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Review of “South Africa: Potential Revenue Losses Associated with Trade Misinvoicing”, Global Financial Integrity, November 2018

This little review seeks to explain the evolution in the methods Global Financial Integrity (GFI) uses to make trade misinvoicing estimates, and its new focus on “potential revenue losses”. GFI has taken a very one-sided approach to potential revenue losses, only counting the taxes it implies are not paid as a result of its estimates of trade misinvoicing behaviours but ignoring the extra taxes that would be paid were its estimates of trade misinvoicing accurate. The net revenue outcome would be much more balanced.