13A.4.1 Potential approaches to quantifying avoidance and evasion
Given the illicit nature of tax evasion, developing accurate measures of such activities is extremely challenging if not impossible.
The International Agency for Research on Cancer’s (IARC) Handbook on the evaluation of tobacco control strategies1 outlines six possible approaches to quantifying the extent of avoidance and evasion. These are outlined below together with comments about the validity of estimates provided by each source, and information on seventh method used in the European Union.
13A.4.1.1 Expert opinion
People who may be regarded as having expertise about the evasion of taxes on tobacco products would include:
- Customs and other law enforcement officials
- Investigators hired by tobacco companies to identify wholesalers and retailers selling illegally manufactured tobacco or counterfeit products
- Professionals employed in health and welfare agencies whose disadvantaged clients may be more likely to be using such products.
Such experts can provide invaluable qualitative information about the sort of products being used and characteristics of the individuals they have encountered who are involved in the illicit market.
Customs officials and customs records can provide valuable information about trends in interceptions of smuggled goods. Customs departments generally report on the number of interceptions and the quantities of good seized.
However none of these people has any particular ability or knowledge that allows them to judge the extent of use beyond what they have observed. Investigators and law enforcement officials are likely to have focused on high-risk areas or groups, or to depend on tip-offs. Professionals working in welfare organisations are likely to be in contact only with the most disadvantaged people of the area their agency services. All three are likely to over-estimate use because they are prone to extrapolate through the prism of their day-to-day ‘worst case’ experience to the entire population. All three are also likely to be influenced by second- and third-hand stories from sources who may themselves be biased or misinformed.
13A.4.1.2 Comparison of import and export statistics
An examination of US Department of Agriculture reports on world markets and trade estimated a 30% difference between total global imports and total global exports of tobacco.2 The basis of this claimed 30% size of the global market for large-scale smuggling of legally manufactured cigarettes has never been seriously examined.3 It is not known for instance, whether global exports during the 1990s were recorded and reported on in ways that systematically differed to the ways that imports were recorded and reported on. Cigarette imports in some countries, for instance, are dutied according to the quantity of cigarettes, and in other countries customs duty is charged on the basis on the weight or the value of the product. International research agencies for convenience often assume that one gram of any tobacco product is equivalent to a single cigarette. However, in reality cigarettes weigh considerably less than one gram. In Australia, any measure of cigarettes imported based on a standard conversion of tobacco weight would be underestimating the number of cigarettes imported by at least 25 to 30%.
13A.4.1.3 Comparisons of tax-paid sales and individually reported consumption measures
Tax paid sales generally reflect shipments at the factory or wholesale level rather than individual consumption. These can vary considerably from actual retail sales both because they occur at an earlier point in time than purchase and consumption by individuals, and because refunds of taxes can be obtained on stock supplied to shops but returned unused. It is therefore highly likely that reported consumption will differ from levels of manufactured tobacco, even if there were no illicit trade.
The United Kingdom is one of the few countries in the world to produce regular yearly estimates of illicit trade, with a methodology based on the discrepancy between trends in legal sales and smoking habits as quantified in household surveys.4 Reported consumption from surveys of consumers in Australia is substantially lower than the extent of consumption suggested by tax receipts—see Chapter 2, Section 2.2. This would likely reflect under-reporting of consumption by cigarette consumers. It is unknown whether the extent of such under-reporting may fluctuate over time.
13A.4.1.4 Modelling demand for tobacco products
Researchers in the US and European Union have undertaken several research projects which attempt to estimate the extent of evasion by developing models that include estimates of price elasticity and differences in prices between state (or Member states) and tax-free jurisdictions such as Native American reservations.5,6 This work is interesting and helpful in assessing the likely and observed increases in legal and quasi-legal circumvention following tax increases or in the presence of price differences. However, trends in legal circumvention may not be an accurate predictor of trends in illegal circumvention. Illegally manufactured and smuggled products are likely to be less readily and reliably available (and harder to find), and consumer concerns about illegality.
13A.4.1.5 Survey of tobacco users’ purchase behaviour
Representative surveys of tobacco users that collect information on purchase location and prices paid can be helpful in determining the extent of various forms of tax avoidance, including cross-border shopping, direct purchase via the Internet and duty-free purchases.7
Surveys can also generate estimates of use of tobacco products that are quite clearly illicit such as illegally manufactured tobacco (known in Australia as chop-chop). The accuracy of estimates will be crucially affected by the representativeness of such surveys, and how confident about anonymity the survey respondents were. Market research companies running surveys for commercial clients typically suffer from very low response rates, with a likelihood that those who are most interested in such products (likely to be those who have used them) will be most likely to agree to participate. Large surveys conducted for government agencies or charities are likely to be more representative, although may be susceptible to social desirability bias. Both sorts of surveys are likely to miss highly disadvantaged individuals such as those who are homeless or who suffer mental health problems who may be more likely to use these considerably cheaper products.
