Report on the implementation of the annual risk management ... · Përmbushëse Rimbursive...

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General report on the treatment of risks identified for 2018, activities undertaken for those risks during the reporting period and the comparison of these activities with the previous year 2017. Report on the implementation of the annual risk management plan for 2018 Period analysed: January –December /2018 Risk Management Division, TAK February, 2019

Transcript of Report on the implementation of the annual risk management ... · Përmbushëse Rimbursive...

Page 1: Report on the implementation of the annual risk management ... · Përmbushëse Rimbursive C'regjistrim Arka fiskale Vizita tjera Realisation of visits plan by type of visits Plan

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General report on the treatment of risks

identified for 2018, activities undertaken

for those risks during the reporting period

and the comparison of these activities

with the previous year 2017.

Report on the implementation of the annual risk management plan for 2018 Period analysed:

January –December /2018

Risk Management Division, TAK February, 2019

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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CONTENT

Introduction ............................................................................................................................................ 3

I. Report on compliance operations – visits, January-December/2018 ................................................ 4

II. Report on compliance activity – audits, January-December/2018 .................................................... 8

III. Treatment and realisation of success milestones ............................................................................ 12

IV. Data on treatment ........................................................................................................................... 16

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Introduction

The January-December/2018 report on the implementation of the Annual Risk Management

Plan for 2018 contains various data on the progress of plan's implementation during the

reporting period and the comparison of these results with the same period of the previous

year.

The report, among other things, includes the various activities undertaken by regional offices

as a result of their commitment to the implementation of the risk treatment plan, not

excluding the ongoing work of our colleagues in raising the awareness of taxpayers so that

the latter strictly apply the applicable laws and thus voluntarily fulfil their tax obligations.

The report contains data from various sources of information while the main data source for

our field activities is the VKME application. This software is enabling the TAK management to

monitor the situation on a daily basis, to generate various information on the field activities

of our officials and to conduct analysis on such activities.

Our contact with regional offices has continued throughout the period, these contacts have

either been in written form through the exchange of letters or often through informal

contacts we have had with these offices.

Based on the data received from regional offices and the data extracted from the database

within TAK, as well as on the analyses done for this period, further in this document we will

present the detailed results.

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I. Report on compliance operations – visits, January-December/2018

During January-December 2018, regional teams have conducted 46,229 different types of visits. Regarding the aspect of extent, size and

types of visits, we have realization of the visit plan for the reporting period by sectors in the Wholesale and Retail Trade sector and in

Accommodation and Food Services sector, regarding the size we have surpassed the plan in the category of micro and small taxpayers,

and by type of visit we have a realization of the plan only in the category of compliance visits. For more details on the realization of the

visit plan for the period January-December 2018 on the basis of regional structure the table below presents the visits and their distribution

by risks and by region.

LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Total visits Number 1,133 4,604 5,414 4,233 7,019 4,845 4,752 4,639 1,524 3,733 4,333 46,229

% in total 2% 10% 12% 9% 15% 10% 10% 10% 3% 8% 9% 100%

Sectorial coverage LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Construction (20%) Number 62 337 373 297 458 171 425 318 79 263 324 3,107

% in total 5% 7% 7% 7% 7% 4% 9% 7% 5% 7% 7% 7%

Wholesale and retail trade (20%)

Number 648 1,378 2,034 1,201 2,603 1,912 1,664 1,869 427 1,014 1,437 16,187

% in total 57% 30% 38% 28% 37% 39% 35% 40% 28% 27% 33% 35%

Processing industry (15%)

Number 155 351 449 332 842 613 646 671 173 470 452 5,154

% in total 14% 8% 8% 8% 12% 13% 14% 14% 11% 13% 10% 11%

Real estate activities (5%)

Number 2 24 28 34 40 13 12 20 - 6 7 186

% in total 0% 1% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0%

Financial and insurance activities (5%)

Number 53 59 24 17 17 9 19 15 20 13 8 254

% in total 5% 1% 0% 0% 0% 0% 0% 0% 1% 0% 0% 1%

Accommodation and food services (10%)

