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An international comparative analysis of self assessment: What lessons are there for tax administrators?


There have been many tax regimes over the last two decades that have moved either to a full or partial system of self assessment. While the reasons for adopting self assessment vary, the most fundamental (and common) reason appears to have been the desire to achieve administrative cost savings. However, an important consequence of self assessment has been that taxpayers have had to assume greater responsibility for their tax affairs and this in turn has implications for tax compliance.

This paper compares and contrasts the implementation and operation of self assessment in eight countries namely the United States, Canada, Japan, Pakistan, Bangladesh, New Zealand, Australia, and the United Kingdom. Some of these countries were early adopters of self assessment, while others are still in the early stages of implementation. Further, some countries have moved to a complete self assessment system, while others have implemented partial systems. There are also variations between these regimes in terms of the supporting mechanisms including penalty provisions, enforcement, post assessment reviews and the ease of compliance. Furthermore, taxpaying culture and attitudes differ across regimes.

From this international comparative analysis emerge lessons for tax administrators on how best to implement and support self assessment, and at the same time, manage compliance risks and improve voluntary compliance. These lessons have relevance to all regimes, as the ongoing need for tax reform is undoubtedly a global phenomenon.

Author profiles

Ann is an Associate Professor at Bournemouth University.
Current at 1 February 2012
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Prof Margaret McKerchar
Margaret is a Professor Australian School of Business, School of Taxation and Business Law, The University of New South Wales. - Current at 01 May 2014
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Ern Chen LOO
Ern Chen is a PhD student at the University of Sydney, Orange and a Lecturer in Taxation at MARA University of Technology, Malaysia.
Current at 3 November 2005
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