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    Who paysthe price?hunger: the hidden

    cost of tax injustice

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    Poverty is an outrage. It robs peopleof dignity, freedom and hope,of power over their own lives.

    Christian Aid has a vision anend to poverty and we believe

    that vision can become a reality.We urge you to join us.

    IDCS is an Indian government-sponsored programme and Indiasprimary social welare scheme to tackle malnutrition and healthproblems in children aged under 6 years o age and their mothers.Christian Aid partner Chetna Vikas helps some o the mostremote and poorest communities in India to access and improvegovernment welare schemes available to themChristian Aid/Sarah Filbey

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    hunger: The hidden cosT of Tax injusTice 1

    contents

    Introduction 2

    1. Hunger the true extent 5

    2. Why tax dodging means people go hungry 9

    3. How tax justice could help combat hunger in India, El Salvador and Ghana 14

    4. Secret links: how companies can use tax havens to dodge taxes 28

    5. Swissploitation: the hidden cost of trading with Switzerland 32

    6. Recommendations: what political leaders need to do in 2013 40

    Endnotes 44

    Abbreviations 48

    Appendix 49

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    ChristianAid/NameName

    This is a standard picture caption, it is the same width as thecolumns on the main pages

    introduction

    Ana Maria Ayalas maize crop was completely destroyed by oodsin El Salvador in October 2011. Most o El Salvadors armersrely on what they can grow in their smallholdings. Inequality,an unair tax system and lack o government investment inagriculture mean almost hal the population live in poverty, andone-third o all children aged under fve die rom malnutrition

    ChristianAid/SusanBarry

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    hunger: The hidden cosT of Tax injusTice 3

    Hunger still blights the lives o one in eight o the That the world remains a long way o seeing these

    global population some 868 million people.1 Progress commitments met is a shameul indictment o modern

    towards halving the number o people who are hungry day priorities, or the sad truth is there would be enough

    by the year 2015, a goal set by world leaders at the turn ood to sustain every man, woman and child on Earth i

    o the century, is disappointing. the interests o the poor were properly upheld. Lacking,

    however, is the political will needed to saeguard their

    In sub-Saharan Arica, the number o people rights, and sucient resources in developing countries

    undernourished has actually increased. In Asia too, the to implement pro-poor policies that would usher in

    gures are alarming. India, at the oreront o newly lasting change.

    emerging economies, is still home to a quarter o

    the worlds hungry, with more than 40 per cent o its In 2013, a mass campaign by more than 120

    children malnourished and stunted.2 organisations in the UK has been launched6 to draw

    attention to some o the key steps that could and

    Hunger has many causes: harvests ruined by food should be taken to help eradicate hunger. Key

    and drought both increasingly common due to demands include greater support or small-scale armers

    climate change lead to shortages and rising prices who produce about our-ths o ood supplies in

    that poor people can ill aord. In addition, a woeul developing countries, as well as measures to address a

    scaling back o investment in small-scale arming in the undamental malaise that hampers the eorts o poorer

    developing world has hit the ability o communities to governments to help themselves: illicit capital fight and

    eed themselves. So, too, has the impact o large-scale tax dodging by multinational corporations (MNCs).

    cash-crop plantations, particularly those producing

    biouels, which have orced poorer armers o the land. Christian Aid estimates that businesses that benetrom lack o transparency in trade and nancial systems

    Confict also plays a role in exacerbating hunger: crops deprive the poorer countries where they trade o some

    are burned or seized or eeding armed groups; people US$160bn (102bn) in tax revenues every year ar

    are driven rom their homes; and there is a shortage more than such countries receive in aid.7

    o labour because o recruitment into armies and

    militias. Employment or migrant workers also ceases Tax revenues are predictable and sustainable

    as in the recent cases o Libya and Ivory Coast sources o income. They are undamental to allowing

    ending the sending home o income to communities developing-country governments to oster human

    in neighbouring states where ood shortages may development. But most poorer countries lack the sta,

    also be acute. expertise and access to corporate inormation to counter

    activities such as transer mispricing, in which some

    Massive rich-country investment in commodity unds MNCs manipulate the prots they make and oten hide

    is yet another actor contributing to rising prices its them oshore.

    impact now so marked that a number o banks no

    longer oer such portolios.3 In this report, Christian Aid provides new evidence o

    how an end to such practices, coupled with appropriate

    Global acceptance that everyone is entitled to development policies, could make major progress

    a standard o living adequate or the health and towards eradicating world hunger. We realise that not all

    wellbeing o himsel and o his amily, including ood4 the revenues raised would automatically be channelled

    was enshrined more than 60 years ago in the United to priority areas such as health and nutrition. There are

    Nations Universal Declaration o Human Rights, other priorities such as education and inrastructure.

    with subsequent UN declarations and conventions There also remain the challenges o corruption and

    underlining the duty o governments to respect, government profigacy; challenges to which Christian

    protect and ull that right.5 Aid and our partners are rising. But without doubt, airer

    tax systems and greater tax revenues could lead toincreased practical measures to reduce ood insecurity.

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    4 Who pays The price?

    Chapter 1 looks at the extent o world hunger today. Chapter 5 looks at the role one tax haven, Switzerland

    (the most secretive o all, according to a recent survey

    Chapter 2 explains how unsustainable tax competition, by the Financial Secrecy Index8), plays in helping MNCs

    ineective tax systems and nancial secrecy enable shit prots and dodge taxes. Analysis o trade data

    MNCs and wealthy individuals to illicitly shit capital to shows that developing countries could have lost as

    jurisdictions with low or zero tax rates, thus dodging much as US$578bn (368bn) between 2007 and 2010

    taxes and maximising prots. It also looks at the rom MNCs trading with or via Switzerland. This is ar

    practical measures that could be unded with the more than the annual estimated US$50.2bn (32bn)

    money lost. cited in a 2012 UN Food and Agriculture Organization

    report that would be needed to create a world ree rom

    Chapter 3 looks at three middle-income countries hunger by 2025.9

    India, El Salvador and Ghana showing how unair tax

    systems and low tax revenues aect the lives o the Finally, chapter 6 contains policy recommendations

    poor. about how to tackle nancial secrecy, illicit capital fight,

    and tax avoidance and evasion. The UK government, as

    Based on the analysis o a sample number o MNCs chair o the G8 in 2013, and the government o Ireland,

    operating in our three country examples, chapter 4 as President o the European Union or the rst six

    shows that those with connections to tax havens are months o the year, have a golden opportunity to take

    paying 28.9 per cent less in taxes as a percentage o determined action to make tax justice a major weapon

    prots than MNCs with no tax haven links. against poverty and hunger. Its an opportunity they

    must not shirk.

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    Dorcas in the yard o her parents home in Fooshegu, northernGhana. Thanks to the support o Christian Aid partner NorthernPresbytery Agricultural Services, her ather, Samson Napatia, isable to give her and her fve sisters three nutritious meals a day,even during the hunger season when ood is traditionally scarce.Samson cannot speak highly enough o Northern PresbyteryAgricultural Services feld ofcers. Since they came to hiscommunity with practical ideas to help armers grow more, hismaize harvest alone is 10 times larger enough to see him tothe next harvest. Until the government has the unds to employmore o its own feld ofcers, it will all to NGOs like NorthernPresbytery Agricultural Services to fll in the gaps

    1. hunger the true extent

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    6 Who pays The price?

    Table 1: Number o hungry people worldwide (millions)

    1990/1992 1998/2001 2004/2006 2007/2009 2010/2012

    1,000 919 898 867 868

    Source: FAO, The State o Food and Agriculture, 2012.

    Table 2: Geographic distribution o hunger

    Region Number o

    millions hungry

    Developed regions 16

    Arica 239

    Asia 563

    Latin America and 49the Caribbean

    Oceania 1

    World 868

    Source: FAO, The State o Food and Agriculture, 2012.

    tePowell

    oinet

    Zenabu Razak, caterer at

    Aid/Ant

    Gbanyamni primary schoolin Ghana, prepares the lunch

    tianthat will be provided ree tois

    Chrall o the schools pupils as

    part o Ghanas ree schooleeding programme

    Progress has been made in the fght against hunger Although there has been some progress in recent years

    since the start o the millennium, when 919 million in reducing the number o children globally aected

    people went to bed hungry every night. Today, the gure by hunger, malnutrition and related causes still lead to

    stands at 868 million, a reduction rom 15 per cent o the the deaths o 2.3 million children every year.14 Indeed,

    worlds population to 12.5 per cent.11 childhood malnutrition is the underlying reason or an

    estimated 35 per cent o all deaths o children under

    To that gure, however, must be added another the age o ve in the developing world, with those that

    1 billion people who continue to suer a lack o survive oten suering long-term irreversible damage.15

    essential micronutrients.12 Known as hidden hunger, Meanwhile, one in every six children aged under ve in

    micronutrient deciencies increase the rate o disease, developing countries is underweight, while as many as

    lower lie expectancy and impair cognitive development, one in our suers stunting.16 Recent research suggests

    learning ability and productivity. The result is a tragic that children under ve who are malnourished are likely

    loss o human potential with ar-reaching implications. to see their uture earnings reduced by almost a quarter.17