Number - 535 881 647 737 656 596 278 125 502 456 5,413

% in total 0% 12% 16% 15% 11% 14% 13% 6% 8% 13% 11% 12%

Other service activities (10%)

Number 2 226 185 398 280 232 140 235 119 256 131 2,204

% in total 0% 5% 3% 9% 4% 5% 3% 5% 8% 7% 3% 5%

Other sectors (15%) Number 211 1,694 1,440 1,307 2,042 1,239 1,250 1,233 581 1,209 1,518 13,724

% in total 19% 37% 27% 31% 29% 26% 26% 27% 38% 32% 35% 30%

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No. of visits January –December/2018: A total of 46,229 visits conducted. Based on the sectorial coverage, we have a realisation of the plan in the Wholesale and Retail

Trade sector,

Accommodation and Food

Service sector and in the

group of other sectors.

Distribution of visits by

risks: regarding the size of

taxpayers, we have

realization of plan of visits to taxpayers of micro and small segments. Whereas regarding type of visits we have realisation of plan in compliance visits and in the group of

other visits.

Table no. 1: - Distribution of visits according to the risk treatment plan during the period: January-December/2018 Source: KTA-DB, VKM

Taxpayer size LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Micro (5%) Number 1 2,179 1,729 1,992 4,191 1,648 2,093 2,271 690 1,998 2,712 21,504

% in total 0% 47% 32% 47% 60% 34% 44% 49% 45% 54% 63% 47%

Small (10%) Number - 1,025 1,447 914 1,333 1,600 1,124 1,028 387 722 844 10,424

% in total 0% 22% 27% 22% 19% 33% 24% 22% 25% 19% 19% 23%

Medium (35%) Number 3 917 1,356 766 1,024 890 1,060 831 301 604 532 8,284

% in total 0% 20% 25% 18% 15% 18% 22% 18% 20% 16% 12% 18%

Large and &LTD (50%)

Number 1,129 483 882 561 471 707 475 509 146 409 245 6,017

% in total 100% 10% 16% 13% 7% 15% 10% 11% 10% 11% 6% 13%

Types of visit LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Compliance (35%)

Number 415 2,008 2,441 1,676 1,988 1,573 1,974 1,686 755 1,354 1,027 16,897

% in total 37% 44% 45% 40% 28% 32% 42% 36% 50% 36% 24% 37%

Reimbursement (15%)

Number 133 592 793 240 453 281 365 403 156 342 249 4,007

% in total 12% 13% 15% 6% 6% 6% 8% 9% 10% 9% 6% 9%

Deregistration (20%)

Number 2 409 342 187 210 368 325 244 316 287 1,229 3,919

% in total 0% 9% 6% 4% 3% 8% 7% 5% 21% 8% 28% 8%

Fiscal register (15%)

Number 54 458 829 198 349 1,621 295 246 158 439 415 5,062

% in total 5% 10% 15% 5% 5% 33% 6% 5% 10% 12% 10% 11%

Other visits (15%)

Number 529 1,137 1,009 1,932 4,019 1,002 1,793 2,060 139 1,311 1,413 16,344

% in total 47% 25% 19% 46% 57% 21% 38% 44% 9% 35% 33% 35%

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Below is a graphical presentation of the distribution of visits for the period January-December 2018, and their percentage share

in the total of visits.

