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Malayan Law Journal Articles/2012/Volume 6/Self-Assessment System and Tax Compliance Complexities [2012] 6 MLJ cxxi Malayan Law Journal Articles 2012

SELF-ASSESSMENT SYSTEM AND TAX COMPLIANCE COMPLEXITIES: TAX PRACTITIONERS' PERSPECTIVES

Ming Ling Lai Accounting Research Institute and Faculty of Accountancy Universiti Teknologi MARA Email: laimingling@salam.uitm.edu.my and Kwai Fatt Choong Faculty of Business and Accountancy University of Malaya, Malaysia Email: kwaifatt@um.edu.my In this study, we assess tax practitioners' experience in the era of the self-assessment system. We also examine tax compliance complexities faced by tax practitioners when representing corporate taxpayers. In addition, we also solicit tax practitioners' views on administrative efficiency of the tax authorities. A survey was administered on 700 tax practitioners who attended the 'Budget Seminars' which was organised by the Malaysian Institute of Accountants in Peninsular Malaysia. In total, 208 usable questionnaires were collected and analysed. The survey found that the respondents opined that the self-assessment system brings more benefits to the tax authorities than the taxpayers and that the self-assessment has indirectly increased their workloads and liabilities. About 70% of the respondents indicated that it is difficult to estimate tax payable for a company, due to uncertainty in the economic conditions. About 63% of tax practitioners surveyed indicated that staff members lacked technical knowledge on complex business matters and are slow in tax refunds. Overall, 78% of tax practitioners surveyed rated the tax authorities as 'average' in terms of administrative efficiency. This study provides important insights on tax compliance complexities faced by tax practitioners in the real business world. This paper contributes to fill up a knowledge gap. Keywords: Self-assessment, taxation, tax compliance, tax practitioners, tax system, Malaysia 6 MLJ cxxi at cxxii INTRODUCTION With effect from Year of Assessment ('YA') 2001, the Inland Revenue Board Malaysia ('IRBM') has streamlined the tax administration policies to embrace a self-assessment tax system ('SAS') on companies.

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The main purpose of the IRBM in embracing SAS is to encourage voluntary tax compliance and to reduce tax administration cost. Under the SAS, the burden of assessing tax liability has been shifted from the shoulders of tax assessors to the taxpayers. Hence, to be tax compliant, taxpayers need to possess a good understanding of the income tax laws and the frequent changes in tax legislations. In the Malaysian tax setting, under the SAS, all existing companies are required to submit estimates of tax payable no later than 30 days before the beginning of the basis period. A company may revise the estimated amount of income tax payable in the sixth and/or ninth month of the basis period for a year of assessment. However, the estimated tax payable for the current year of assessment must not be less than 85% from the estimated or revised estimated tax payable of the immediate preceding year. If the actual tax assessment exceeds the original estimate or revised estimate by the amount exceeding 30% of the actual tax payable, the difference will be subject to a penalty of 10%. On the other hand, the monthly instalment payment will be due on the tenth of every month, commencing from the second month of the basis period of the year of assessment. Failure to pay the tax instalment on time will subject the defaulter to a 10% penalty on the amount unpaid, by virtue of s 107C (9) of the Income Tax Act 1967. In addition, a 10% + 5% penalty will also be imposed for every late payment of the balance of tax payable. New companies are required to submit tax estimates within three months from the date of commencement of operations with instalment payments commencing from the sixth month of the basis period. However, in Budget 2008, it was proposed that small medium enterprises (those companies with paid up share capital not more than 2.5 million at the beginning of the basis period) will be exempted from submitting the estimated tax payable and instalment payments for the first two years of assessment after commencement of business operation. In respect of the deadline to file a tax return form, all companies must submit their tax returns within seven months after the closing of their accounts. Failure to furnish a tax return on time can result in prosecution and a fine which is between RM200-RM2,000, or six months' imprisonment, or both, as stated in s 112(1) of the Income Tax Act 1967. It was reported that since the implementation of the SAS, Malaysian tax defaulters have increased by almost 6 MLJ cxxi at cxxiii ten times within two years from 25,160 in 2003 to 239,666 in 2005 (Krishnamoorthy, 2006a). The offences included failure to submit returns, declaring false returns and not providing sufficient information, etc. According to the Chief Executive Officer of the IRBM, around one-third of Malaysians who are eligible to pay tax did not pay tax. In 2005, 1.3 million potential taxpayers did not file their tax returns; it was estimated that the Malaysian Government had lost approximately RM307.7m due to tax non-compliance (Krishnamoorthy, 2006b). To be tax compliant, taxpayers need to be tax literate. For those who operate a business or a company, they must have some basic understanding of taxability of income from business and non-business sources and the deductibility of expenditure. Indeed, in the SAS, business owners and corporations need to have a good understanding of the basic concept of the SAS in order to be tax compliant. However, the Malaysian tax laws are inherently voluminous and complex; and the constant changes make it difficult even for tax officers, tax academics and tax practitioners to keep abreast of the latest development, let alone the ordinary taxpayers. PREVIOUS RESEARCH Prior studies that were conducted in the United States of America ('US') (for example, Erard, 1993; Klepper and Nagin, 1989) and in Australia (for example, Inglis, 2002; JR Marshall, Smith, and Armstrong, 1997; Mckerchar, 2005) found that tax practitioners are playing a crucial role in tax compliance. For example, Klepper and Nagin (1989) asserted that tax practitioners (ie, the professional tax preparers) represent 'both a means of increasing compliance and also potentially a threat to compliance' (p 191). When tax laws are clear, tax practitioners act as 'tax enforcers', whilst, when tax laws are ambiguous, tax practitioners act as 'tax exploiters' (Klepper and Nagin, 1989). Erard (1993) shared the same view; he expounded that tax practitioners are in a position to exercise a strong and direct influence on the tax administration and compliance processes. Newberry, Reckers and Wyndelts (1993) provided the empirical evidence that tax