    In India, or example, iron and iodine deciencies that

    cause stunting are estimated to result in productivity Women, who make up a little over hal the worlds

    loss equivalent to 2.95 per cent o GDP annually.13 population, suer disproportionately, accounting or

    some 60 per cent o the worlds hungry as a result o

    persistent, deep gender inequalities.18

    t t lt m blm t t lt mmt btw l

    m. it ml t lt ltl t ttm mll m, t m vtm , t vt

    Olivier de Schutter, UN Special Rapporteur on the Right to Food10

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    hunger: The hidden cosT of Tax injusTice 7

    W m bm mt w That same year, at the World Summit on Food Security,In recent years, world leaders have been party to a held in Rome by the UNs Food and Agriculture

    series o undertakings and pledges to tackle hunger Organization (FAO), world leaders unanimously

    head-on. In 2000, at the Millennium Summit, they pledged renewed commitment to eradicating hunger

    agreed to reduce poverty at historically unprecedented sustainably and at the earliest date. They set as

    rates through collaborative global action. The rst o the their target reducing respectively the proportion and

    eight millennium development goals (MDGs) aimed to the number o people who suer rom hunger and

    halve the percentage o people aected by hunger by malnutrition by hal by 2015.20

    the year 2015.

    The then-FAO director-general, Jacques Diou, stressed

    the need to produce ood where the poor and hungry live,

    and to boost agricultural investment in those regions.21

    Yet, despite all promises made, a look at the percentage

    o people suering rom hunger and the actual number

    o people undernourished shows that progress has

    been disappointing. In southern Asia, where 327 million

    children, women and men were undernourished in 1990,

    In 2008, the year ood-price spikes triggered rioting the decrease ater more than two decades has been

    in more than 30 countries, the UN Secretary-General less than 5 per cent. Worse still, in Arica, the number

    established a High Level Task Force on the Global o hungry people has increased by 36 per cent over the

    Food Security Crisis, which included heads rom UN same period, rom 175 to 239 million people.specialised agencies, and the World Bank and IMF.

    The truth is we are a long way rom halving the number

    A G8 Summit in Aquila (Italy) in 2009 then agreed a Food o people suering rom hunger.

    Security Initiative that committed US$20bn (12.7bn)

    over three years or sustainable agriculture development

    and saety nets or vulnerable populations.19 However,

    much o the money was later not orthcoming.

    W v t m; w vt t t lmt

    m t t t ltm. W l t wll

    US President John F Kennedy, 1963

    Table 3: Progress made towards halving the number o people who suer rom hunger, expressed as

    prevalence o hunger

    Region Baseline

    1990/1992

    1998/2001

    2004/2006

    2007/2009

    2010/2012

    MDG

    target2015

    Level o

    achievement*

    World 18.6% 15% 13.8% 12.9% 12.5% 9.3% 65.6%

    Arica 27.3% 25.3% 23.1% 22.6% 22.9% 13.65% 32.2%

    Asia 23.7% 17.7% 16.3% 14.8% 13.9% 11.85% 82.7%

    Latin

    America

    and the

    Caribbean

    14.6% 11.6% 9.7% 8.7% 8.3% 7.15% 88.1%

    Oceania 13.6% 15.5% 13.7% 11.9% 12.1% 6.8% 23.1%

    Source: FAO, The State o Food and Agriculture, 2012.

    *Level o achievement is our own calculation.22

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    8 Who pays The price?

    Table 4: Progress made towards halving the number o people (in millions) who suer rom hunger,

    expressed in absolute terms

    Region 1990/1992 1998/2001 2004/2006 2007/2009 2010/2012 WFS

    Target

    2015

    Achievement*

    World 1,000 919 898 867 868 500 26.4%

    Arica 175 205 210 220 239 87.5 No reduction

    Asia 739 634 620 581 563 369.5 47.6%

    Latin

    America

    and the

    Caribbean

    65 60 54 50 49 32.5 49.2%

    Oceania 1 1 1 1 1 0.5 No reduction

    Source: FAO, The State o Food and Agriculture, 2012.

    *Level o achievement is our own calculation.

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    Women prepare ood or the Jan Satyagraha marchers.Christian Aid partner Ekta Parishad organised the march in 2012.More than 50,000 poor and landless armers marched peaceullyto demand rights to the land they have worked on or years.Eight days into the month-long march, the Indian governmentagreed to their main demands

    2. Why tax dodgingmeans people go

    hungry

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    10 Who pays The price?

    W t t tl t long way rom the rate in the developed world they couldmbt achieve all the MDGs including halving the number oThe ace o global poverty and thereore hunger has people living in hunger.30

    changed in recent years. Whereas two decades ago

    most o the worlds poor people lived in low-income23 There are, o course, cogent reasons why developing

    countries, today two-thirds are to be ound in countries countries are unable to raise the requisite amount. Large

    that the World Bank classies as middle-income numbers o their citizens, especially smallholder armers

    countries, such as India and China.24 in rural areas, live in poverty and do not enjoy taxable

    incomes. In addition, such countries have large untaxed

    With that change, in the UK at least, a growing chorus inormal sectors.

    o dissent has questioned whether countries that are

    relatively rich, in comparison to least-developed nations, Revenues are also lost when developing countries oer

    should still receive aid, particularly at a time o cuts in major tax incentives to oreign companies in return or

    public services at home.25 investment. The ear is that without such tax breaks,

    the companies may go elsewhere. In recent years,

    The argument ignores such salient acts as the minimal development agencies, including Christian Aid, have

    dierence in per capita income between low-income sought to draw attention to the huge costs associated

    countries and the economically disadvantaged in middle- with tax incentives. In act, evidence seems to suggest

    income countries. It ignores too the sheer scale o need that costs are oten ound to be higher than the benets

    in many o todays emerging economies. In Brazil, or derived rom the investment they seek to attract.

    instance, a country that has a GDP almost as large as that

    o the UK, some 16 million people the same number as Finally, one o the most important actors workinglive in the Netherlands go hungry every day.26 against developing countries is tax avoidance and

    evasion by MNCs and wealthy individuals. In 2008,

    Christian Aid would like to see a world ree rom hunger Christian Aid estimated that tax evasion associated to

    and poverty, where aid is no longer necessary. For this trade mispricing by MNCs costs developing countries

    to become a reality, the causes o poverty need to be around US$160bn (105.3bn) a year, ar more than they

    addressed and developing countries need to nd the receive in aid.31

    resources to cope on their own.

    Dealing with the corporation tax gap in developing

    As a sustainable and predictable source o nance, countries could, according to research by the IF

    tax revenues have a key role to play in ostering campaign, raise enough public revenue to save the lives

    economic sel-suciency or both the developed and o 230 children under ve every day.32

    the developing world. Providing a sound economic

    ooting or development, air and ecient tax systems hw m bl t talso have an impact on the body politic itsel, leading to Foreign direct investment, the investment in

    greater transparency and accountability on the part o commercial activities in one country by a business in

    governments as taxpayers demand evidence o how another, rose by 2,000 per cent between 1982 and 2011

    their money is being spent.27 to US$1.5tn (955bn).33

    The UK government says: Governance appears to be To attract the vast amounts o oreign capital now

    better where governments have to earn their incomes available, many countries have resorted to potentially

    by taxing a wide range o citizens and economic damaging tax competition, such as the reduction o

    activities... Well-managed taxation systems can play a corporate income tax rates, the granting o generous tax

    major role in state building.28 incentives to oreign corporations, and even, in some

    cases, lax legal enorcement and the promotion o

    Today, however, low-income countries collect an average secrecy provisions, eg banking secrecy laws.o only 13 per cent o their GDP in tax revenues, compared

    to around 35 per cent in countries in the Organisation or Some countries those generally known as tax havens

    Economic Co-operation and Development (OECD).29 The or secrecy jurisdictions have made their capacity to

    UN estimates that i the worlds least-developed countries attract oreign capital their major economic activity.

    raised at least 20 per cent o their GDP rom taxes still a The prime attractions they oer are a low or zero tax

    W tm t [g8] t v bt t v t v. T wll l

    t t l vl t llt t tt t tm

    UK Chancellor o the Exchequer George Osborne, February 2013

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    hunger: The hidden cosT of Tax injusTice 11

    rate and nancial secrecy, heedless o the damage that Financial secrecy enables other orms o illicit capital

    might cause elsewhere. fight too, including corruption. Raymond Baker, a senior

    ellow at the US Center or International Policy and an

    A lack o inter-government cooperation at regional and internationally respected authority on money laundering,

    global levels and the eective infuence o powerul has estimated that some 3 per cent o money moved

    beneciaries rom the tax competition phenomenon illicitly around the world consists o the proceeds o

    have resulted in numerous legal loopholes as well bribery and thet by government ocials.40

    as a lack o transparency, which enables MNCs and

    wealthy individuals to shit capital and prots in secret Research published last year estimated that US$854bn

    to minimise their tax liability. (543bn) illicitly escaped rom sub-Saharan Arica

    between 1970 and 2008. This gure is double the

    One method used by some MNCs is transer ocial development aid fows over the same period,

    mispricing, where dierent subsidiaries o the same and our times the size o Aricas debt in 2008,41 thus

    corporation sell goods and services to each other at making sub-Saharan Arica the region with the highest

    manipulated prices. False invoicing involves similar prevalence o undernourishment a net creditor to the

    transactions taking place between unrelated companies. rest o the world.