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Figure no. 2: - Visits by sector, size and type, period: January-December/2018 Source: TAK-DB,VKME

0%

50%

100%

150%

200%

250%

- 2,000 4,000 6,000 8,000

10,000 12,000 14,000 16,000 18,000

Realisation of visits plan by sectors

Plan i vizitave Vizitat e realizuara % e realizimit të planit

0%

100%

200%

300%

400%

500%

600%

700%

800%

900%

1000%

-

5,000

10,000

15,000

20,000

25,000

Mikro Të vegjël Të mesëm Të mdhenjë&DTM

Realisation of visits plan by size

Plan i vizitave Vizitat e realizuara % e realizimit të planit

0%

50%

100%

150%

200%

250%

-

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

Përmbushëse Rimbursive C'regjistrim Arka fiskale Vizita tjera

Realisation of visits plan by type of visits

Plan i vizitave Vizitat e realizuara % e realizimit të planit

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II. Report on compliance activity – audits, January-December/2018

In details, and always based on the annual risk treatment plan for 2018, the audits have been presented including their distribution by risks

and regions for the reporting period. Wholesale and Retail and Processing Industry are the sectors for which the plan of audits has been

realised. The following table clearly explains that besides the Wholesale and Retail, Processing Industry and other sectors designated as

Other Sectors, the realisation of the audit plan has not been completed as per the plan. The distribution of audits by region is given below

in detail.

LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Total audits 129 179 158 145 229 175 146 145 54 169 185 1,714

Compulsory (10%) Number 43 88 37 71 48 35 24 20 21 42 61 490

% in total 33% 49% 23% 49% 21% 20% 16% 14% 39% 25% 33% 29%

Reimbursement (10%) Number 14 21 25 16 19 15 2 8 3 10 22 155

% in total 11% 12% 16% 11% 8% 9% 1% 6% 6% 6% 12% 9%

Random (5%) Number 3 9 3 1 3 4 0 0 10 37 5 75

% in total 2% 5% 2% 1% 1% 2% 0% 0% 19% 22% 3% 4%

Risk-based audits (75%) Number 69 61 93 57 159 121 120 117 20 80 97 994

% in total 53% 34% 59% 39% 69% 69% 82% 81% 37% 47% 52% 58%

Sectorial coverage of risk-based audits LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Construction (20%) Number 9 32 32 25 25 18 24 17 6 20 33 241

% 7% 18% 20% 17% 11% 10% 16% 12% 11% 12% 18% 14%

Wholesale and retail trade (20%)

Number 74 87 78 48 99 74 71 70 21 52 70 744

% 57% 49% 49% 33% 43% 42% 49% 48% 39% 31% 38% 43%

Processing industry (15%) Number 16 13 15 11 40 37 32 29 7 37 26 263

% 12% 7% 9% 8% 17% 21% 22% 20% 13% 22% 14% 15%

Real estate activities (5%) Number 1 2 2 2 6 0 0 3 0 0 0 16

% 1% 1% 1% 1% 3% 0% 0% 2% 0% 0% 0% 2%

Financial and insurance activities (5%)

Number 3 0 0 0 0 0 0 1 0 0 1 5

% 2% 0% 0% 0% 0% 0% 0% 1% 0% 0% 1% 0%

Accommodation and food service (10%)

Number 0 5 2 6 9 5 5 3 3 17 8 63

% 0% 3% 1% 4% 4% 3% 3% 2% 6% 10% 4% 4%

Other service activities (10%)

Number 0 0 0 7 2 1 1 2 2 12 3 30

% 0% 0% 0% 5% 1% 1% 1% 1% 4% 7% 2% 2%

Other sectors (15%) Number 26 40 29 46 48 40 13 20 15 31 44 352

% 20% 22% 18% 32% 21% 23% 9% 14% 28% 18% 24% 21%

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Number of audits,

January-December 2018

- During the period

January-December/2018,

1,714 audits were

conducted, and we have a

realisation of the audit

plan only in the

compulsory audits. Based

on sectorial coverage,

realisation of the plan has

been reached only in the

Wholesale and Retail and

Processing Industry

sectors.

