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J ournal of Modern Accounting and Auditing, ISSN 1548-6583

October 2011, Vol. 7, No. 10, 1051-1059



A Feasibility Study on the Implementation of External
Tax Audit in Malaysia


Sellywati Mohd Faizal, Zakiah Muhammaddun Mohamed
Universiti Kebangsaan Malaysia, Malaysia

Norsiah Ahmad

Universiti Malaysia Terengganu, Malaysia

This study examines the feasibility of external tax audit implementation in Malaysia. External tax audit has been
purported to enhance tax administration efficiency, deter tax evasion and noncompliance as well as improve tax
collection for a nation. Therefore, this study solicits perceptions from various stakeholders on the new service while
retaining the principle of justice that lies in the tax system. External tax audit refers to the process of business
income tax returns being attested by other than the tax authority. External tax audit has been implemented
successfully to increase tax compliance in some areas such as Taiwan, Bangladesh and United States of America.
Therefore, this study examines the benefits and risks influencing the implementation of external tax audit in
Malaysia from the viewpoints of corporate taxpayers and tax agents. Data is obtained through questionnaire from
the selected respondents. Findings from multiple regression analysis reveal that tax agents and taxpayers agree with
the implementation of this new service. For tax agents, the external tax audit has benefits and risks, while taxpayers
believe that only benefits influence their agreement to the external tax audit. This study contributes to the tax
literature by providing knowledge on the feasibility of external tax audit implementation in Malaysia.
external tax audit, corporate taxpayers, tax compliance
Introduction
Malaysias income mostly depends on the tax revenue in sustaining the economic stability and
development. Economic Planning Unit in 2009 reports that the tax revenue is the main source to the Malaysia
income especially contributed by the collection of direct taxes. Further, Annual Report of Inland Revenue
Board Malaysia [IRBM] signifies that in 2006 revenue generated from direct taxes was RM 65.74 million. This
figure was 54.5% of the total federal government revenue. In 2007, this figure increases to RM 74.70 million;
however, it only contributed to 52.7% of the federal direct taxes. From the total amounts of the direct taxes, the


Acknowledgements: The authors gratefully acknowledge Universiti Kebangsaan Malaysia for granting financial support to this
project under the research grant UKM-GUP-J KKBG-08-03-008.
Sellywati Mohd Faizal, researcher, School of Accounting, Faculty of Economics and Management, Universiti Kebangsaan
Malaysia.
Zakiah Muhammaddun Mohamed, Ph.D., lecturer, School of Accounting, Faculty of Economics and Management, Universiti
Kebangsaan Malaysia.
Norsiah Ahmad, Ph.D., associate professor, School of Accounting and Finance, Faculty of Management and Economics,
Universiti Malaysia Terengganu.
Correspondence concerning this paper should be emailed to Norsiah Ahmad: norsiah@umt.edu.my.
A FEASIBILITY STUDY ON THE IMPLEMENTATION OF EXTERNAL TAX AUDIT