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practitioners are an important third party, as a great number of taxpayers deal with tax agencies through tax practitioners. Meanwhile, Marshall et al. (1997) found a number of factors that influenced the ethical judgment and shaped the behaviour of tax practitioners. Among the few factors are the probability of audit detection (audit risk), client pressure on tax practitioner to act unethically and the revenue contribution of a client to tax practice. In a later study, Marshall, Smith and Armstrong (2006) found that the severity of tax law violation is an important factor in ethical decision making when representing clients, but audit risk and the amounts involved are not. Using a nationwide online survey on Australian tax practitioners, Mckerchar 6 MLJ cxxi at cxxiv (2005) found that income tax complexities has an enormous impact on tax practitioners in Australia; the burden of (opportunity provided by) tax complexity falls on tax practitioners, as a large proportion of taxpayers rely on tax agents to be tax compliant. Mckerchar (2005) argued that since the implementation of the SAS, tax practitioners in Australia are having bigger roles to play in tax compliance, tax audits and tax enforcement processes. Vos and Mihail (2006) asserted that in self-assessment, tax practitioners are assuming the duty of tax officers. In essence, under the SAS, the responsibilities of the government's tax administration has shifted to the taxpayers but sub-contracted to tax agents/tax practitioners at a cost. In essence, the literature review found even in developed countries such as Australia and the United Kingdom ('UK') provide that the implementation of the SAS was overwhelmed with various problems and criticisms at the beginning. In the UK, a survey conducted by the Association of Certified Chartered Accountants ('ACCA') found that 36% of ACCA members had problems with the SAS and about 9% of them claimed that self-assessment was chaotic even after four years of implementation (ACCA, 2002). On the other hand, Inglis (2002) had the opinion that the SAS is not working properly in Australia as the frequent changes in tax laws make it difficult for tax specialists and tax assessors to comprehend, let alone anyone else. Consequently, on 24 November 2003, the Australian Treasurer announced a major review of the SAS based on concerns raised by the Australian taxpayers and it took almost a decade for the SAS to really make a difference in Australia (Paddock and Oates, 2003). In the Malaysian tax setting, although there is no official statistics on how many taxpayers seek the service of tax practitioners, nonetheless, it is reasonable to assume due to the complexity of income tax laws and the need to comply with the public rulings issued by the IRBM, most businessmen and corporations have to engage tax agents or tax professionals to prepare tax returns. At the time of study, except the studies of Loo and Ho (2005) as well as Choong and Lai (2008) had attempted to study individual and business taxpayers' responses in the post-self assessment regime; no published study on tax compliance complexities faced by Malaysian tax practitioners in the post self-assessment regime. Hence, the lack of scholarly study shapes the motivation for this study. RESEARCH OBJECTIVES The research objectives are (i) to assess tax practitioners' experience in the era of the SAS; (ii) to examine tax compliance complexities faced by tax practitioners when representing corporate taxpayers; and (iii) to investigate tax practitioners' 6 MLJ cxxi at cxxv views on the administrative efficiency of the tax authorities. RESEARCH METHODOLOGY A questionnaire was used to collect data. The questionnaire was administered to 700 tax practitioners who attended 'Budget Seminars' in the months of September and October, which were organised by the Malaysian Institute of Accountants in Peninsular Malaysia. In total, we collected 208 usable responses from tax practitioners who were professional accountants in tax practice. In this study, a 'tax practitioner' is defined as 'tax proprietor, tax accountant, tax adviser and registered tax agent' and this definition of 'tax practitioner' was adapted from studies of Roth, Scholz and Witte (1989) and Marshall et al (1997). DATA ANALYSIS The respondents' profiles

