1) They focus more on potential revenue loss (from trade tariffs, VAT and CIT) rather than capital flight, acknowledging that the calculations show apparent flows in both directions
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GFI's recent reports on trade misinvoicing from Nigeria and Kenya are interesting (and i think a significant methodological improvement) https://www.gfintegrity.org/report/nigeria-potential-revenue-losses-associated-with-trade-misinvoicing/ … https://www.gfintegrity.org/wp-content/uploads/2018/10/GFI-Kenya-Potential-Revenue-Losses-Associated-with-Trade-Misinvoicing.pdf … (this thread focuses on the Kenya report)pic.twitter.com/uS2nnisHW5
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(although... I'm not sure how the VAT calculation works? If you evade import VAT unless the importer is the final consumer someone still pays the VAT?... also why does import overinvoicing reduce CIT, but import underinvoicing does not increase it?)
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2) They are based on detailed COMTRADE data - commodity by commodity and using import-export country pairs, rather than balance of payments.
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This allows the data problem of transit trade to be isolated and removed from the data (these are problems i've written about before https://hiyamaya.wordpress.com/2016/07/20/misinvoicing-or-misunderstanding/ …). GFI calls these 'lost' and 'orphaned' trades
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3) They look at individual pairs of data and consider whether the mismatch is plausible -- implausibly large mismatches in volumes more likely due to reporting error than misinvoicing are down-weighted.pic.twitter.com/ghWXnuo94Y
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4) They break the results down by commodity and by trade partner, so you can see the story the data is telling. In Kenya, the big numbers relate to imports of worn clothing, cereals, electrical equipment, vehicles and fuel.pic.twitter.com/1qxXSLIOy4
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But, as they highlight, these are not the commodities with big apparent misinvoicing price gaps.pic.twitter.com/5t53kEmhTQ
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Similarly the countries that are the biggest contributors to the absolute numbers - China, India, Pakistan, UK do not necessarily have the biggest apparent misinvoicing gaps (apart from Pakistan)pic.twitter.com/Cj1D8azVuH
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5) There is a whole discussion about transport & insurance markups -- should it be 14%, 10%, 6% ? GFI use a model which takes into account different products, countries etc.. which averages at 9% for Kenya
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Many of the major areas of apparent misinvoicing (vehicles, electrical equipment, fuel) are underinvoiced by 1-3% ..... this seems like it could be within the range of uncertainty about transport costs
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Used clothing and cereals have larger misinvoicing margins. There is a nifty graphic which shows absolute and relative size of the apparent tariff losses by product and countrypic.twitter.com/AW3Yd3laZ1
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This seems to me like a useful risk assessment tool. These are specific red flags to follow up on. Are there innocent explanations for the patterns in the data or is there something dodgy in these specific trades? (like whats up with used clothing exports from UK to Kenya?)
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I'd like to see what the potential losses in different categories look like with different modelling assumptions on the transport costs -- how robust are they? But all in all a lot of improvement in the methodology.
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Its not quite so clear in the Nigeria case - again they focus detailed analysis on import underinvoicing (absolute numbers driven by small margins on large volumes of vehicle imports). But import underinvoicing is not the biggest category in Nigeria...what is the export story?pic.twitter.com/t2gX52TCWc
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Kudos to
@GFI_Tweets for working to address the methodological issues and improve the estimates (they could publish the underlying data and calculations too!)Show this thread
End of conversation
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