-rec-0056", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-2f0b48e40871de6b", "page": 52, "quote": "In general, expenses at Mine B incurred by a company already producing at Mine A should not be deductible against income from Mine A.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0077", "recommendation_id": "cr-2012-060-rec-0057", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-56c47975f1f3f1e9", "page": 52, "quote": "Tax accounts for the CIT and any surcharge should be ring-fenced by mining license.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0078", "recommendation_id": "cr-2012-060-rec-0058", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-9e9cad98d3fb0fa5", "page": 53, "quote": "Some instruments may work better than others in capturing supernormal profits, and some may be quite distorting and should be rejected although they may be used in certain countries.", "source": "document" } ], "confidence": 0.78, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0080", "recommendation_id": "cr-2012-060-rec-0059", "relation": "contextually_associated_with", "link_basis": "same_or_adjacent_page_lexical_similarity", "evidence": [ { "evidence_id": "ev-66190f96512a914d", "page": 53, "quote": "The key design features of a mining fiscal regime should have the following characteristics :", "source": "document" } ], "confidence": 0.52, "review_status": "unreviewed", "recommendation_type": "normative_modal_candidate", "recommendation_confidence_tier": "medium", "conservative_recommendation": false }, { "observation_id": "cr-2012-060-obs-0087", "recommendation_id": "cr-2012-060-rec-0066", "relation": "responds_to_context", "link_basis": "same_paragraph", "evidence": [ { "evidence_id": "ev-1787b8322eddd527", "page": 58, "quote": "At least, tax provisions that are prone to abuse should 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