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The respondents' profiles show that a mixture of tax practitioners had responded to the survey (see Table 1). The majority of the 208 survey respondents (62.5%) were from Kuala Lumpur (the capital city of Malaysia); 26% were from the Northern region; and 11.5% were from the Southern region of Malaysia. About 46.1% described themselves as sole practitioners or tax partners/directors in a small firm, 25.5% as tax managers, 15.4% as tax supervisors and 13% as tax assistants. Chinese were the most notable participants, making up about 91%, which reflects the reality that in Malaysia, Chinese dominate the tax professions. Majority of the survey respondents were females (57.7%) who were aged between 25 and 34 years old (45.7%). More than 69% of the respondents possessed professional qualifications and 24% had bachelor degrees. More than 70% of tax practitioners worked in a small firm or firm with a single office, 4.8% worked in firm with multiple offices in one state, and 22.1% worked in firm with offices in more than one state. Only 2.9% of them worked in the 'Big 4' accounting firms. Table 1:The Respondents' Profiles Number 1 Ethnic Group Chinese Malay Indian 2 Gender Male Female 190 13 5 88 120 Percentage (%) 91.3 6.3 2.4 42.3 57.7 6 MLJ cxxi at cxxvi 45.7 36.0 10.6 7.7 24.0 1.0 69.2 5.8 2.9 70.2 4.8

Age

25-34 years 35-44 years 45-54 years 55 years and above

95 75 22 16

Qualification

Bachelor's De- 50 gree Masters Professional Others 2 144 12 6

Size of firm

Big 4

Firm with single 145 office Firm with multiple offices in one state 10

Firm with offices 46 in more than one state

22.1

In respect of professional membership, Figure 1 indicates that majority of the survey respondents were members of the Malaysian Institute of Accountants (66.8%), the Association of Certified Chartered Accountants (45.7%), Malaysian Institute of Taxation (22.1%), Malaysian Association of Tax Accountants (16.8%), Certified Practicing Accountants, Australia (9.6%), Malaysian Institute of Certified Public Accountants (7.2%), Institute of Chartered Secretaries and Administrators (2.9%) and Chartered Institute of Management Accountants (2.4%).

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6 MLJ cxxi at cxxvii The survey also found that 62% of the tax professionals surveyed had more than five years work experience in taxation and 49.5% of them also indicated that at least half of their workloads were related to the preparation of tax returns for companies. Collectively, the respondents' profiles indicate that the survey respondents had vast experience in tax practice and hence could provide useful information on tax compliance complexities faced by the tax practitioners when representing corporate taxpayers in the era of the SAS. Tax compliance complexities faced by tax practitioners in the SAS Several questions were designed to elicit tax compliance complexities faced by tax practitioners with the SAS. At the outset, six statements were designed to elicit the respondents' general experience of the SAS. All statements were measured on a 5 point-scale anchored on (1) 'strongly disagree' to (5) 'strongly agree'. One sample t-tests were used to test the statistical significance of the mean scores. Table 2 presents the mean scores and t-test results. Table 2: Tax Practitioners' Experience of the SAS Mean a. b. c d. e. f. g. The SAS brings more business to tax practitioners 3.42*** The SAS increases the workloads of tax practition- 4.29*** ers The SAS increases tax practitioners' liability 4.39*** The SAS provides more benefits to tax authorities 4.51*** than the taxpayers The SAS increases taxpayers' compliance costs The SAS is implemented effectively in Malaysia 4.40*** 2.60*** Standard Deviation 1.027 0.956 0.951 0.873 0.862 0.982 1.021 t-statistic 5.87 19.56 21.05 24.92 23.46 -5.85 -3.12