    With 60 per cent o world trade, according to the OECD,34 Its clear that ar-reaching global action is needed to prise

    now taking place between companies that are part o the open the nancial secrecy o tax havens that not only

    same MNC, such transactions play an important part in acilitates tax dodging, but also hides the proceeds o

    articially distributing prots and tax liabilities.35 corruption, drug tracking and other crimes.

    However, transer mispricing is not the only mechanism Governments have their role to play (as outlined in

    used by corporations to dodge taxes. As ActionAids chapter 6), but MNCs do too. The UN Guiding Principles

    recent report on Associated British Foods shows, on Business and Human Rights state that corporations

    corporations establish complex corporate structures to have the duty to respect human rights, including

    exploit tax legal loopholes and benet rom the existing the right to be ree rom hunger.42 However, when

    network o tax agreements between countries (double corporations engage in abusive tax avoidance or evasion,

    tax treaties).36 they create an adverse impact on the human rights o

    others. Such activities, even when legal, are increasingly

    These complex corporate structures oten involve the being seen as immoral.

    establishment o subsidiaries in tax havens. The sheer

    scale o business now conducted through tax havens is hw t v immense. More than hal o world trade today ollows Tax revenues should account or at least 20 per cent

    such a route: hal o all banking assets are held oshore o a countrys GDP or sustainable development to

    and one-third o oreign direct investment is channelled become a reality.43 Indeed, evidence suggests that

    through such accounts.37 Arican countries with higher tax collections generally

    have lower levels o undernourishment: countries

    This secret world allows vast amounts o money to collecting more than 20 per cent o their GDP in tax had

    be hidden rom public scrutiny, acilitating tax dodging an average level o undernourishment o 15 per cent

    and massively reducing revenues that could promote during 2005-08, while those collecting less than 10 per

    development. The OECD has estimated that the money cent had an average rate o undernourishment o 32

    lost by developing countries to tax havens is nearly three per cent.44

    times the amount o aid they receive.38

    Increasing tax revenues is necessary to end hunger

    More recent research by the Tax Justice Network and poverty. However, what matters most is how

    estimates that rich individuals alone could be hiding as governments make an eective use o the nancialmuch as US$21tn (13.4tn) in tax havens. I the capital resources available. In this sense, the eective

    gains o 3 per cent o US$21tn (13.4tn) were taxed at investment o tax revenues to increase the productivity

    30 per cent, it would generate revenues o US$189bn o smallholders agriculture and develop appropriate

    (120bn) a year.39 pro-poor markets becomes essential.45

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    12 Who pays The price?

    Today, more than hal the population o the developing As well as enhancing ood security and maximising

    world (3.1 billion people) live in rural areas and, o these, the productivity o limited arable land, the right kind

    2.5 billion derive their livelihood rom agriculture. In o support or smallholders can contribute to poverty

    many developing countries, agriculture remains the main reduction through multiple benets, including providing

    driver o economic growth and is oten the sector that is employment,48 building resilience to sudden changes

    most resilient to global economic crises.46 in the weather or other actors aecting ood supply,

    empowering women and vulnerable or excluded

    At least hal o the ood consumed in the world communities, and enhancing the natural resource base

    is produced by smallholders, who produce ood on which the uture o ood production depends, or

    or subsistence and/or or sale to local, as well as instance by promoting soil-conservation practices.49

    sometimes regional and international, markets. These

    arms are the backbone o rural economies. The World Bank estimates that agriculture growth

    is three times more eective in reducing extreme

    However, many ood-producing households are trapped poverty than growth in other sectors, particularly in rural

    in poverty, oten not producing enough or their own areas.50 A thriving agricultural sector is a strong basis

    consumption or making only meagre prots rom their or economic diversication, creating new opportunities

    sales, so they are unable to build up assets or invest that can contribute to much-needed economic

    in practices that could help increase and diversiy their dierentiation and employment.

    production, cope better with risks and uncertainties, and

    seize market opportunities. Tackling tax dodging and nancial secrecy could provide

    the US$50.2bn required every year to tackle hunger.

    Food insecurity47 persists because sucient ood is notproduced or available to poor people in those places

    where it is most needed, and because poor people

    cannot aord to buy enough ood to meet their needs.

    Low levels o production are the result o lack o

    government investment in smallholder agriculture

    or many decades. Small-scale armers are oten

    marginalised by policy-makers, and lack the ability to

    infuence policies and programmes to their benet,

    particularly over the provision o agricultural research

    and technology development, rural credit, transport

    inrastructure, and access to markets to buy and

    sell goods.

    Other important causes o hunger are natural hazards

    such as droughts and foods, slow-onset climate change

    and environmental degradation, lack o income security

    and other saety nets, as well as dispossession o some

    o the worlds most vulnerable people rom land.

    ahWilson

    Even i smallholders produce enough to sell, ood

    markets are characterised by power inequalities and Aid/Sar

    policy and inrastructure ailures, which keep small-scale istian

    ood producers poor, limiting their purchasing power Chr

    and preventing ood rom being distributed to whereit is needed. In many developing countries, local ood In El Salvador, Rosa Cruz worries about her son and

    husband. With no other jobs available, they work in thesugar cane felds, where they are exposed to toxic chemicals.Her husband is already suering rom chronic kidney ailure,which could be caused by the pesticides used in the felds

    markets are ragmented, and in the case o staple oods,

    the usual mechanics o demand and supply do not work

    at all, especially in sub-Saharan Arica.

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    hunger: The hidden cosT of Tax injusTice 13

    What developing-country governments could do to combat hunger

    Tackling tax dodging and illicit capital fight could crops they grow, removing barriers to innovation

    provide much needed revenue to help combat ood and adaptation (or example, lack o access to

    insecurity. Governments in developing countries improved seed varieties), and integrating disaster

    should use tax revenue eectively, particularly in risk reduction strategies and climate services with

    support o measures to improve ood security. This agricultural development work

    could include: implementing eective programmes o social

    supporting ood production or local and national protection or the most vulnerable groups

    domestic consumption and regional markets

    through investment in agricultural research promoting education and health systems,

    involving local armers (including smallholders), including improving nutritional education,

    and the development o technologies appropriate healthcare and amily planning, and access to

    to their needs, including irrigation and storage water and sanitation.

    capacity

    In addition, actions should be taken to: ensuring equitable access, especially o women,

    to credit and land, with a ocus on long-term adopt policies to prevent and manage excessively

    sustainable development volatile ood price fuctuations

    promoting sustainable ood production, empower small-scale producers and their

    which is commercially viable and protable, organisations in decision-making about public

    environmentally sound, inclusive and equitable spending on agriculture and rural development

    promoting pro-poor markets, or example through challenge unsustainable production and

    the development o thriving and integrated local consumption in industrialised countries, and

    ood industries in which ood producers can add highlight the links between ood and energy,

    value to their products and improve their access including the problems o biouels expansion

    to markets promote stronger and more equitable global

    improving inrastructures, such as road systems, governance, particularly o international trade,

    to support ood transportation agricultural investment, and nancial and

    commodities markets. building the populations resilience to ood

    shortages by helping armers to diversiy the

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    3. hoW tax justice coulhelp combat hunger

    in india, el salvadorand ghana

    d

    The Jan Satyagraha 2012 campaign or land rights or some o thepoorest people belonged to, and was rooted in the experiences o,the Indian people. Yet Christian Aid partner and march organiserEkta Parishad stressed the importance o global solidarity to thiscampaign, striving or justice on a very global land issue. Withsecure access to land and ree rom the ear o being orced otheir land by big business, armers are able to invest their timeand resources in caring or the land and ultimately grow moreood or their communities

    ChristianAid/SimonWilliams

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    hunger: The hidden cosT of Tax injusTice 15

    Table 7: Child undernourishment in India

    Percentage o children who are stunted 47.9%

    Percentage o children who are

    underweight43.5%

    Mortality (per 1,000 births) 66

    Source: UNDP, Human Development Report 2011.

    Table 5: Poverty and inequality in India

    Population 1,245 million

    Gross national income (GNI) per capita US$3,296 (2,096)

    Position in Human Development Index (2011) 134

    Income GINI coecient51 36.8

    Average income: 20% richest over 20% poorest ratio 5.6

    Population living on less than US$1.25 (0.80) a day 41.6%

    Source: United Nations Development Programme (UNDP), Human Development Report 2011.

