Following a period of economic softening, and in light of the government's ambitious spending and infrastructure plans, the government has been ramping up its efforts to improve tax collections. As with previous efforts to do so, the government has demonstrated a relatively joined-up approach to tax collection. Within the MEMR officials have introduced a system of prior tax compliance validation for certain licenses and approvals (e.g., to obtain a business license and to approve a transfer). They have also introduced relatively onerous disclosure requirements in relation to applicants' beneficial owners.
The MEMR began implementing tax compliance validation in late 2015 based on Decree No. 4458K/84/MEM/2015. However, the disclosure of information on beneficial ownership was not formally implemented in the mining sector until early 2018, following the issuance of a circular letter by the Director General of Mineral and Coal (DGMC) in late 2017.
The introduction of these requirements resulted in significant delays in license and approval processes.