In general, the relationship between inland reven- 2.78** ue and tax practitioners has improved since the implementation of the SAS

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* Significant at p<0.1; ** significant at p<0.05; *** Significant at p<0.001. The results show that majority of the respondents concurred with the statement that the 'SAS brings more business to tax practitioners' and the 'SAS has indirectly increased their workload'. The mean score was 3.42 and 4.29 on a 5 point scale respectively (significant at p<.001). This finding is consistent 6 MLJ cxxi at cxxviii with Marshall et al (1997; 2006) who found that in Australia, more taxpayers sought the service of tax agents after the implementation of the SAS. As presented in Table 2, majority of the survey respondents also indicated that the SAS has indirectly increased their liabilities, with the mean score of 4.39 (significant at p<.001).The plausible explanation for this finding is the provision in s 114 (1A) of the Income Tax Act ('ITA') 1967 which requires tax practitioners to exercise reasonable care in performing their duties as a tax agent to the corporate taxpayer. Section 114(1A) can be invoked when there is an understatement of tax by a corporate taxpayer arising from tax advice or services given by the tax agent. Hence, in the SAS, tax practitioners assume onerous responsibilities to ensure that tax returns submitted are in compliance with the Income Tax Act and public rulings. Prior to the SAS regime, this responsibility was rested on IRBM's tax officers, however, under the SAS, this responsibility has shifted to taxpayers but then most taxpayers transferred it onto tax practitioners with a cost, as many taxpayers opted to engage tax practitioners with a fee to handle tax matters. Indeed, since the inception of the SAS, tax practitioners (be it tax proprietors, tax partners, tax managers or tax directors) are exposed to greater risks and burden. As expected, the survey found that respondents had the opinions that the SAS provides more benefits to the IRBM than the taxpayers (with a mean score of 4.51 and significant at p<.001) and that the SAS has actually increased taxpayers' compliance costs (mean score of 4.40 and significant at p<.001). These findings seem to support the assertions of Hansford and McKerchar (2004) as well as Vos and Mihail (2006). Notably, Hansford and McKerchar (2004) asserted that by shifting the tasks of preparing tax returns, the tax authority can minimise its overall operating costs; and the tax authority is always at the best position to exploit the tax law complexity to their benefit especially when it comes to dispute. Thus, the SAS has further benefited the UK tax authority (Hansford and Mckerchar, 2004). In line with this, Vos and Mihail (2006) also asserted that in the self-assessment regime, the cost saving benefited by the tax authority in Australia were at the expense of the taxpayers. In turn, when asked whether the SAS is implemented effectively in Malaysia, the finding as presented in Table 2 shows that majority of the respondents did not think so (the mean score was 2.60 on a 5 point scale (significant at p<.001). On top of this, at a 95% confidence level, respondents thought that the relationship between IRBM and tax practitioners has not improved since the implementation of the SAS (mean score of 2.78 and significant at p<.05). 6 MLJ cxxi at cxxix Next, the survey respondents were asked to indicate areas where they encountered difficulties when representing companies in tax compliance in the era of self-assessment. Figure 3 presents these findings.

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About 70% of the respondents indicated that it is difficult to estimate the tax payable for companies. This finding supports the assertions of Veerinderjeet and Renuka (2002) that providing tax estimates under the SAS has become very challenging, due to uncertainty in the economic conditions. Related to this, although companies are allowed to revise their tax estimates twice a year (in the sixth and/or ninth month of the basis period), about 45% of the survey respondents claimed that it is difficult to revise the estimated tax payable in the sixth and/or ninth months of the basis period. About 69% of the respondents indicated that it is difficult to interpret income tax laws and the public rulings issued by the IRBM. The survey found four key areas where tax practitioners encountered difficulties are closely related to the efficiency of the IRBM. Notably, about 64% of respondents claimed that the IRBM was slow in processing tax refunds. Nearly 63% of them indicated that tax personnel lack technical knowledge on complex matters. About 58% claimed that the IRBM tax advice is not sufficiently accessible, and 51% claimed that there were delays on IRBM's response to correspondences. In turn, the survey found that compliance with the stringent requirements set by the tax authority for companies is among the problems faced by tax practitioners. Nearly 34% of respondents indicated that 6 MLJ cxxi at cxxx there are too many deadlines to remember. About 28% of them claimed that they had difficulties in handling tax queries from the IRBM. Approximately 27% of the respondents indicated that it was difficult to meet tax filing deadlines. These problems, coupled with other problems (which occur due to some of the corporate clients who are slow and are unable to furnish the required information on time) are the common problems. Tax practitioners' overall perception of the Malaysian tax authorities today Adapting a question from Ernst and Young's 2006 annual tax survey, this study investigates tax practitioners' overall perception of the Malaysian tax authorities, in term of the tax administrative efficiency and its relationships with the taxpayers since the implementation of the SAS. Notably, 78 % of the respondents rated the Malaysian tax authorities as 'average' in term of administrative efficiency; this finding indicates that