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main contributor comes from corporate taxes. This percentage shows the importance of corporate taxes in
contributing to the Malaysia tax revenue.
In order to maintain this performance, tax audit becomes a core activity of IRBM to enhance voluntary
compliance among taxpayers. IRBM is trying to enhance tax compliance through tax audit so that taxpayers
either individuals or corporate will not escape from paying their taxes. The main objective of tax audit is to
encourage taxpayers voluntarily report the true tax liabilities in accordance to the tax laws. It is also an
approach to educate and expose taxpayers towards their responsibilities and obligations as stated in Income Tax
Act (ITA) 1967.
Although tax audit become the main objective of IRBM, unfortunately, in IRBMs Annual Report 2005
shows that some of the selected audit cases could not be resolved. For example, in 2004, 6,439 audit cases are
being selected and only 4,657 are resolved. Meanwhile, in 2005, 9,405 are being selected and 7,204 are
resolved. From the audit performs on corporate taxpayers, only 0.89% of the number is being audited and
resolved in 2004, 1.41% in 2005 and 1.57% in 2006 (IRBM, 2006)
1
.
This statistic reveals the current practice of tax audit is not sufficient to solve audit cases and tax
administration problems because it could only be performed on a small numbers of taxpayers. If that happened,
the tax revenue collection to the country will be affected. In addition, the problem on tax audit also arises after
self assessment system (SAS) was introduced in 2001 for corporate taxpayers which require sufficient and
competent tax audit officers. The lack of tax audit officers will affect the aim to audit all taxpayers (Pertubuhan
Berita Nasional Malaysia, 2006). However, IRBM has to bear high administration cost in terms of audit cost if
they intend to audit all taxpayers (Kamdar, 1997). Something needs to be done to enhance the current practice
of tax audit by introducing a new approach which is external tax audit (ETA). Previous research has
acknowledged the effectiveness of ETA by providing evidence on higher tax compliance in countries where
ETA is mandated (Lin, 2000; Sen & Bala, 2002).
ETA refers to the process of business income tax returns being attested by other party than the tax
authority such as chartered public accountants (CPAs) or tax agents (Lin, 2000). ETA can also be defined as the
special audit carried out by other party outside the tax authority such as accountant firms to assess tax returns.
Some of the areas such as Taiwan, Bangladesh and United States of America (USA) use ETA to improve their
tax administration for the purposes to increase tax collection, reduce the workload of the tax authorities, curb
tax evasions and others.
However, ETA will not deny and abolish the roles of tax authority in performing tax audit. The tax
authority will have to perform audit on the selected taxpayers even after the external tax auditors attesting those
tax returns (Lin, 2000). ETA differs from the tax audit is currently practicing widely by many countries. Tax
audit is the extension of the normal audit process that gives true and fair view on the financial statement (Sen &
Bala, 2002). Tax audit is internally conducted by the tax audit officer.
ETA is yet to be executed in Malaysia, therefore there is reformation in Malaysias current tax system if
Malaysia intends to introduce ETA. As a party that is being imposed taxation and a party who will be appointed
to handle ETA, taxpayers and tax agents opinion and responds about ETA must be taken into consideration.
Does the introducing of ETA give benefits or risks to them? Would the additional revenue be raised by

1
The percentages are calculated from the number of companies audited and resolved divided by the number corporate tax returns
to IRBM in the respective years. The actual number of cases audited may be higher since the IRBM Annual Report only publishes