S

Size of taxpayers per risk-based audits

LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Micro (5%) Number 0 35 22 53 31 45 6 11 3 31 46 283

% 0% 20% 14% 37% 14% 26% 4% 8% 6% 18% 25% 17%

Small (10%) Number 0 22 6 18 29 27 9 7 15 19 32 184

% 0% 12% 4% 12% 13% 15% 6% 5% 28% 11% 17% 11%

Medium (35%) Number 0 47 61 23 97 48 70 72 22 62 60 562

% 0% 26% 39% 16% 42% 27% 48% 50% 41% 37% 32% 33%

Large & LTD (50%) Number 129 75 69 51 72 55 61 55 14 57 47 685

% 100% 42% 44% 35% 31% 31% 42% 38% 26% 34% 25% 40%

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Distribution of

activities by risks -

Regarding the size of

taxpayers, the plan has

been achieved by field

teams in the micro and

small categories. While regarding the aspect of audits only in long audits the plan has been achieved and surpassed.

Table no. 2: - Distribution of audits according to the risk treatment plan during the period: January-December/2018

Source: TAK-DB, VKME

Below is a graphical presentation of the audits conducted from the aspect of the reasons for opening the audit, size, sectors and type of

audit for the period January-December/2018.

Types of audits per risk-based audits LTD Prishtina 1 Prishtina 2 Prishtina 3 Gjilan Ferizaj Prizren 1 Prizren 2 Gjakova Peja Mitrovica Total

Monthly audits (25%) Number 12 22 4 14 19 16 33 13 2 8 25 168

% 9% 12% 3% 10% 8% 9% 23% 9% 4% 5% 14% 10%

Annual audits (45%) Number 49 41 40 33 73 71 65 40 25 33 57 527

% 38% 23% 25% 23% 32% 41% 45% 28% 46% 20% 31% 31%

Long audits (30%) Number 68 116 114 98 137 88 48 92 27 128 103 1019

% 53% 65% 72% 68% 60% 50% 33% 63% 50% 76% 56% 59%

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Figure no. 2: - Audits according to reason, sector, size and type, period: January-December/2018 Source: TAK-DB, VKME

0%

100%

200%

300%

400%

-

500

1,000

1,500

Të detyrueshme Rimbursive Rastësishme Kontrtollet ebazuara në rrezik

Realization of the audit plan according to the reason for audit

Plani i kontrollave Kontrollat e realizuara % e realizimit të planit

0%

100%

200%

300%

400%

-

200

400

600

800

Realization of the audit plan according to sectors

Plani i kontrollave Kontrollat e realizuara % e realizimit të planit

0%

100%

200%

300%

400%

500%

600%

-

100

200

300

400

500

600

700

800

Mikro Të vegjël Të mesëm Të mdhenjë&DTM

Realization of the audit plan according to size

Plani i kontrollave Kontrollat e realizuara % e realizimit të planit

0%

50%

100%

150%

200%

250%

300%

350%

400%

-

200

400

600

800

1,000

1,200

Kontrolle mujore Kontrolle vjetore Kontrolle të gjata

Realization of the audit plan according to the type of audits

Plani i kontrollave Kontrollat e realizuara % e realizimit të planit

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III. Treatment and realisation of success milestones

As a result of field activities, 46,229 visits and 1,714 audits for the period January-December 2018, below are presented the realization of the success milestones for

each treatment identified for 2018.

Compliance

field

Compliance

risk Description

Plan Realisation

Treatment

measures Time limits Success milestone Activities Success milestones

Registration Non-

registration

Taxpayers who pursuant to the tax legislation are

required to be registered and equipped with fiscal

number and who did not do that, or taxpayers who

have been registered and equipped with fiscal

number but have not been registered for VAT or

another relevant account and are obliged to do so.

• Information &

education

• Visits

• Audits

• Call Centre

• Risk Module

January –

December

• Increase of the number of VAT

filers for 15% without changing

registration threshold;

• Increase for 100% of the number

of taxpayers registered by TAK

through operational activities.

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Call Centre

• Risk Module

Decreased number of taxpayers

registered in VAT for 2%,

Increase number of taxpayers

registered by TAK through

operational activities for 27%.