    Table 6: The goal to eradicate hunger in India

    1990-1992 2004-2006 2010-2012 2015 target

    (reduce by 50%)

    Level o achievement

    in 2012*

    Number o people

    undernourished

    (millions)

    240 238 217 120 19.1%

    Proportion o peopleundernourished

    26.9% 20.9% 17.5% 13.45% 69.9%

    Source: FAO, The State o Food Insecurity in the World, 2012.

    *Level o achievement is our own calculation.

    Table 8: India in the Global Hunger Index 201252

    1990 1996 2001 2012

    Global Hunger

    Index

    30.3 22.6 24.2 22.9

    Source: International Food Policy Research Institute

    (IFPRI), Global Hunger Index 2012.

    i

    Indias gross national income (GNI) per capita doubled

    between 1995 and 2010.53Yet, one in every our hungry the goal o halving hunger by 2043.55 As the Nobel Prize

    people in the world lives in the sub-continent. As the winner Amartya Sen put it: there is probably no other

    tables above clearly indicate, India will not reach the example in the history o the world development o an

    target to halve the incidence o hunger by 2015. economy growing so ast or so long with such limited

    results in terms o broad-based social progress.56

    While the proportion o undernourished people has

    allen by 35 per cent since 1990, the actual number o India, with a score o 22.9, ranks 66 out o 79 countries

    people still suering rom hunger only decreased by in the Global Hunger Index (GHI), worse than Niger or

    9.5 per cent, rom 240 million in 1990 to 217 million in Sudan. But the aggregated national data hides important

    2012. Almost hal o the children under the age o ve in internal disparities.India suer rom stunting, while more than 40 per cent

    o children and 30 per cent o women are underweight. According to the India State Hunger Index57 analysed

    In addition, it is estimated that as many as 80 per cent by the International Food Policy Research Institute in

    o children and 56 per cent o women are anaemic.54 2008, the scores ranged rom 13.6 or Punjab to 30.9

    At the current pace o events, India would only achieve

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    16 Who pays The price?

    or Madhya Pradesh, the worst-perorming state. Punjab

    would actually rank 34th when compared to the GHI

    2008 country rankings (between Nicaragua and Ghana),

    while Madhya Pradesh would be ranked 82nd (between

    Chad and Ethiopia).

    The same analysis showed that 12 o Indias 17 states

    all into the alarming category, while the situation in

    one, Madhya Pradesh, was extremely alarming. For the

    majority o states, high child underweight ratios were the

    key reasons or the high GHI score.58

    Despite the signicant and sustained growth rates

    experienced in India in the past two decades, 3,000

    people still die o starvation every year.59 But it is not as

    though the country ailed to produce enough ood or

    everyone. In act, India sold around 10 million tons o

    ood grain in open market in 2012.

    Handling o ood stocks remains a key challenge in

    India.60 Some 80,400 tons o ood grain rotted in 2012

    due to lack o storage acilities.61The government

    claims that its ability to ensure ood or all is limited by

    budgetary constraints.

    T ntl f st Bll t bl tbt tmIn October 2010, concerned with the alarming state o

    ood insecurity in the country, the National Advisory

    Council (NAC) drated a National Food Security Bill,

    proposing legal ood entitlements or 75 per cent o

    the population.

    In January 2011, an expert committee set up by the

    then prime minister examined the Bill and made several

    recommendations, including reducing the percentage o

    the population entitled to the benets o the programme

    rom 75 to 63 per cent.

    Based on these recommendations, a drat Bill was

    circulated in September 2011 by the Ministry o Food,

    Consumer Aairs and Public Distribution or public

    eedback. The Bill nally proposes ood grain entitlement

    or up to 75 per cent o the rural population and 50 percent o the urban population. O these, at least 46 per

    cent o the rural population and 28 per cent o the urban

    population are declared as priority households and are

    entitled to 7kg o subsidised ood per person per month

    (non-priority households are entitled to 3kg per person

    per month). Hence, the Bill ollows a targeted public

    distribution approach.

    However, many in India, including Christian Aid partner the

    Centre or Budget and Governance Accountability (CBGA),

    claim that all citizens in India should be entitled to the ood

    distribution system. For households to be entitled to the

    ood distribution system, they need to be identied as

    poor by the government and receive the corresponding

    Below Poverty Line card. In the past, methods used to

    identiy potential recipients were proved to be based on

    aulty estimates o who was living below the poverty line.

    As a result, the programme ailed to reach many in need.

    Three dierent national surveys62 have shown that as

    many as hal o the current poorest households in India do

    not have a Below Poverty Line card.63

    One o the main arguments or the government to opt

    or a targeted system was the need to control spending.

    According to CBGA, ensuring ood or all vulnerablehouseholds would cost an additional US$20.6bn

    (13.1bn) per year. This gure could be reduced i

    transport systems and storage capacity were improved.

    ChristianAid/SimonWilliams

    Ekta Parishad activist Sita Ram holds a jar containingdonations oten given by people with precious little tospare to support the Jan Satyagraha marchers

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    hunger: The hidden cosT of Tax injusTice 17

    Niyancis experience o the public distribution system (PDS)

    Chr Shortages used to be a major issue. We wereistianAid/Sar

    really struggling; villages were isolated we were

    only having one meal a day and we didnt have anyah means to improve our ood supply, Niyanci recalls.Filbey

    Most o the households were registered as BPL

    Below Poverty Line which meant that they

    were entitled to PDS grain, but collecting it entailed

    an 8km walk to the nearest grain dealership.

    We had to carry it ar on our heads and cross the river

    during the rainy season. It would take us an entire

    day to collect the rice, and when we reached the

    dealership, we were oten told the distribution date

    had changed, explains Niyanci.

    We werent inormed about when the rations had

    arrived. Also they would update the passbook [to

    show wed collected], but say that the rations hadntcome. Months would pass at a time in that way,

    she says, recounting a common tale o corrupt

    administration o such schemes, which are not

    properly monitored.

    The consequences to amilies that depended on

    these rations were signicant. When we were not

    getting rations on time we would have to go or casual

    labour, wed migrate and be underpaid, she explains.

    The situation improved when the womens group,

    ater organising protests, was oered the chance to

    Niyanci Miranda lives in a village called Parasdah, take over the distribution.

    in the state o Jharkhand, where the prevalence o

    hunger is the second-highest in the country. We realised the importance o organising these

    women and giving them a platorm rom which to

    She is a member o a local womens group that claim their rights and entitlements, explains Rani

    was established with the support o Christian Aid Kumari o Chetna Vikas.

    partner Chetna Vikas. The group has been running

    the governments public distribution system, which Niyanci concludes: Although the government is doing

    provides subsidised oods in an area covering quite a lot, it is not enough. We were lucky, but most

    more than 1,000 households. However, while ood o the programme does not reach all people in need

    security has signicantly improved in Parasdah and in India. Many go still hungry.

    neighbouring villages, it was not always like this.

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    18 Who pays The price?

    hw i t v mGiven Indias sustained period o growth between 1990

    and 2010, per capita income grew at almost 5 per cent a

    year in real terms64 the Indian governments claims that

    budgetary constraints hamper its ability to improve ood

    security or the 212 million people that are undernourished

    stretch credulity. Low tax revenues, however, are an issue.

    With a tax-to-GDP ratio o 16.8 per cent, India obtains

    a relative very low level o income compared to other

    emerging economies. Brazil, or instance, has a 34.2 per

    cent ratio, while South Aricas tax revenues represent

    31.2 per cent o its GDP.65

    Another key characteristic o the Indian tax system is the

    relatively low part played by direct taxes (personal and

    corporate income taxes). In 2009-10, they represented

    37 per cent o total tax revenues, one o the lowest o

    all G20 countries, and well below South Arica at 57.5 per

    cent and Russia at 41.3 per cent. 66

    One reason or the short all is the low tax rate enjoyed

    by high earners. The current 30 per cent rate is lower

    than the average maximum personal income tax rate in

    sub-Saharan Arica, which is 35.07 per cent.67

    As or corporate income tax, research shows that there

    is a signicant dierence between the statutory tax rate

    (33 per cent) and the rate that is eectively being paid

    (24 per cent).68 Despite this, a new Direct Tax Code Bill

    proposes to lower corporate taxes even urther.

    Illicit capital fight and tax dodging in the orm o transer

    mispricing by national corporations endeavouring to take

    tax advantages (such as a tax holiday) in the special

    economic zones69 that have been created, as well as by

    international corporations shiting prots to lower tax

    jurisdictions, are a major problem.

    With around 3,500 disputes over alleged mispricing,

    India has the most transer-mispricing cases in the world

    ater Japan and Canada.70 According to the countrys

    Directorate o Transer Pricing, the amounts involved

    in mispricing ran at US$8.1bn (5.2bn) in 2010-11 and

    US$12.6bn (8bn) in 2011-12.71 Corporation tax o 33

    per cent on these amounts would have provided an

    additional US$6.9bn (4.4bn).