the number of cases audited and resolved.
A FEASIBILITY STUDY ON THE IMPLEMENTATION OF EXTERNAL TAX AUDIT

1053
introducing ETA? All these questions can be answered by those respondents. Therefore, the main objective of
this study is to seek views and opinion of taxpayers and tax agents on a feasibility of ETA in Malaysia by
identifying the benefits and risks influencing its implementation. The findings of this study provide implications
as to whether taxpayers and tax agents are willing to consider adopting this new practice of tax audit.
The paper is organized as follows. The next part briefly reviews prior studies on tax audit in Malaysia and
ETA. Conceptual framework and hypotheses development are explained next and followed by the methodology
section. The next section discusses the findings and finally, the paper presents its conclusion.
Literature Review
Tax Audit in Malaysia
Tax audit refers to the practice of monitoring and enforcing the social contract between public and
government (Pentland & Carlile, 1996). Tax audit is the extension of the normal audit process that gives true
and fair view on the financial statement (Sen & Bala, 2002). In Malaysia, IRBM has produced the Audit
Framework to be used as a guide to the tax officers carry out their tasks efficiently and effectively. In that
framework, tax audit is defined as a checking process of business records and affairs that relates to taxpayers
financial condition in order to avoid any misreporting of their incomes. Moreover, tax audit also is performed
to encourage taxpayers declaring the true taxable income and paying the right amounts in accordance with tax
laws and regulation. Every time the officers receive tax returns from taxpayers, they have responsibilities to
ensure taxpayers have complied with all rules and regulation stated under ITA 1967. For that reason, a sample
of taxpayers will be selected to be audited in order to deter any evasion and noncompliance (IRBM, 2009).
There are two types of tax audit namely desk audit and field audit carried out by IRBM. Desk audit is held
at IRBMs office. It is normally concerned with straightforward issues and tax adjustments. Taxpayers will be
called to IRBMs office for an interview to get further information. Meanwhile, field audit is taken placed at a
taxpayers premise that involves the examination of business records. A taxpayer will be informed prior to a
field audit. A field audit however is different from ETA. A field audit is carried out by IRBMs tax officers
whereas ETA is performed by external party than IRB such as accountant firms and tax agents.
The Relationship Between Tax Audit and Tax Compliance
Prior studies have recognized the tax audit as a medium to enhance tax compliance and to deter tax
evasion. By using cross sectional data from 1977 to 1985, Dubin and Wilde (1990) approved that tax rate and
audit rate have significantly deterrence effects on noncompliance. According to Beck, Davis, and J ung (1991),
tax compliance improve when penalty rate and probability audited increase, but no tax rate effect on tax
compliance. Kamdar (1997) in his study using time series analysis found that tax audit rate has a positive and
significant relation with compliance.
Collins and Plumlee (1991), on the other hand, studied the effect of tax schemes on reported income. Tax
schemes comprise random selection, cut off and conditional schemes. If cut off and conditional schemes were
used, noncompliance which encompasses underreporting of income will go down as compared to random
method. It indirectly suggests that tax audit can reduce underreported income notwithstanding the schemes used.
The findings from other researchers such as Alm, J ackson, and McKnee (1992) also revealed that taxpayers
will report high taxable income with aggressive tax audit and penalty. In contrast, Bergman and Nevarezs
(2006) study on taxpayers in Argentina and Chile revealed findings that is inconsistent from previous studies in
A FEASIBILITY STUDY ON THE IMPLEMENTATION OF EXTERNAL TAX AUDIT

