VAT Audits of Evasion Cases in Albania

VAT evasion is a heading that covers a whole rangethe future. The circumvention of rules governing
of different types of fraud. The most well-known ofdistance selling is also penalized as tax evasion.
them are so-called "under reported" sales. This meansForging documents to benefit from preferential
that sales made are not reported to the tax authoritiescustoms tariffs and the deliberate use of incorrect
and in some cases no VAT is charged. The greatestcustoms classification are also widely used practices in
challenge, however, are orchestrated attacks againstorganized tax evasion.
the VAT system and thus against the stability of publicField audits
finances. These types of fraud effectively exploit theInspections and investigations are conducted to gather
system of value added tax collection and input taxfacts of fiscal relevance and information for the
reclamation, with one party to a transaction failing todetermination of existing tax obligations. Tax audits are
pass on VAT proceeds to the tax office while thecarried out by tax office audit units (with the tax office
other party reclaims the input tax shown in the invoiceusually being responsible for auditing small and
from the tax office. Such schemes are frequentlymedium-sized enterprises) or large trader audit units
operated by businesses that are set up for the sole(special units auditing large and very large enterprises).
purpose of VAT evasion and close down again afterA special priority area are special VAT audits, which
just a few months. Deliberate failure to report or payoften result in the detection of large-scale tax evasion
VAT results in massive tax evasion.or insufficient tax payments, deferments of tax and
In 2008, tax audits carried out by the tax officesinadequate record-keeping.
resulted in the additional assessment of more than halfThe focus of tax audits is on the retrospective
a billion Albanian Leks (1 Euro is equal to 135 Leks) inreviews of balance sheets and tax returns filed by
VAT from businesses, with the lion's share of morebusinesses. The findings of such audits relate to all
than 180 million Leks being accounted for by unjustifiedtypes of taxes (VAT, income tax, corporation tax,
deduction of input tax. As a result, the Albanianetc.). Besides the actual under reporting of revenues,
economy suffers a massive competitive disadvantage,which affects both VAT and income taxes, it is also
as competitors not paying their VAT liabilities are abledivergent views on individual balance sheet items that
to offer goods and services at significantly lowerresults in significant additional tax assessments. Audits
prices than businesses honoring their tax obligations.generally cover periods for which annual tax returns
Artificial companies on demandhave already been filed. The detection of major fraud
Especially in the construction and related industries,cases requires rapid intervention on the part of the
setting up fake companies for the systematic evasionauditors. Audit activities performed at short notice,
of wage taxes and social security contributions is aincluding special VAT audits, permit the rapid
widespread practice. The "lifecycle" of suchidentification of artificial firms, fictitious invoices and
companies is short (not more than one fiscal year);cases of carousel fraud.
therefore new supplies of new artificial companies areAnother key component of the audit work conducted
being created in an ongoing process. The only purposeby the financial authorities is the "joint audit of
of fake companies: tax evasion and social securitywage-related taxes and charges". Different types of
fraud. However, as liability rests only with thewage-related taxes are no longer checked by
managers of these enterprises and they are usuallydifferent people at different times, but all wage-related
just front men, it is generally very difficult to actuallytaxes are verified by one audit official working for
hold anyone accountable for the fraud.either the tax office or the social security organization.
Tax evasionThis way, wage tax, social security contributions and
Organized tax evasion very often involves unlawfullymunicipal taxes can be audited simultaneously, which
benefiting from tax-exempt supplies or export refunds.greatly improves the efficiency of such controls.
It also includes non-payment of VAT as a result ofIn 2009, 195 auditors and investigators were engaged
insolvency and the subsequent establishment of a newin monitoring legal compliance by large, medium-sized
company, a method that is applied quite systematically.and small enterprises. The extra tax revenues
In such cases, one-sixth of the amount that is paid forassessed as a result of more than 2,110 audit
an item by the consumer - and thus by any memberprocedures amounted to Leks 25.2 million.
of the public - flows into organized tax fraud schemes.The most important task is to not only respond after
Because of this "willful" failure to pass on VAT to thethe fact to offences already perpetrated, but to also
tax authorities, the "seller" is able to sell goodsanalyze potential risk scenarios in advance and to
significantly cheaper than an (honest) competitor. Thisattain control by means of strategic and organizational
VAT share of one-sixth of the selling price is oftenmeasures. For this purpose, cooperation with national
higher than the trader's "gross profit margin".and international authorities has to be developed
It is quite obvious by now that massive tax lossesfurther and maintained. This is done through periodic
occur in a number of industries and that tackling thisformal and informal contacts and the exchange of
type of fraud will be one of the greatest challenges ofexperiences and information in specific areas.