    That wealthy individuals and MNCs in India have

    signicantly engaged in illicit capital fight and tax

    avoidance and evasion practices is also conrmed

    by recent research conducted by Global Financial

    Integrity.72The Washington-based think tank estimates

    that India could have lost as much as US$462bn

    (294bn) between 1948-2008. The transer o deposits

    rom Indian to oshore banks by individuals and

    corporations is identied as one o the key routes o

    illicit nancial fows out o the country. As the share o

    oshore deposits increased rom 36.4 per cent o total

    deposits in 1995 to 54.2 per cent in 2009, deposits in

    Indian banks ell commensurately to 45.8 per cent.Not surprisingly, according to research by the OECD,

    Mauritius, a tax haven, appears to be the top investor

    country into India.73

    Generous tax exemptions enjoyed by businesses and

    individuals also help account or the low level o tax

    raised as a percentage o GDP. A government estimate

    o the revenue oregone in exemptions in 2011-12 alone

    was US$99bn (63bn), which represents a staggering

    5 per cent o GDP.74

    Table 9, based on research by Christian Aid partner

    CBGA, suggests tax-policy changes that could provide

    additional revenue. The gures seem to indicate that

    with a airer and more ecient tax system, the Indian

    government could nd the resources required to

    ensure ood security or all its citizens.

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    hunger: The hidden cosT of Tax injusTice 19

    Table 9: How tax policies could provide revenue to tackle hunger

    Area o intervention Policies to be adopted Estimated annual

    additional tax revenue

    Marginal tax rate on personal Increase marginal income tax rate on income above US$5.8bn (3.7bn)

    income US$37,000 (23,532) rom the current 30 per cent to

    40 per cent.

    Capital gains tax Re-introduce long-term capital gains tax on securities US$13bn (8.3bn)

    transactions, and tax short-term capital gainsprogressively as personal income. The current

    zero tax on long-term capital gains on securities

    privileges stock market speculation and avours

    wealthy individuals.

    Property tax, including Expand and make property tax more progressive; US$15.3bn (9.7bn)

    wealth, inheritance and re-introduce inheritance tax (estate duty); improve

    municipal property tax the targeting and valuation system or municipal

    property tax.

    Tax arrears Tax arrears should be collected immediately, and no US$11.5bn (7.3bn)

    laxity should be shown in ling cases.

    Tobacco tax Increase taxes on tobacco, as the current rate is low Increase o US$3.4bn

    according to international standards. (2.2bn) and save

    US$5.6bn (3.6bn)

    on tobacco-related

    diseases.

    General anti-avoidance rule A strong GAAR should be introduced in order to

    (GAAR) tackle aggressive tax planning by corporations.

    The government decided to postpone this measure

    to 2015-16.

    Advance pricing agreements APAs could be established with some relevant US$4.3bn (2.7bn)

    (APAs) corporations as a means to avoid transer mispricing.

    Double tax avoidance The current double tax agreements with Mauritius US$2.3bn (1.5bn)

    agreements and Singapore need to be reviewed in relation to the

    treatment o capital gains tax.

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    20 Who pays The price?

    el slvTable 10: Poverty and inequality in El Salvador

    Population 6.225 million

    Gross national income (GNI) per capita US$5,925 (3,768)

    Position in Human Development Index (2011) 105

    Income GINI coecient 46.9

    Average income 20% richest over 20% poorest ratio 12.1

    Population living on less than US$1.25 (0.80) a day 5.10%

    ource: UNDP, Human Development Report 2011.

    able 11: The goal to eradicate hunger in El Salvador

    1990-1992 2004-2006 2010-2012 2015 target

    (reduce by 50% )

    Level o

    achievement

    in 2012*

    Number o people

    undernourished

    0.79 0.71 0.76 0.395 7.5%

    (millions)Proportion o people 15.6% 12.6% 12.3% 7.8% 42.3%

    undernourished

    ource: FAO, The State o Food Insecurity in the World, 2

    Level o achievement based on our own calculations.

    012.

    able 12: Child undernourishment in El Salvador Table 13: El Salvador in the Global Hunger Index 2012

    Percentage o children who are stunted 24.6% 1990 1996 2001 2012

    Percentage o children who are

    underweight

    6.1% Global Hunger 10.1 8.7 5.4

    Index

    5.7

    Mortality (per 1,000 births) 17 Source: IFPRI, Global Hunger Index 2012.ource: UNDP, Human Development Report 2011.

    S

    T

    S

    *

    T

    S

    In El Salvador, the extent o undernourishment remains One child in our is stunted and, according to a recent

    the same as 20 years ago. Despite a gross national World Bank study, 38 per cent o children aged 6-24

    income per capita o almost US$6,000 (4,000), months are anaemic. In addition, one-third o all

    the prevalence o hunger is very similar to the world deaths o children under ve is considered caused by

    average: one in eight people are hungry. malnutrition.76 Eating varied and nutritious ood remains

    a challenge in El Salvador, the World Bank concluded.

    Although classied as a lower-middle-income country, a

    recent government survey75 shows 47.5 per cent o the Inequality also remains an issue in El Salvador. In 2011,

    population (47.6 per cent o women and 47.3 per cent o the richest 20 per cent o households enjoyed 58.3 per

    men) live in poverty, o whom more than a third (15.46 cent o the national income, while the poorest 20 perper cent) live in extreme poverty. The governments cent accounted or just only 2.4 per cent.77 Exacerbating

    estimation is thus largely consistent with the gures o matters is an unair tax system, where those with the

    undernourishment provided by FAO, as shown in table greatest ability to pay ace the least taxes.

    11 above.

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    hunger: The hidden cosT of Tax injusTice 21

    altl vtmt tl El Salvadors lack o progress in tackling hunger cannot

    be readily understood without considering the damaging

    eects o the stabilisation and structural adjustment

    programmes implemented since 1989. These are the

    series o reorms demanded by donor governments and

    international nancial institutions o poorer countries in

    return or aid.

    In El Salvadors case, they included a decrease in

    trade taris, the suppression o agricultural marketing

    boards, increases in the costs o agricultural inputs, the

    elimination o guaranteed prices to producers, a cutting

    back o agricultural research and technical assistance to

    armers, and the reduction o credit to agriculture (rom

    20 per cent o total credit in 1980 to 7 per cent in 2011).78

    All are actors that help to explain to a large extent the

    collapse o agricultural production, especially o rice,

    corn, vegetables, meat and eggs. In 1993, El Salvador

    produced 93 per cent o the ood grain consumed: today,

    only 28 per cent o rice, 54 per cent o corn and 62 per

    cent o beans eaten are produced locally. All the rest are

    imported. In the case o vegetables, 70 per cent o the

    amount consumed is imported.79

    Today El Salvador invests just 1.5 per cent o its budget

    in agriculture, as opposed to 5.2 per cent in 1990.80 More

    than 80 per cent o its arms are small-holdings that

    do not produce or market, nor do they have access to

    modern production techniques and credit.

    Unsurprisingly, the damaging eects o earlier policies

    have led to a signicant increase in migration. In

    1990, 60 per cent o the population lived in rural areas,

    as opposed to 37 per cent today, while 3 million

    Salvadorans have let the country, most to seek

    new opportunities in the US.81

    A vulnerable community the community. A small piece o land was assigned

    to me by the community, so I can now produceChr some vegetables or our own consumption duringistianAid/Olg

    the rainy season. Unortunately though, I cannot sell

    ood at the market as we need to pay US$2 (1.27)a a day i we want to sell, or US$1 (0.64) i you only

    o

    Castr want to be there in the morning, but there have been

    days where I sold nothing and had no money to pay

    even US$1 (0.64).

    I cannot get a decent job, and I cannot buy meat,

    milk or even cereals or my children. I sometimes

    work or another woman and sell the products that

    she gives me, but with that I only earn US$3 (1.91)

    The community o Milagro Belen is located in a day, not enough to take care o my amily.

    Candelaria, a municipality in Cuscatln Region. It is

    home to 350 people (200 women and 150 men), The act that larger companies and wealthy

    most under the age o 35, grouped into 96 amilies, individuals do not pay their air share o taxes is

    all living in poverty. outrageous. I wonder how it is acceptable that the

    poorest people in El Salvador have to pay VAT, i

    Families in the community mainly eat ruits and then large national and international companies do

    vegetables, with occasional meat and dairy products. not pay taxes. The government has to require large

    Food consumption is severely limited due to companies to pay their taxes, and with that money,

    unemployment, problems to access markets, lack o it needs to create programmes to support rural single

    land security and insucient credit. mothers, old people, and communities throughaccess to land, decent jobs, and seeds and ertilisers

    Rosa Denis Aguilar, a 46-year-old woman, describes to grow our own ood.

    the precarious living conditions aced by amilies in

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    22 Who pays The price?