Documentati

on

Goods

without

origin &

shortage in

stocks

Taxpayer identification and treatment, as follows:

- Taxpayers possessing goods and pursuant to the

legislation in force, these goods are not documented

with regards to their origin and under-declare them or

are not able to provide the supporting documentation

for goods whereby justifying the origin and location of

goods;

- Taxpayers who are not able to provide supporting

documentation with regards to the goods in circulation

(outside location(s) of taxpayer);

- Taxpayers who should be able to document all goods

from the moment of receipt and until they are sold or

systemised, including sale or systemization

documentation. The concerned treatment will mainly

cover sectors as: trade, processing industry,

construction, etc.

• Information &

education

• Visits

• Audits

• Risk Module

January-April

September-

December

• Increase of the value of goods

without origin for 40% based on

TAK operational activities in the

field;

• Increase of value of shortage in

stocks for 30% based on TAK

operational activities in the field;

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Risk Module

Based on the activities in the field

we have a decrease in the value

of goods without origin for 40%

compared to the previous period,

And increase of the value of

shortage in stocks for 7%

compared to 2017.

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Documentati

on

Failure to

keep records

or incorrect

of keeping

records

Businesses which with records kept unduly avoid tax

obligations, as:

- Failure to install fiscal cash registers;

- Failure to issue fiscal invoices during the sale;

- Use of non-fiscal equipment, non-fiscal printers;

- Keeping double records;

- Failure to inform TAK for changes, as: NACE code,

address, etc.

• Information &

education

• Visits

• Audits

• Call Centre

January –

December

Treatment of 20% of cases with a

history of unduly kept records

(mandatory fines);

• Information &

education

• Visits

• Audits

• Call Centre

During the period January –

December 2018, 11% more fines

have been imposed for unduly

kept records, compared to the

previous year, and approximately

the same number in fines for

failing to issue fiscal invoices etc.

Declaration Continuous

lending

Treating businesses operating with continuous lending

from 21,219 taxpayers who have declared in VAT during

2017, only 40 % of them have been obliged to pay at

least one time during the entire relevant year.

• Information &

education

• Visits

• Audits

• Risk module

January –

December

• 10% increase in the number of

taxpayers making payments in VAT

during one annual period.

Baseline 2017

• Information &

education

• Visits

• Audits

• Risk module

Decrease in the number of

taxpayers who make payments in

VAT for 1% compared to previous

period.

Declaration

Non-

compliance

between

declaration

and

information

available at

TAK

Taxpayers who in their declarations report different data

from those available at TAK. This risk includes the

following taxpayers:

- Non-compliance between the amount presented in the

VAT declaration and data from Customs on conducted

imports/exports,

- Non-compliance between the turnover declared in VAT

declaration and turnover in fiscal cash registers;

- Non-compliance between report of purchases above

EUR 500 and declared purchases;

- Non-compliance between reported and declared

transactions (purchase/sale books).

• Information &

education

• Visits

• Audits

• Risk module

January –

December

Treatment of 90% of cases

identified with incorrect reports.

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Risk module

Based on the data from the risk

analysis module for 2017 and

2018, there is an increase in the

number of cases of

noncompliance in export

(parameter 146) compared to

2017 for 35%,

Increase in the number of cases of

noncompliance in imports

(parameter 147) compared to the

previous year for 16%,

And increase in the number of

cases with discrepancies in

turnover between the submitted

declaration and PEF reports

(parameter 153), compared to

2017 for 5%.

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Declaration

Non-filers

and late

declarations

Treatment of all registered businesses and natural

persons with small and large incomes who do not

declare, stop declaration or file late declaration and

taking necessary steps by TAK so the abovementioned

taxpayers file their declarations within the legal time

limits. This treatment covers in particular trade, service,

artistic, construction sectors, etc.

• Information &

education

• Visits

• Audits

• Call centre

• Risk module

Time limits will

be based on the

AI for treatment

of non-filers

dated

29.11.2017

• Treatment for 90% of all stop-

filers;

• Reduction of the number of non-

filers as follows: - 70% in VAT; -

90% in PIT and CIT.

• Reduction of the number of late

declarations for 40%.