1054
which on average tax audit do not enhance compliance. In fact, taxpayers who have never been audited comply
more after the enforcement than those who have been audited in prior years.
External Tax Audit
ETA refers to the process of business income tax returns being attested by other party than the tax
authority such as chartered public accountants (CPAs) or tax agents (Lin, 2000). This definition is premised on
similar concept as outsourcing since it involves a third party external to the organization. Lee (2001) defined
outsourcing as the process of turning over part or all of an organizations functions to external service
provider(s). The process is done to acquire economic, technological, and strategic advantages. Schniederjans
and Zuckweiler (2004) explained outsourcing as a reallocation of service from one location to another.
Outsourcing can also be referred as a service requiring a contract with external party (Sanders, Locke, Moore,
& Autry, 2007) to provide products or services that could also be provided internally (Carey, Subramaniam, &
Karin, 2006) that can give mutual benefits to the organization and the outsourced company (J umah & Wood,
1999). Hence, we can conclude that ETA is an outsourcing process in which the tax audit service performed by
external auditor and benefits IRB and the taxpayers.
In ETA, companies as taxpayers entrust CPAs or tax agents to attest before filing the tax returns to the tax
authority. In preparing the attested tax return, the external tax auditors must examine and check the accounting
records and documents to determine and make adjustments to the taxable income figures and attach the tax
return attestation report to the tax authority. If the attested tax return is selected as a part of auditing process, tax
authority will ask the external tax auditor to provide documents such as the attestation worksheets and the
companys accounting records (Lin, 2000).
Only a few countries around the world are currently adopting ETA in their tax system. These areas include
Taiwan, Bangladesh and selected states in USA. These countries administered ETA to improve their tax
administration. For instance, ETA was introduced in Bangladesh in 1990s after having experience on poor
performance of tax administration that brought to low tax returns and reduce countrys tax revenue (Sen & Bala,
2002). The decision to use ETA positively gave impact to Bangladeshs tax administration and tax compliance.
Similarly, tax authority in Taiwan implements ETA to ensure companies compute and file true and fair
corporate tax returns in accordance to the countrys tax laws. Reports on the attested tax returns then will be
submitted to the tax authority. As an encouragement, Taiwan government provides various incentives for those
companies which submit their tax returns to the CPA (Lin, 2000). Lin (2000) studied incidences of tax evasion
among CPA attested business income tax returns versus non-attested returns (ordinary returns) and reveals that
companies with attested tax returns have lower tax evasion rate when compared to companies which submitted
unattested tax returns. This finding indicates that the tax attestation service assists taxpayers to fulfill their
obligations and reduce the workload of the tax authority. Meanwhile, in USA, external tax auditors have been
appointed to audit sales tax in Florida and Texas. Companies in these two states entrusted CPAs to audit their
sales tax compliance and this process successfully enhances the sales tax compliance (Cameron, Chambers, &
Mccoy, 2003).
Conceptual Framework and Hypotheses Development
The study is premised on outsourcing literature since it involves an outsourcing arrangement whereby a
third party is introduced to the relationship between taxpayers and the tax authority. Various factors including
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1055
benefits and risks of outsourcing need to be considered before adopting this new service. This is important to
ensure proper implementation of the new service.
Cost saving is the main reason an organization chooses to use outsourcing service for their activity (Corbett,
2004). For example, tax authorities in USA appoint private tax collection agency service to collect tax return on
behalf of government in order to overcome high collection costs after the government suffers lost from that
activity (Braunchli, 2008). Meanwhile, expertise, experience, and qualification offered by external auditor
encourage most organization to use external auditor to operate their internal audit (Carey et al., 2006).
Outsourcing of tax audit activity is also able to give benefit to the interested parties in term of job opportunity to
accountant firms or tax agent to be competitive in the market to grab opportunity to provide audit services
(Cameron et al., 2003). According to Lin (2000), ETA implementation has given benefit to taxpayers by helping
them to fulfill their responsibilities. Apart from that, external auditor becomes a representative of taxpayers to
transact and deal with the authorities. It can save time and prevent pressure and problems when dealing with the
tax authorities. As such, benefits have been identified becoming a consideration to most organizations to use
outsourcing services. This study expects that benefits derived from ETA will give rise to a favorable opinion of
ETA to be exercised in Malaysia. Therefore, the hypotheses H1a H1b are developed as follows:
H1a: There is a positive relationship between benefits of ETA with a favorable opinion on implementation
of ETA for tax agent;
H1b: There is a positive relationship between benefits of ETA with a favorable opinion on implementation
of ETA for taxpayer.
Although ETA seems to give benefit to interested parties, Lin (2000) suggested that several issues would
have to be considered in term of additional cost to the external tax auditor and taxpayers. External tax auditors
appointment cost is part of compliance cost that needs to be borne by taxpayers (Lin, 2000). However, high
compliance cost leads to increase in tax evasion and noncompliance. Besides that, the exposure of customer
confidential information to outside parties is one of the risks arising from the arrangement. Some customers or
organizations refuse to give their information to outside parties (Robertson et al., 2004). Integrity also becomes
an issue in which an external party carried out audit work may not be independent because they may be
influenced by management thus affecting the quality of the audit (DeAngelo, 1981). As such, risk has been
identified as an obstacle on the implementation of ETA. Therefore, the hypotheses H2a and H2b are developed
as follows:
H2a: There is a negative relationship between risks of ETA with a favorable opinion on implementation
ETA for tax agent;
H2b: There is a negative relationship between risks of ETA with a favorable opinion on implementation
ETA for taxpayer.
Research Method
ETA is yet to be performed in Malaysia, thus this study will be an exploratory in nature to determine the
feasibility of ETA implementation. Information for this study was gathered using questionnaire survey. In an
effort to get opinions and responses on ETA in Malaysia, two groups of respondents are selected which are tax
agents and corporate taxpayers comprising small-medium enterprises (SMEs). The number of samples selected
is determined by looking at the Krejcie and Morgan (1970) table as suggested by Sekaran (2006). Two different
sets of questionnaires were sent to 265 tax agents and 285 SMEs using enumerators.
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The independent variables used for this research are benefits and risks of ETA for both respondents.
Benefits for tax agents are measured based on eight statements in the questionnaire and for companies nine
statements need to be answered. Meanwhile, four statements on risks are given to be answered by tax agents
and five statements for companies.
The dependent variable for this research is opinion on ETA implementation. Both groups of respondents
were required to answer the statements related to this variable. Five statements have to be answered by SMEs
and eight statements will be answered by tax agents.
Research Model
The empirical model used for this research to test hypotheses is as follow:
= + + + (1)
where:
=Opinion on ETA implementation;
=Benefits;
=Risks;
=Constant;