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the Malaysian tax authorities has improved in recent years but there is still room for improvement in terms of efficiency and relationships with taxpayers. This finding supports the Ernst and Young (2006) survey, which found that about 57% of Malaysian chief executive officers (CEO) rated the Malaysian tax authorities' performance as 'average'. Under the SAS, tax officers are no longer burdened with assessment activities, hence it is reasonable to assume that more manpower and human resources can be devoted to improve service to taxpayers. However, the result shows that services provided by the Malaysian tax authorities are still far from meeting the tax practitioners' expectations, as only 1% of respondents viewed the IRBM as 'good-efficient and friendly'. Meanwhile, 8% of the tax practitioners surveyed perceived the Malaysian tax authorities as 'not good-inefficient and unfriendly'. The remaining respondents (3%) were of the opinion that the Malaysian tax authorities' efficiency has improved but it still alienates taxpayers. It is worth noting here that in the Ernst and Young (2006) survey, 23% of Malaysian CEOs also felt that the Malaysian tax authorities alienated taxpayers. SUMMARY AND CONCLUDING REMARKS This study provides some insights for the tax authorities on the difficulties faced by tax practitioners when representing corporate taxpayers in tax compliance. The main areas where tax practitioners encountered most difficulties in tax compliance for companies are mostly related to inherent weaknesses of the SAS, as well as the inefficiency and quality of tax services provided by the IRBM. Since the IRBM requires taxpayers (and their tax representatives) to submit the estimated tax payable, tax assessment and 6 MLJ cxxi at cxxxi payment on time, the IRBM should also be efficient in their internal processes, particularly in processing tax refunds and tax correspondences. Insufficient access channels for tax practitioners to obtain tax guidance and advice from the IRBM would not help the IRBM to achieve greater voluntary compliance. Moreover, the situations would deteriorate further if the IRBM is not responsive to complexities and problems faced by tax practitioners. As tax officers are no longer burdened with tax assessment workloads, therefore, it is reasonable for tax practitioners to expect and demand better tax services and guidance on tax policy matters from the IRBM. Although the SAS has been operating for more than ten years in Malaysia, there are still some inherent weaknesses in the system. The Malaysian tax authorities with its vision 'as a world-class tax administrator' and its mission 'to provide quality taxation service to increase national revenue' as well as its objective 'to create and implement a fair and effective tax management system' must take serious effort to deliver its 'quality policy' and 'The Taxpayer's Charter' as outlined in the IRBM's homepage in practice (see http://www.hasil.gov.my). The findings suggest that it is imperative for the IRBM to address issues arising in respect of the SAS and the efficiency of the IRBM in order to gain respect and confidence among tax practitioners. Some suggestions in achieving this are outlined below: (a) to enhance the content of tax authorities' website; it is suggested that they create and maintain a specific 'tax practitioners site' or 'tax agent portal' for tax practitioners to interact online with the tax authorities, just like what the 'Australian Tax Office' and 'Internal Revenue Service of the United State' have done; to appoint technically sound and dedicated tax officers to answer tax queries promptly and professionally on tax matters via the help desk, phone, fax or email; to ensure prompt response time, within ten working days for all tax correspondence; the tax authorities ought to review and update public rulings to reflect the current practice; and to have regular dialogue sessions with tax practitioners to improve industrial relation with tax practitioners.