Assessing the use of branded illicit cigarettes through surveys is another matter altogether. It is doubtful that respondents could accurately judge whether they have purchased counterfeit cigarettes, especially in the absence of tax stamps. Reproductions of packaging can be highly convincing and small variations in the taste of tobacco products can occur for a variety of reasons—variations in tobacco leaf, variations or changes in manufacturing procedures, freshness of the stock, deterioration of the product due to sun or heat damage, and individual-level variations. Fluctuations in the taste of the product are therefore not a failsafe guide as to whether that product is likely to be counterfeit.
The price of tobacco products is also not necessarily a guide to their legal status. Contraband (including counterfeit) tobacco products are not necessarily substantially cheaper than the cheapest products sold in the legal the market or the popular brands sold ‘on special’ at discount outlets.
Consumers’ likelihood of agreeing that cigarettes they purchased were counterfeit or contraband is also likely to increase substantially after major stories in the media reporting that such products are readily available.
13A.4.1.6 Observational data collection
Relatively untested but potentially quite promising approaches to assessing several dimensions of tax avoidance and evasion is the direct observations of vendors selling illicit tobacco products, and the direct observation of packs provided by cigarette consumers or observed directly by researchers. This has been helpful in several European countries where interviewers were trained to recognise the various health warnings, tax markings and tax stamps required in each country.1
An article published in PLos One in 2011 on tracking Google keyword searches reported a useful method of quantifying consumer interest in purchasing reduced-tax or tax free cigarettes following tax increases in the United States.8
‘Mystery shopper’ studies could provide useful information in the future, but such studies pose quite a few practical difficulties, such as whether retailers would sell contraband stock while any person other than the purchaser was in the store. Two studies from Australia in the years surrounding plain packaging implementation had success in either purchasing illicit tobacco from small retailers,9 or eliciting information or offers to sell chop-chop tobacco to fieldworkers10—see also Section 13A5.4 Measuring changes in illicit tobacco use following plain packaging.
Litter studies of cigarette packs have been used in Chicago in the US where most states require state-specific tax stamps to be affixed to cigarettes11 and New Zealand where cigarettes have carried pictorial health warnings larger than those in many other countries.12 The Chicago study provided a useful estimate of the extent of purchases of packs from the areas adjacent to the Chicago tax zone. The New Zealand study was less informative: packs purchased outside New Zealand (a very popular international tourist destination) may have been legitimately purchased in small quantities for personal use by tourists or locals recently arrived back from overseas.
The adoption of ever-widening restrictions on smoking in outdoor places and strictly applied anti-littering laws would make it difficult to collect packs in many jurisdictions. The IARC review suggested7 that it is likely that the sort of people who litter —despite strong social norms against and laws fining people for littering— may also well be significantly more likely than the rest of the population who smoke to purchase illicit tobacco products.
13A.4.1.7 Composite models
In 2004 the European Anti-Fraud Office (OLAF) of the European Commission contracted professional services company Klynveld Peat Marwick Goerdeler (KPMG) to undertake a detailed assessment of likely market penetration of avoided and evaded cigarettes throughout the European Union.13 The reported estimated that approximately 8–9% of cigarettes fell into that category, and that rates were substantially higher in Estonia, Hungary, Lithuania, Poland and Slovakia. Since 2005, Philip Morris International has funded KPMG14 to continue this initiative known as Project Star.15 Project Star uses a combination of consumer surveys, discarded pack studies, analysis of sales data, import and export data, duty-free sales data, customs seizures and interviews with industry and customs officials to produce its estimates. Project Star is a highly elaborate model which provides a great deal of detail on the characteristics of the market in each country. The work has not been subject to peer review and relies on data provided by tobacco companies but not publicly available, so its quantifications of both avoided and evaded taxes on tobacco products cannot be verified.
13A.4.2 Overview of methods used internationally to quantify illicit cigarette trade
A 2020 review found that there was an increase in comprehensive studies of the scale and features of the illicit cigarette trade in the last decade.16 As discussed in Section 13A.4.2 the study methodologies can be challenging even for experienced researchers: discarded pack collection sample procedures are complex, whereas cigarette consumer surveys require specific questions to get accurate information on illicit cigarette consumption. The research team of the 2020 review published a toolkit on measuring illicit trade in tobacco products to gather researchers’ knowledge on the illicit cigarette trade and provide easy-to-follow instructions for planning and implementing investigations in various settings.17
A summary of the methods used to estimate the illicit cigarette trade in the review is in Table 13A.4.1 below. A summary of some of their findings, along with suggestions from the toolkit, is provided in this section.
13A.4.2.1 Direct approaches
Direct approaches were the empty discard pack study, purchasing packs from vendors, pack examinations in cigarette consumer surveys, and a mix of two or more methods, which facilitate an expanded investigation of the illicit trade. Pack elements that help differentiate legal from illicit packs include brand name, the presence of a legitimate tax stamp, the presence and content of health warnings, price marks, pack size, duty-free markings, and other features.