=Regression coefficient variable ;

=Regression coefficient variable ;

=Error.
Empirical Results and Discussion
In total, 75 of 265 tax agents (28.30%) and 30 of 285 companies (10.5%) returned the questionnaires. The
small rate is reasonable and normal comparable to the other taxation researching Malaysia using SMEs as
respondents (e.g., 9% in Slemrod and Venkatesh (2002), 16% in Hijattulah and Pope (2008)). Since the rate is
low then response bias test is implemented to ensure there is no difference between the late response and the
early response. This is to avoid using the late response bias (Babbie, 2010) that will influence the result. T-test
is used to compare mean score of two different groups (Tabachnick & Fidell, 2007). For tax agents the result
presents no significant difference between early response and late response for all the variables: dependent
variable ( =-1.527, =0.145), benefits ( =1.837, =0.079) and risks ( =1.348, =0.193). Similarly, for
SMEs no significant difference is noted for all the variables: dependent variable ( =-1.133, =0.267), benefits
( =-0.314, =0.756), risks ( =0.595, =0.556). Thus, all answers given by respondents are usable for
further analysis.
Respondents Characteristics
Tax agents. Respondents working with firms that operated for more than 10 years (44%) are the most
number of respondents participated in this study, followed by respondents who are working with firms operated
between 6 to 10 years (33.3%) and respondents who worked with firms that are less than 5 years (22.7%).
While, majority of tax agents have working experience exceeding 10 years (46.7%), 6 to 10 years (38.7%) and
1 to 5 years (14.7%). Additionally, 62.7% tax agents are working in small sized firm with the number of
personnel less than 10 persons and only 1.3% respondents are working with firms that have personnel more
than 50 persons. At the same time, the most tax agents who answered the questionnaires consist of those who
are working in firms that have only one partner whether audit partner or tax partner.
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Moreover, most respondents are affiliates to more than one professional body whereby Malaysian Institute
of Accountants is the professional body that has highest number of members participated in this research (51
persons), followed by Chartered Taxation Institute of Malaysia (43 persons), Association of Certified
Accountants (30 persons), Malaysian Association of Tax Accountants (19 persons), Malaysian Institute of
Certified Public Accountants and Chartered Institute of Management Accountants (six persons), Institute of
Chartered Secretaries and Administrators (four persons) and only one person has membership in Certified
Public Accountant Australia. Tax agents participated in this study consist of those working in firm which offers
various services such as tax field (96.0%), advisory service (61.3%), assurance (52.0%) and other services such
as auditing, accounting, and secretarial work (18.6%).
Taxpayers. For taxpayers group, 50% of SMEs participated in this study are parent companies while 50%
are subsidiaries to parent company listed in Bursa Malaysia. Twenty-one of SMEs sampled (70.0%) are having
annual sales exceeding RM 10 million and five companies (16.7%) with sales value between RM one million
until RM 10 million while the rests have sales less than RM one million. Majority of the SMEs, 26 companies
(70.0%) have paid-up capital exceeding RM 10 million while 86.7% of SMEs sampled have between 51-150
employees. Next, number of SMEs with the experience of being tax audited by IRBM is low compared to
SMEs which have never been audited namely 13 companies (43.3%). There are also SMEs which not only have
been imposed with desk and field audit but also with tax investigation included in the sample. These SMEs
have been audited in the 1990s, 2001, 2006, 2007, 2008 and 2009. The breakdown on industry for the SMEs
participated in this study is as follows: 53.3% in manufacturing industry, 10.0% in agriculture industry, trade
and communication, 6.7% in transport, construction and information technology, and only 3.3% in finance,
information technology, oil and gas, real estate investment trust, retailing and stock exchange.
Descriptive Statistics
Findings from descriptive analysis show that tax agents agree that Malaysia tax authority should reform
the tax system by introducing ETA with min score =3.65 (Table 1). However, the tax agents perceptions differ
from taxpayers perception in which the later are less agreeable on the implementation of ETA in Malaysia
with min score =2.81. For perceptions on benefits and risk, both groups of respondents agree that ETA has
benefits but and risks associated with its implementation with mean score for benefits =3.64 and 3.45; mean
score for risks =3.53 and 3.78.

Table 1
Variables
Tax agents
Taxpayers
Mean Standard deviation Mean Standard deviation
Feasibility 3.65 0.503 2.81 0.842
Benefits 3.64 0.540 3.45 0.858
Risks 3.53 0.752 3.78 0.697

Hypotheses Testing
This study uses multiple regressions to test the hypotheses. The results show that hypotheses 1a and 1b are
supported in which there is positive relationship between benefits of ETA and their opinion of ETA for both
respondents groups. The results suggest that the more benefits gained by the respondents, the favorable their
A FEASIBILITY STUDY ON THE IMPLEMENTATION OF EXTERNAL TAX AUDIT

1058
opinion of ETA. In contrast, hypotheses 2 are not supported for both groups of respondents in which for tax
agent, risks have positive and significant relationship with a feasibility of ETA, whilst for taxpayers, risks have
an insignificant positive relationship with their opinion on ETA implementation (see Table 2).
From the results we can conclude that tax agents are willing to accept the implementation of ETA
regardless of the benefits and risks of the arrangement. