On 7 April 2020 the OECD Forum on Tax Administration (FTA) published a document containing advice on business continuity considerations to be taken into account by tax administrations as they deal with the tax consequences of the COVID-19 crisis.
The guidance has been prepared in collaboration with the Intra-European Organisation of Tax Administrations (IOTA) and the Inter-American Center of Tax Administrations (CIAT).
Owing to its likely duration and severity the crisis creates particular issues in relation to ensuring that important tax administration functions continue and that taxpayers and tax officials are kept safe. The guidance therefore covers important issues such as governance issues, remote working, staff welfare, training and redeployment.
Communication with taxpayers should be facilitated by ensuring the tax administration website is easy to find and easily navigable; there are clear pointers to how to contact the tax administration during the crisis and stating expected response times; the site sets out the ways in which taxpayers can be supported; and any changes in services and processes are communicated clearly.
The document points out that it is important to identify critical functions; desirable functions; and non-essential functions. These might be defined as services that are essential for ensuring the health, safety, security or economic well-being of the country’s citizens, or that are essential for the effective operation of government. They would also include time-critical functions that cannot be interrupted even for a matter of hours. Some tax administration operations may also be important because they enable the continuance of critical functions of other parts of government, so these can be agreed by consultation with other government departments.
As a general rule the tax administration would normally undertake risk analysis to identify the places where core systems may have critical vulnerabilities. The tax administration should already have put in place a risk management plan setting out the mitigating actions to be taken. The problem of dealing with the critical vulnerabilities may become wider and more urgent during the crisis and relevant staff may need to consult to consider further mitigating actions that might become necessary. A contact may need to be appointed for each function to liaise with other areas of the tax administration and with suppliers on these issues. Personnel and back-up personnel may need to be identified to continue critical services and functions.
In addition to publishing this document the FTA is taking other actions to assist tax administration. Tax officials across the globe are being brought together online for virtual meetings to discuss a range of measures to continue tax administration operations and protect taxpayers; a discussion forum is communicating actions taken in response to the crisis through the Knowledge Sharing Platform; and following the recent publication of guidance on treaty issues for cross-border workers the FTA is working on further actions to support cross-border workers who are temporarily required to stay in a location other than their usual place of residence or usual workplace.