However, several concerns may arise throughout the pack legality identification process. A few examples are shown below:
- Most states in the United States mandate tax stamps on cigarette packets. The tax stamp, however, is put on clear cellophane packaging rather than directly on the pack. Because most consumers discard the cellophane packaging shortly after opening the pack, determining whether the required taxes have been paid is challenging. It is very hard to discover littered packs with complete cellophane packaging. As a result, illicit trade research undertaken in the United States necessitates further evaluations of pack features beyond tax stamps to determine pack legality.
- Brazil established an advanced tax stamp tracking and tracing system. It should be simple to ascertain whether the correct Brazilian tax been paid for a specific cigarette pack. The excise tax stamp, which provides the pack's unique identifying number, gets torn when the pack is opened. Unfortunately, because of this design, researchers attempting to detect noncompliant packs will be unable to use the tracking and tracing functions unless the packs are received prior to opening.
- ‘The European Union (EU) Tobacco Product Directive requires packs in all member states to carry both pictorial and text health warnings (European Union, 2014). The EU provides the complete list of possible texts and pictures (European Commission, 2016). Countries sharing the same language have packs that are nearly indistinguishable from one another (for example, Germany and Austria), as these packs display identical health and pictorial warnings. Researchers in those circumstances must pay extra close attention to other pack details (for example, in the case of Germany and Austria, the packs carry different quitline messages) to distinguish between packs.’ Page 1317
13A.4.2.2 Gap analysis
One of the frequently used approaches was include gap analysis using secondary data. Gap analysis estimates the illicit cigarette trade using a difference between survey-measured consumption and tax-paid sales or revenue.
Strengths of the gap method are:
- Only two datasets are needed: 1) the quantity of tax-paid cigarettes (usually available from national tax authorities and/or from national customs offices in countries where cigarettes are entirely imported), and 2) cigarette consumption patterns (generally available through user surveys).
- This method does not require primary data collection, special statistical software or extensive econometric skills.
Weaknesses of this method are:
- Not providing an exact figure or estimate of either volume or proportion which may cause underreporting.
- This method should be applied only if the fixed underreporting percentage (as well as the constant percentage for duty-free shopping, etc.) is feasible.
- For comparative reasons, consistency in the survey sample methodology and collection procedures is required.
13A.4.2.3 Coordinated efforts
A number of studies related to the illicit trade of tobacco products have been conducted as part of government efforts aimed at quantifying and comprehending the illicit trade in tobacco products. To measure revenue losses resulting from the illicit trade in tobacco products, the UK has published annual reports since 2001.32 This endeavour assists in assessing the performance of the UK's anti-illicit tobacco strategies by quantifying illicit commerce consistently over time. The Brazilian Ministry of Health funded a telephone survey to investigate the scope of illegal trade in Brazil from 2014 to 2017.33 Gambian and Mongolian officials from government organizations participated in studies on illicit trade in their countries.37,38 A Lithuanian study was funded through a government grant.36
13A.4.3 Tobacco prices and illicit trade
The 2020 review16 found that the variation in illicit cigarette prices is large across the various countries, even after adjusting purchasing power parity, and the pricing of illegal cigarettes often correspond to the prices of legal cigarettes.
13A.4.4 Illicit tobacco trade in Aotearoa New Zealand
The New Zealand Government has had a similar tobacco tax policy to Australia: it implemented a series of annual tax increases—10% on top of adjustment for inflation— from 2010 and 2020, by 10% each year.39 Based on data from 2010 to 2013, ASH New Zealand estimated that between 1.8 and 3.9 percent of total tobacco consumption (including cigarettes and loose-leaf tobacco) was illicit.40 This was a small increase from the 2010 ASH estimate that the illicit market accounted for between 0.7 and 2.0 percent of all tobacco consumption,41 suggesting that tax increases enacted by the NZ Government since 2010 had a minimal impact on use and purchase of illicit tobacco.
13A.4.5 More reports on illicit tobacco trade from other international groups
The World Customs Organization (WCO) reported that tobacco products account for more than two-thirds (69%) of all seizures of excise goods in 2022, while seizures of alcohol products account for 31% of seizures.42 Cigarettes make up half of all seizures and contribute to approximately half of the reported revenue seizures. Seizures of other tobacco products account for 15.7% of all seizures. Among seizures of other tobacco products, 49.9% were related to chewing and dipping tobacco in 2022, compared to 46.3% in 2019 and 32.8% in 2019. Almost 30% (28%) of other tobacco product seizures were related to hand-rolling and pipe tobacco in 2022, similar to 28% in 2021 and 22.8% in 2019.
The International Property Crime Threat Assessment 2022,43 published by EUIPO and Europol, reported that tobacco consumption decreased continuously over the past years in the EU, but that 7.8% of total cigarette consumption was illicit, with a loss of EUR 8.5 billion in tax revenues. The report highlighted that there was an ever-increasing volume of counterfeit cigarettes detected in the EU, and this has been partially attributed to the presence of illegal tobacco factories within the EU.
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