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Call centre

• Risk module

Compared to the data from 2017,

during 2018 there is a decrease in

the number of non-filers in VAT

for 17%, in WM decrease for 25%,

in PIT decrease for 33% and CIT a

decrease for 46%

Declaration

Failure to

apply

reverse

charge in

construction

The concerned treatment includes businesses in the

construction sector, which do not respect the legal basis

related to the application of reverse charge, thus making

under-declaration.

• Information &

education

• Visits

• Audits

• Risk module

January-

December

Increase of the number of

businesses applying the reverse

charge for 15%.

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Risk module

Increase in the number of cases

applying the reverse charge for

10%, compared to the previous

year

Declaration

Under-

declared sale

prices

Businesses which do not declare the correct goods sale

price, according to the arm’s length market

• Whole sale and retail sale,

• Service activities,

• Real estate activities

• Human health activities

• Information &

education

• Visits

• Audits

• Risk module

February-March

July-August

October-

November

• Increase for 50% of results from

TAK operational activities in the

field.

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Risk module

Based on the evidences from the

audit carried out in the period

January-December 2018 we have

20% less additional tax for cases

of under-declared sale prices,

compared to the previous year.

Declaration

Failure to

withhold

taxes

Based on the recent assessment related to the expansion

of informal economy in Kosovo carried out by EU, the

number of employees in informal sector in Kosovo

amounts to 45,000 employees. The number of

businesses, even though declare employees, pay their

salaries in cash and those are not reported to pay the

withholding tax. All this has a significant impact on

revenues and contributions for social assistance funds.

It is worth mentioning that so far, based on the visits and

audits conducted during the period January - November

2017; only 1,363 employees have been identified.

• Information &

education

• Visits

• Audits

• Call centre

• Risk module

January-

December

• Increase for 100% of the number

of employees registered due to

field activities.

Baseline year 2017.

• Information &

education

• Visits

• Audits

• Call centre

• Risk module

Increase for 3% of the number of

employees declared by businesses

during the period January-

December 2018, compared to the

same period of the previous year,

whereas from the field activities

87% more employees have been

registered this year compared to

the previous year.

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

15

Declaration Inadmissible

deductions

Identification of businesses with low payment coefficient

compared to the declared turnover; therefore, in order

to treat these cases, TAK should conduct visits and audits

in order to verify whether incurred expenses are correct

or there are inadmissible deductions.

•Information &

education

•Visits

•Audits

• Risk module

April-July

• Treatment of all cases with high

degree of risk based on risk

analysis.

•Information &

education

•Visits

•Audits

• Risk module

Based on the evidence of the

audits carried out during the

period January-December 2018

we have 169% more additional

tax for cases of under-declared

sale prices, compared to the

previous year.

Declaration Under-

declarers

Businesses within the segment of medium and largesized

businesses, in particular activities of trade, service,

construction and production, who do not file correct

declarations

- Businesses registered for VAT and declare with zero

and those who declare and pay € 37.5 on quarterly basis,

as well as businesses which stay for a long time near the

threshold to enter the scheme of real income and VAT

taxation, in particular for businesses with trade,

professional services, entertaining – artistic activities,

etc.

•Information &

education

•Visits

•Audits

• Risk module

January-

December

• Treatment of all cases with high

degree of risk based on risk

analysis.

•Information &

education

•Visits

•Audits

• Risk module

A total of 109 audits have been

carried out related to under-

declarations, resulting to over 1.5

million euro additional tax

Payment

Failure to

pay tax

obligations

Taxpayers who have outstanding obligations to TAK,

regardless tax types

Taking all actions

pursuant to the

tax legislation

January-

December Treatment of all cases

Taking all actions

pursuant to the

tax legislation

39% increase in the number of

taxpayers who have outstanding

obligations compared to previous

year

Payment

Delays in

paying tax

obligations

Taxpayers delayed in fulfilling tax obligations, namely

late payments to TAK, regardless of tax types

Taking all actions

pursuant to the

tax legislation by

the Forced

Collection

January-

December Treatment of all cases

Taking all actions

pursuant to the

tax legislation by

the Forced

Collection

Increased collections in the

activities of Forced Collection for

16% compared to the same

period of last year

Tabela nr. 3: - Trajtimet sipas planit të rreziqeve për vitin 2018 Burimi i të dhënave: ATK-DB, VKME