(b) (c) (d) (e)

The study carries the merits of conducting a survey in the real world, ie, the pragmatic tax compliance setting. The purpose of this study is not to measure income tax complexity per se or its impact on compliance in the era of the SAS, but just to find out tax practitioners' experience and opinion on the SAS and their tax compliance complexities. The limitations of the study are: firstly, it 6 MLJ cxxi at cxxxii was a cross-sectional study, hence the opinions of the survey respondents might change over time; and secondly, self-report measures were used for data analysis, as such, they could be over stated. Last but not

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least, this study only analysed the responses from 208 tax practitioners that participated in the 'Budget Seminar'. Hence, care must be exercised in generalising the findings to a wider population. As scholarly study on tax practitioners and the SAS is scant; thus this paper contributes in providing empirical evidence and important insights to tax authorities and tax practitioners in business. Future studies can be conducted on a larger sample to cover more issues in order to get a clearer picture. A comparative study can also be conducted to examine tax practitioners and the SAS in the Asia Pacific region and around the world. ACKNOWLEDGMENT The earlier version of this paper was presented at the Oxford Business and Economic Conference, St Hugh's College, Oxford University, United Kingdom, on 24-26 June. The authors thank the conference participants for their comments. REFERENCES

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18.

ACCA, 2002, ACCA Members' Survey: Self-Assessment March 2002, pp 1-18. Retrieved 5 May 2003, from http://www.accaglobal.com Choong, KF and Lai, ML, 2008, Tax Audit and Tax Evasion under the SAS: Survey Evidence in Malaysia, Malayan Law Journal, March-April, pp 14-23. Erard, B, 1993, Taxation with representation: An Analysis of the Role of Tax Practitioners in Tax Compliance, Journal of Public Economics, 52, pp 163-197. Ernst and Young (Ed), 2006, Annual Tax Survey, Malaysia. Hansford, A, and Mckerchar, M, 2004, Developing the UK Self-Assessment Regime: Is Collaboration the Key, Australian Tax Forum, 19, pp 81-98. Inglis, M, 2002, Taxing Times: Is Self Assessment Working? Policy 18(3), pp 3-9. Klepper, S and Nagin, D, 1989, The Role of Tax Preparers in Tax Compliance, Policy Sciences, 22, pp 167-194. Krishnamoorthy, M 2006a, '1.3 million did not pay tax', The Star, 26 August 2006. Retrieved 5 April 2007, 2007, from http://www.thestar.com.my 6 MLJ cxxi at cxxxiii Krishnamoorthy, M, 2006b 'Defaulters rise by 10 times', The Star, 14 August 2006. Retrieved 5 April 2007, 2006, from http://www.thestar.com.my Loo, EC and Ho, JK, 2005, Competency of Malaysian Salaried Individuals in Relation to Tax Compliance under Self-Assessment, eJournal of Tax Research, 3(1), pp 45-62. Marshall, JR, Smith, M and Armstrong, RW, 1997 Self-Assessment and Tax Audit Lottery: The Australian Experience, Managerial Auditing Journal, 12(1), pp 1-8. Marshall, R, Smith, M and Armstrong, R, 2006, The impact of Audit Risk, Materiality and Severity on Ethical Decision Making: An Analysis of the Perceptions of Tax Agents in Australia, Managerial Auditing Journal, 21(5), pp 497-519. Mckerchar, M, 2005, The Impact of Income Tax Complexity on Practitioners in Australia, Australian Tax Forum: a Journal of Taxation Policy, Law and Reform, 20(4), pp 529-554. Newsberry, KJ, Reckers, PMJ and Wyndelts, RW, 1993, An Examination of Tax Practitioner Decisions: The Role of Preparer Sanction and Framing Effects Associated with Client Condition, Journal of Economic Psychology, 14(2), pp 439-452. Paddock, A and Oates, C, 2003, Corporate Tax Self-Assessment Lessons from Down Under, International Tax Review, 14(10), pp 28-30. Roth, JA, Scholz, JT, and Witte, AD, 1989, Taxpayer Compliance: An Agenda for Research, in Vol 1: University of Pennsylvania Press. Veerindeerjit, S and Renuka, B, 2002, The Malaysian SAS of Taxation: Issues and Challenges, Akauntan Nasional, January/February 2002, pp 10-15. Vos AM, D R and Mihail, T, 2006, The Importance of Certainty and Fairness in a Self-Assessing environment, Retrieved from http://www.igt .gov.au/content/media/ATAX_paper April_2006.pdf.