    The government o El Salvador is currently implementing

    a ve-year development programme, with a total budget

    o US$4.8bn (3bn), or an average o US$975m (620m)

    per year. This plan ocuses mainly on improving access

    and quality o essential services, while only 4 per cent

    o the budget (US$40.6m/25.8bn) is directly devoted to

    promoting agricultural production.82

    Christian Aids partner FESPAD (Foundation or the Study

    and Application o Law) considers that the government

    should urgently upscale the plan to a total investment

    o US$1.4bn (0.9bn) per annum. Some o the priorities,

    as identied by FESPAD, should include the increase in

    the level o credit available, the expansion o the national

    production area, the growth o storage capacity, the

    investment in agricultural research, the improvement o

    irrigation systems and the promotion o womens access

    to credit and land.

    Investing to develop agriculture in rural areas would not

    only raise national production, but also have an important

    domino eect on other sectors o the economy, such astrade, banking services and construction, thus helping to

    reduce hunger and poverty in El Salvador.

    hw t l t tkl Two consecutive waves o scal reorms have been

    adopted by the government o El Salvador in the past

    ew years.

    In 2009, new legislation was passed to counter transer

    mispricing, and the capacity o the revenue service was

    increased. A second wave o reorm took place in 2011

    and brought signicant changes in relation to direct taxes.

    Some 82,000 taxpayers with income below US$503

    (320) per month were exempted rom paying taxes,

    while the tax rate on income above US$6,200 (3,943)

    per month was raised rom 25 per cent to 30 per cent.

    On corporate income tax, the tax rate on income above

    US$150,000 (95,400) was increased by 5 per cent, and

    a tax rate o 1 per cent was created or businesses that

    continued trading despite having declared losses or

    two consecutive years. A tax rate o 5 per cent was also

    introduced on dividends.

    Although these are positive measures, the tax burdenas percentage o GDP in El Salvador is still below 16 per

    cent, compared to the regional average at 18.3 per cent.83

    In addition, the tax system continues to be highly

    regressive, which partly explains the high level o

    inequality. Compared to OECD economies, indirect

    taxes in El Salvador provide a higher share o revenues

    than direct taxes.

    Within direct tax revenues, companies contribute 40

    per cent more than individuals. Within individual tax

    revenues, taxes on labour represent 57 per cent o the

    total,84 which suggests that the tax burden in El Salvador

    is disproportionately placed on ordinary people.

    El Salvador also aces a very signicant challenge in

    relation to tax evasion and generous tax incentives.

    The government estimates tax evasion, oten in the

    orm o transer mispricing, costs El Salvador as much

    as US$1.7bn (1.1bn) a year, which is twice the 2012

    scal decit.85

    According to a report published by the Economic

    Commission or Latin America and the Caribbean

    (ECLAC), the overall income tax gap in El Salvador in2005 was estimated as 45.3 per cent o the tax income

    revenue, equivalent to 3.1 per cent o GDP.86

    O this, the tax gap or corporate income tax was

    estimated as 51 per cent o the corporate tax revenue

    and equivalent to 2.1 per cent o GDP, while the tax gap

    or personal income tax was estimated as 36.3 per cent

    o the revenue and equivalent to 1 per cent o the GDP.

    As or tax incentives, a recent report by the scal

    committee o the legislative assembly indicated that

    there were 26 dierent laws in El Salvador that enabled

    corporations to avoid taxes legally, oten through the

    granting o incentives.87

    The same report stated that the value o these

    exemptions could have been as high as US$9.3bn (6bn)

    between 2001 and 2009. For 2011, the commission

    estimated a loss o US$1.2bn (0.76bn). The tax

    incentives oered in special economic zones cost

    US$206.5m (131.3m), a gure that represents 0.9 per

    cent o GDP.

    This implies that tax evasion and tax incentives together

    are costing El Salvador more than US$2.9bn (1.84bn)every year. Taking action to collect 50 per cent o this

    amount would provide much needed resources to

    eradicate hunger in the country.

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    hunger: The hidden cosT of Tax injusTice 23

    Table 14: How the government could increase tax revenue and combat hunger

    Area o intervention Policies to be adopted

    Tax evasion Strengthen legislation and the tax administrations capacity to ght tax

    evasion, with a special ocus on tackling transer mispricing.

    Tax incentives Review the current policies on tax incentives and other tax avoidance

    provisions, and limit the granting o tax incentives to those cases

    where they are really eective and benets are higher than the

    associated losses.

    Corporate income tax Introduce a more progressive corporate income tax system, where

    those corporations that obtain higher prots contribute relatively more

    to the exchequer.

    Personal income tax Apply the minimum tax rates on income above US$800 (508) per

    month, rather than the current US$503 (320). For single mothers, this

    could go up to US$1,000 (636) per month. With this measure, it is

    estimated that the government may lose US$35m (22.3m) per year,

    but it would promote consumption and reduce inequality.

    VAT Introduce a new 35 per cent tax on luxury items.

    Property tax Introduce a new tax on property, with lower tax rates in rural areas.

    Tax revenues rom property taxes could be transerred to municipalities

    at local level.

    Compiled by Christian Aids partner FESPAD.

    ChristianAid/SusanBarry

    This community lostits entire shrimpharvest due to theextreme oodingacross El Salvador

    in October 2011caused by TropicalDepression 12E. Withno unds availableto help them rebuildtheir livelihoods,people had to repairthe damage and buynew shrimp larvaethemselves beorethey could startharvesting again

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    24 Who pays The price?

    Population 25 million

    Gross national income (GNI) per capita US$1,584 (1,007)

    Position in Human Development Index (2011) 135

    Income GINI coecient 42.8

    Average income 20% richest over 20% poorest ratio 9.3

    Population living on less than US$1.25 (0.80) a day 30%

    Source: UNDP, Human Development Report 2011.

    Table 16: The goal to eradicate hunger in Ghana

    Ghana 1990-1992 2004-2006 2010-2012 2015 target

    (reduce by 50%)

    Achievement in 2012

    Number o people

    undernourished

    6 2 1 3 Goal achieved as o

    2012.

    (millions)

    Proportion o peopleundernourished

    40.5% 9.5% 5% 20.25% Goal achieved as o2012.

    Source: FAO, The State o Food Insecurity in the World, 2012.

    Table 17: Child undernourishment in Ghana Table 18: Ghana in the Global Hunger Index 2012

    Percentage o children who are stunted 28.6% 1990 1996 2001 2012

    Percentage o children who are

    underweight

    14.3% Global Hunger 21.4 16.3 12.8

    Index

    8.9

    Mortality (per 1,000 births) 69 Source: IFPRI, Global Hunger Index 2012.

    Source: UNDP, Human Development Report 2011.

    Ghana, a middle-income country since 2010, is widely

    hailed as a positive development story. Clear policies,

    together with a government commitment to support

    and und them, have contributed to a signicant

    decline in poverty and hunger, making it one o the very

    ew countries in sub-Saharan Arica that could halve

    poverty and hunger by 2015. Progress, however, has

    been accompanied by increasing inequalities in the

    living conditions o the Ghanaian people.

    Agriculture is estimated to be the primary source o

    livelihood or about 41.3 per cent o Ghanaians,88 withabout 80 per cent o total agricultural production in the

    hands o smallholder armers.89 Yet smallholder arming

    households, and in particular ood-crop armers more

    than 50 per cent o whom are women are poorer

    and more ood insecure than other groups in Ghana,

    with about hal o them alling below the poverty line.

    Today, around a third o the population lives on less than

    US$1.25 (0.80) a day, more than 1.25 million people are

    undernourished, and more than one child in every ve

    is stunted.

    The three northern regions in particular have suered

    rom lack o targeted policies or, and limited investment

    in, economic development. Fity-our per cent o the

    extreme poor live in the Northern region alone, which is

    home to only 17.2 per cent o Ghanas total population.

    The Upper West, Upper East and Northern regionstogether make up 70 per cent o the countrys poor.90

    These regions have unpredictable rainall patterns and

    only one harvest each year in contrast with two in the

    south. They also ace periodic drought and sometimes

    gTable 15: Poverty and inequality in Ghana

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    hunger: The hidden cosT of Tax injusTice 25

    foods, both o which are increasing in requency because

    o climate change.91These climatic conditions, combined

    with a series o challenges in the agriculture sector, create

    an alarming situation that calls or urgent action. Most

    people living in north Ghana do not have access to ood

    or between three and six months a year.92 Families resort

    to ood rationing in the long, lean season, and cut back to

    two meals a day instead o three. In some cases, parents

    go without to enable their children to eat, and livestock

    and personal valuables are sometimes sold in order to

    purchase ood, making the owners more vulnerable the

    ollowing year as they have ewer assets to all back on.93

    It is estimated that about 40 per cent o under-ve

    mortality in Ghana is linked to malnutrition.94 According to

    the World Food Programme, in 2007 chronic malnutrition

    among children ranged rom 34 per cent to 48 per cent in

    the Northern Region, and acute malnutrition rom 8 per

    cent to 12 per cent in the Upper West and Upper East

    Regions. In a bid to increase crop yields, many children

    are taken out o school to work on their parents arms.