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16

IV. Data on treatment

The graphical analysis presented below provides a

more detailed illustration of the treatment of data,

based on the following treatments:

Non-registration: - During January-December 2018, a

total of 435 taxpayers have been registered from the

field activities, compared to the previous year where

we had about 93 fewer taxpayers registered. Viewed

from the sectors aspect, the largest number of new

registrations belongs to the wholesale and retail

trade sector and to other service activities. Regarding

VAT declarer taxpayers, we have about 5% more

taxpayers who have declared VAT compared to 2017.

Goods without origin and shortage in stocks: - There

are a considerable number of taxpayers who have

the problem related to goods without origin as a

result of purchases without invoices, as well as

undeclared sales which is then reflected as shortage

in stocks. Based on the success milestones defined in

the risk treatment annual plan we have over 520

thousand euros of goods without origin or 40% less

than the previous year and over 26.6 million euros

shortage in stocks or increase of value for 7%

compared to the previous year.

Failure to keep records or incorrect keeping of

records: - according to the risk treatment plan, for

this year it is foreseen to increase the number of

treatments of cases with a history of unduly kept

records. Based on the field activities, compared to

the previous period, during this period we have an

11% increase in fines imposed for unduly kept

records, same number in fines imposed for failure to

issue fiscal invoices, 37% increase in fines for

incorrect or non-submitted information, etc.

-

5,000

10,000

15,000

20,000

25,000

Declarers in VAT 2017/2018

Janar-Dhjetor 2017 Janar- Dhjetor 2018

342435

Taxpayers registered from operational activities

Janar-Dhjetor 2017 Janar- Dhjetor 2018

- 400,000 800,000

Janar-Dhjetor 2017

Janar-Dhjetor 2018

Value of goods without origin from visits

-

5

10

15

20

25

30

Janar-Dhjetor 2017 Janar-Dhjetor 2018

Mill

ion

s

Value of shortage of stocks from visits

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Continuous lending: - From 23,437 taxpayers who

have declared in VAT during the period January-

December 2018, only 37% of them have paid at least

once during the entire relevant year.

Noncompliance between declaration and

information available at TAK: - there is a number of

taxpayers who in their monthly declarations of VAT

have not reported the correct amount of imports or

exports or have noncompliance between the

turnover in fiscal cash register and the turnover

declared in VAT declaration. Based on the data from

the risk analysis module the number of taxpayers

with noncompliance by years is the following:

Non-filers and late declarations: Based on the data of

statistical reports and on data from 2017 reports, we

see that this year there is a decrease in the number

of non-filers in VAT for 17%, non-filers in WM for

25%, non-filers in PIT for 33% and in CIT for 46%.

0 1000 2000 3000 4000 5000

Mos mbajtja e regjistrimevene rregull

Mos leshimi i kuponit fiskal

Pasqyre informatash e padorezuar ose jo e sakte

Ndëshkimi administrativ përmallrat pa origjinë

Mos sigurimi i qasjes në libratose regjistrimet

Fines

Janar-Dhjetor 2018 Janar-Dhjetor 2017

0 200 400 600 800 1000 1200

Sektorët tjerë

Ndertimtaria

Aktivitetet e tjera sherbyese

Person Fizik

Industria perpunuese

Akomodimi dhe sherbimi…

Tregtia me shumice dhe…

Visits for incorrect keeping of records

8,852 8,722

-

2,000

4,000

6,000

8,000

10,000

Number of taxpayers who make payments in VAT

Gjendja Janar-Dhjetor 2017 Gjendja Janar-Dhjetor 2018

0 1000 2000 3000 4000

Sektorët tjerë

Informimi dhe komunikimi

Transporti dhe magazinimi

Akomodimi dhe sherbimi…

Aktivitetet profesionale,…

Ndertimtaria

Industria perpunuese

Tregtia me shumice dhe…

Number of payments executed during 2018 in VAT by sectors

0

1000

2000

3000

4000

Eksportetreale/Eksportet e

deklaruara

Importetreale/Importet e

deklaruara

Pef/Qarkullimi nëTVSH

Noncompliance between declaration and information available at TAK

Gjendja Janar-Dhjetor 2017 Gjendja Janar-Dhjetor 2018

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Failure to apply reverse charge in construction: -