    Central to the attainment o the vision o sustainable

    long-term agricultural development is the need to

    commit the requisite nancial resources to und the

    sector, with special attention to irrigation, research and

    technology, storage acilities and credit. A Medium Term

    Agriculture Sector Investment Plan (METASIP) has been

    developed to achieve an agricultural GDP growth rate

    o at least 6 per cent annually, based on the Maputo

    Declarations commitment to allocate at least 10 per

    cent o government expenditure in agriculture.95

    According to the nancial and investment plan contained

    in the METASIP, it will cost the government o Ghana a

    total o US$766m96 (487m) to achieve the objectives

    o the sector or the period. O this amount, the

    governments total unding contribution is 32 per cent.

    Adopting policies to increase tax revenues could bridge

    the unding gap o US$518.45m (329.7m).

    e v l t t l mmGhana is the rst country in Arica to have adopted a

    tailored national plan to promote a ree school eeding

    programme, ollowing the recommendations o

    the United Nations Millennium Projects Task Forceon Hunger and the New Partnership or Aricas

    Development (NEPAD).

    The programme started as a pilot in 2005 and has since

    been expanded to target more than 1 million school

    pupils rom deprived communities. The programme

    aims at providing one hot and nutritious meal or each

    child every day.

    The programme targeted the eeding o 1,040,000

    pupils by the end o the rst phase (2007-2010), but

    it was only able to reach about 67 per cent o pupils

    targeted.97 An additional US$ 34.5m (22m) would have

    been required annually to meet the initial goal.98

    In 2012, the programme was expected to reach 1,500,000

    pupils with a unding requirement o about US$112m

    (71.2m) to meet the target. However, the government

    was only able to cover 38 per cent and the remaining 62

    per cent had to come rom external donors.99

    Currently, the programme covers just about 22 per cent o

    all primary and kindergarten pupils across the country.100

    Some donors have recently stopped their contributions, so

    the eectiveness and sustainability o this programme is

    largely dependent on a viable source o revenue.

    ChristianAid/AntoinettePowell

    Children at Gbanyamni primary school enjoy their schoollunch provided through Ghanas ree school eedingprogramme. Ensuring that Ghanas government can collectthe taxes it is owed will ensure more unds are available orthe programme to reach more schools

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    26 Who pays The price?

    Fuel or learning

    When I eat, I get energy, says Fuseini. I eel better

    in class ater Ive eaten. I there wasnt ood or us at

    school, it wouldnt be good or us.

    ell

    wo

    But many children are yet to benet because thePet eeding programme does not run in their local

    oine

    t

    school or because their parents rely on their help or

    istianAid/Ant

    arming. This is the case o Sulemana Alhassan, who

    journeys several kilometres to his amilys eld to

    work under the blazing sun. He is just 13.Chr

    Sulemana would much rather be at school, but

    Fuseini Fatmata didnt start school until she was nine without advice and support rom government on

    years old. Now age 12, shes determined to do well, how to grow more without the need or extra labour,

    but with money tight at home, breakast is never his ather says he needs Sulemanas help. I I dont

    guaranteed. come to help my ather, where will they get enough

    ood? asks Sulemana.

    On the days she misses it, Fuseini struggles to

    concentrate in class. Sulemana doesnt enjoy working on the arm andwould much rather be at school. When I am at the

    Fuseini explains: Sometimes in the morning my arm I dont have a chance to talk to anybody and I

    mother prepares rice and we eat it beore coming become tired. Sometimes I nd when I get home

    to school. [Sometimes] we dont get anything. My there is nothing to eat. My whole body gets weak

    stomach will be boiling when we dont eat and its and I will oten go to sleep early.

    like a sickness to me. I eel dizzy and eel some

    stomach pains and my mind is not on what they are I want to be in school because I want to be a teacher

    teaching us in the class. in the uture. The reason I want to be a teacher is

    they are normally paid at the end o each month. [I]

    For pupils like Fuseini, Ghanas school eeding I got a salary at the end o each month, I could use it

    programme means they get at least one nutritious to help my brothers and sister.

    meal a day and can make the most o their lessons.

    p m tw t t tkl A series o reorms in the 1980s to the Ghanaian tax

    system contributed to improving overall tax collection in

    Ghana, while making the system airer. As a result, tax

    revenues today, as a percentage o GDP, are well above

    the average in sub-Saharan Arica.

    Direct taxes in Ghana are mainly individual income and

    corporate taxes. Other types o taxes in the direct-taxcategory include capital gains, property and rent taxes,

    which contribute marginally to the tax revenue due to

    inadequate enorcement o these laws.

    The tax burden on low-income earners has been

    lessened through the abolition o tax on the minimum

    wage and the introduction o a lower rate or those with

    incomes only marginally above the minimum wage. This

    is to ensure that disposable income or household basic

    consumption stays above the minimum wage.

    The corporate tax rate was reduced rom 32.5 per cent

    in 2001 to 25 per cent in 2006. However, to increase tax

    revenue, the mining sector corporate income tax ratewas increased to 35 per cent in 2012.

    The contribution o direct taxes to total tax revenue has

    been increasing since 2001, rising rom 24.61 per cent in

    2001 to 32.84 per cent in 2005, and 34 per cent in 2009.

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    hunger: The hidden cosT of Tax injusTice 27

    However, while the share o personal income taxes to

    total direct tax revenue is increasing, that o corporate

    tax ell rom 47 per cent in 2005 to 40 per cent in 2009.

    Indirect taxes continue to be a major source o tax

    revenue, accounting by the third quarter o 2011 or

    about 33 per cent o total tax revenue.101 Some provision

    has been made to reduce the burden on the poor, with a

    range o basic consumption items exempted rom VAT.

    During the 2008 ood crisis, the government removed

    the 20 per cent import duty on rice and other basic ood

    to keep prices down.102

    In the same year, a communication service tax was

    introduced to help und the national youth employment

    programme (NYEP) and a 6 per cent charge is now

    levied on all communications and related services

    (such as internet and data services).103 As o June

    2012, a total o 457,779 young people who would have

    been vulnerable to poverty have been engaged in the

    programme.104

    Ghana passed a new transer pricing regulation

    in 2012 and has since trained a team to oversee

    its implementation. It has also signed the Mutual

    Administrative Assistance in Tax Matters, a convention

    that acilitates the sharing o inormation between the

    tax authorities o signatory nations.105

    s

    cll mDespite Ghanas progress in improving tax revenues and

    making the system airer, a number o challenges remain.

    Coordination among the revenue collection agencies

    has been a major challenge to building an ecient tax

    system. This has been exacerbated by the absence o

    proper mechanisms to share tax inormation among the

    Ghanaian institutions concerned. While the government

    has undertaken some important initiatives, such as

    the creation o an integrated Ghana Revenue Authority

    (GRA) in 2009 and the establishment o the Tax Policy

    Unit to strengthen the capacity in the pursuit o

    accountable, transparent and sustainable tax policies,

    law and reorm and capacity building is still needed.

    Increasing taxes rom the inormal sector, in which 80per cent o the working population is engaged, is a major

    challenge because there are ew records o accounts,

    many people earn very little income, and workers are

    oten invisible to the authorities.106

    Recently, new measures have been introduced including

    a tax on public transport operators and a tax stamp or

    small traders, but these bring in relatively little revenue.107

    Christian Aid partners in Ghana have been working

    with emale small traders who pay taxes and demand

    accountability rom the government on that basis.

    Generous tax incentives oered to oreign investors are

    also a problem. Although corporate taxes in the mining

    sector have been increased, along with a windall prot

    tax o 10 per cent, exemptions seriously undermine the

    potential revenue gains.108

    The IMF estimated that tax exemptions amounted

    to about 1.6 per cent and 0.9 per cent o GDP in 2009

    and 2008 respectively,109 while the Ministry o Finance

    and Economic Planning indicate Ghana may be losing

    US$700m (445m) per annum rom VAT and import

    exemptions. Christian Aid partner Ghana Integrity

    Initiative (GII) has been campaigning or a tax-incentive

    ramework that is transparent, accountable and well

    targeted.

    Ghanas revenues are also being undermined by

    corporations not paying their due royalties. Research110

    undertaken by Christian Aid and other development

    agencies in 2007 revealed that mining companies have

    never paid royalties above 3 per cent, despite the higher

    rates on a sliding scale stipulated in the Minerals and

    Mining Act. These lower royalties led to lost revenue o

    US$68m (43.2m) a year between 1990 and 2007.

    Finally, transer pricing abuse needs to be tackled.

    Analysis o the mining sector suggests that some

    US$36m (22.9m) is lost through transer mispricing

    each year.111 In addition, Christian Aid research has

    showed that the average amount o tax loss to Ghana

    in trade relations with the EU between 2005 and 2007

    through trade mispricing was between 30.7m-51.4m

    (US$41.1m-US$68.9m/26.2m-43.8m) each year.112

    In 2008, the country lost 62.4m (US$83.6m/53.2m)

    because o trade mispricing, which accounted or about

    3.4 per cent o total tax revenue in the same period.113

    The challenges described seriously undermine the

    capacity to raise tax revenues and address ood

    insecurity and poverty in Ghana.

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    4. secret links:hoW companies

    can use tax havensto dodge taxes

    ChristianAid/RachelBaird

    Mopani Copper Mine in Muulira, Zambia. The mine is largelyowned by a subsidiary o FTSE100 giant Glencore. It has beenaccused o dodging tax in Zambia, an allegation it denies. Inaddition, it causes signifcant local environmental damage sulphur dioxide air pollution and soil pollution so bad that mostplants will not grow and, local people suspect, chronic pollution othe water they drink. Christian Aid partner the Centre or Tradeand Policy Development is supporting a local campaign group todemand improvements to the Kankoyo environment

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    hunger: The hidden cosT of Tax injusTice 29

    New research by Christian Aid into the fnancial and

    ownership data o MNCs operating in India, El Salvador

    and Ghana strongly suggests that corporations with links

    to tax havens are not paying their air share o tax.

    o t mtllOur research was to establish whether MNCs with

    subsidiaries in tax havens114 pay less in taxes than

    corporations without such links, based on the hypothesis

    that, because tax havens oer secrecy and nil or low tax

    rates, enterprises using their services have greater incentives

    and opportunities to dodge taxes than those that dont.

    To test this, we analysed three dierent indicators:

    pre-tax prots reported per unit o asset, as a proxy

    or the corporates tax base115

    taxes paid per unit o asset

    taxes paid per unit o pre-tax prot, as a proxy orthe average eective tax rate.

    The concrete research goal was to test i MNCs with

    connections to tax havens report lower pre-tax prots per

    unit o asset and pay less in taxes per unit o asset and

    unit o prot than other multinational corporations. The

    level o revenue was not used as a variable in our research

    because revenue itsel is oten aected by prot-shiting

    strategies, so the preerence was to use assets instead.

    In order to carry out our research, we obtained access to

    Orbis,116 a commercial database containing consolidated

    and unconsolidated nancial and accounting data, as

    well as inormation on shareholders and subsidiaries o

    around 108 million national and multinational companies.

    Data in Orbis is derived rom ocial balance sheets, prot

    and loss accounts, and nancial statements notes, and is

    complemented with news, market research, inormation

    rom ocial bodies (or example, stock exchanges) and

    private correspondence. The producer o the data has

    also developed a uniorm ormat that is applied to each

    entity analysed in order to address comparison issues. In

    our own research, we used the data available in Orbis or

    India, Ghana and El Salvador to produce both descriptive

    and regressive statistical analyses.

    However, two considerations need to be taken into

    account. First, data available or all the required variables

    or El Salvador and Ghana was limited to a relatively small

    number o corporations, so the aggregated results, and

    thereore conclusions, are to a very large extent driven by

    India, or which data in Orbis is much more abundant.

    This limitation also implies that only descriptive

    statistical analysis was applied to Ghana and El

    Salvador, as regression models require a higher sample

    o observations than are available in Orbis or thesetwo countries.

    Secondly, because the data used in our analysis

    belonged to MNCs o dierent sizes and operating in

    dierent sectors with heterogeneous characteristics,

    eg dierent average protability ratios, we took the

    precaution o controlling or these dierences in our

    regression model. In other words, we wanted to make

    sure that dierences ound were really attributable to the

    use o tax havens, and not to other variables such as the

    size o the MNC or the sector where it operates.

    Table 19 shows the results obtained in our research

    when we analysed data rom those MNCs with asset

    values o at least US$10m (6.36m).

    Table 19: Aggregated results or MNCs with asset values o more than US$10m (6.36m)

    MNCs with no tax MNCs with tax haven links Dierences observed: how much

    haven links less profts reported and less

    Indicator Numbero MNCsin sample

    Resultsobtained or oursample o MNCs

    Numbero MNCsin sample

    Resultsobtained or oursample o MNCs

    paid in taxes per unit o asset and

    unit o proft respectively when

    the MNC has links to tax havens

    Prots reported per

    100 units o assets

    770 6.9 727 6.6 4.3%

    Taxes paid per 100

    units o assets

    681 2.3 668 2 13%

    Taxes paid per

    100 units o prots

    680 24.2 667 17.2 28.9%

    Source: table uses data rom Orbis 2010.

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    30 Who pays The price?

    As table 19 indicates, MNCs with connections to tax Tables 20, 21 and 22 show the results we obtained or

    havens reported in 2010, on average, 4.3 per cent less each specic ratio and country on the basis o the data

    prots per unit o asset; paid 13 per cent less taxes per available or all MNCs operating there, regardless o thei

    unit o asset; and 28.9 per cent less taxes per unit o size. As stated above, only the sample or India is large

    prot than MNCs with no links to tax havens. These enough to draw statistically meaningul conclusions.

    results strongly suggest that MNCs with links to tax However, the descriptive results obtained or Ghana

    havens use income-prot-shiting strategies to reduce and El Salvador, based on a much lower number o

    their tax bills. corporations,117 may suggest that prot shiting could

    actually be a more serious problem in those countries

    with less administrative capacity to tackle tax dodging,

    so urther research should be undertaken.

    r

    Table 20: Profts declared per 100 units o assets

    MNCs with no

    tax haven links

    Country Number Profts

    MNCs with tax

    haven links

    Number Profts

    How much less profts reported

    per unit o asset when the MNC

    has a tax haven link

    India 787 6.6 738 6.5 1.5%

    Ghana 25 4.8 3 3 37.5%

    El Salvador 15 15.9 16 4.8 69.8%

    Source: table uses data rom Orbis 2010.

    Table 21: Taxes paid per 100 units o assets

    MNCs with no

    tax haven links

    Country Number Taxes paid

    MNCs with tax

    haven links

    Number

    How much less paid in taxes per

    unit o asset when the MNC has

    a tax haven linkTaxes paid

    India 722 2.3 685 1.9 17.4%

    Ghana 6 3.1 2 0.9 71.0%

    El Salvador 4 0.7 5 0.2 71.4%

    Source: table uses data rom Orbis 2010.

    Table 22: Taxes paid per 100 units o proft

    MNCs with no MNCs with tax

    tax haven links haven links

    Country Number Taxes paid Number

    Taxes paid

    How much less paid in taxes per

    unit o proft when the MNC has

    a tax haven link

    India 714 24.1 683 16.8 30.3%

    Ghana 6 17.1 2 8.6 49.7%

    El Salvador 3 22 5 8 63.6%

    Source: table uses data rom Orbis 2010.

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    hunger: The hidden cosT of Tax injusTice 31

    As indicated in table 22, MNCs operating in India (4.8bn) would have been raised. However, we are not

    with connections to tax havens are ound to pay, on suggesting that the dierence in the eective tax rates

    average, 30.3 per cent less in taxes per unit o prot is entirely explained by prot shiting; other actors, such

    than those MNCs with no tax haven links. Considering as the impact o tax incentives, could have an infuence

    that all MNCs with tax havens links in our sample made as well. In any case, the eective rate estimated in our

    total prots o US$104bn (66.1bn) in 2010, had they research is signicantly lower than the Indian corporate

    paid the same eective tax rate as MNCs that do not income tax rate (33 per cent).

    use tax havens, additional tax revenue oUS$7.5 bn

    Table 23: Additional tax could be obtained i MNCs with tax-haven links paid the same tax rate as other

    MNCs

    Profts declared Eective tax rate Eective tax rate Eective tax rate Tax revenue that

    by MNCs in our or MNCs with no or MNCs with tax dierence could have been

    sample with tax tax haven links haven links lost due to proft

    haven links shiting by MNCs

    with tax haven

    links

    104,000,000,000 24.1 16.8 7.3 7,592,000,000

    Source: research results based on our own estimation, using data rom Orbis 2010.

    The results obtained in the descriptive analysis are where MNCs can exploit the existing legal loopholessupported by those obtained in the regression model, and secrecy provisions to avoid paying their air share

    as shown in appendix 1. Our regression results remain o tax.

    valid when we control or both sector heterogeneity118

    and company size. All the dierent specications in the While the separate legal entities that orm a multinational

    regression analysis show consistent results and indicate corporation are treated rom a tax perspective as i they

    that MNCs with links to tax havens report ewer prots were independent companies, the truth is that they all

    and pay less in taxes per unit o asset and prot. In the ollow an overall business strategy. Today, management

    regression analysis, our results are particularly strong lines clearly go beyond national boundaries.

    (statistically signicant) when the variable taxes paid per

    unit o asset is analysed. In its report, the OECD identies prot shiting as a

    undamental cause o tax dodging. Similarly, the OECD

    Christian Aids research strongly suggests that acknowledges the increased segregation between

    multinationals oten use tax havens to shit prots the location where actual business activities and

    rom higher to lower tax jurisdictions. In many cases, investment take place and the location where prots

    these tax haven subsidiaries lack economic substance are reported or tax purposes. In other words, MNCs

    (eg there are no manuacturing processes or products are transerring mobile activities to where they benet

    sold in the tax havens market), which implies that they rom a avourable tax treatment.

    could exist or the only purpose o avoiding and evading

    taxes. Our ndi