There are a number of businesses in the Construction

sector that do not adhere to the legislation, thus

under-declaring. Based on the risk analysis during

2018 we have 1,867 cases applying the reverse

charge. Also during the period January-December

2018 only 2,960 visits have been conducted

regarding failure to apply reverse charge.

Under-declared sale prices: - this treatment targets

all those businesses which do not declare the correct

goods sale prices, according to the arm’s length market. During the period January-December 2018 82 audits have

been conducted, compared to the same period of last

year where we had 84 audits.

Failure to withhold taxes: - During 2018, from the

field activities, about 2,552 employees have been

registered in different sectors. When compared to

the previous year, we have about 1,190 more

employees registered in the period January-

December 2018, whereas an increase for 3% in the

number of declared employees.

TVSH WM CD PD

Jodeklaruesit -17% -25% -33% -46%

-50%

-40%

-30%

-20%

-10%

0%

Non-filers

0

400

800

1200

1600

2000

Gjendja Janar-Dhjetor 2017 Gjendja Janar-Dhjetor 2018

Number of cases applying reverse charge

0 200 400 600 800 1000 1200

Sektorët tjerë

Ndertimtaria

Aktivitetet e tjera sherbyese

Person Fizik

Industria perpunuese

Akomodimi dhe sherbimi…

Tregtia me shumice dhe…

Visits for failure to apply reverse charge 2018

0 20 40 60 80 100

Janar-Dhjetor 2017

Janar-Dhjetor 2018

Number of audits for under-declared sale price

3,058,124

2,447,715

Additional tax from audits

Janar-Dhjetor 2017 Janar-Dhjetor 2018

- 100 200 300 400

Janar-Dhjetor 2017

Janar-Dhjetor 2018

Thousands

Declared employees

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Inadmissible deductions: - From the results of the

audits carried out during January-December 2018, in

order to verify whether the incurred expenses are

correct or not, a total of 218 audits have been

conducted resulting in over 10.2 million euros

additional tax.

Under-declarers: - Another rather frequent

phenomenon is incorrect declarations or under-

declarations. Always referring to the results from the

field, during the period January-December 2018 we

have 109 audits conducted by field teams resulting in

a total of over 1.5 million euros additional tax.

Failure to pay: - Until December 2018 the number

of taxpayers having tax obligations to TAK

reaches over 27 thousand, and compared to the

same period of last year we have an increase of

39% in the number of taxpayers with outstanding

obligations.

1,363

2,553

Employees registered from the visit

Janar-Dhjetor 2017 Janar-Dhjetor 2018 0 50 100 150 200

Janar-Dhjetor 2017

Janar-Dhjetor 2018

Number of audits to under-declarers

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

Janar-Dhjetor 2017 Janar-Dhjetor 2018

Aditional tax

20,16127,925

Taxpayers with outstanding tax obligations

Janar-Dhjetor 2017 Janar-Dhjetor 2018

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RISK MANAGEMENT DIVISION: JANUARY-DECEMBER/2018 REPORT

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Delays in paying tax obligations: - Over 77.3

million euros is the value of the collection from

activities of Forced Collection during the period

January-December 2018, compared to the same

period of last year where we have a higher

accomplishment for 16%, or, expressed in value,

for 10.4 million euros.

0

20

40

60

80

100

Janar-Dhjetor 2017 Janar-Dhjetor 2018

Mill

ion

s

Collections from Forced Collection activities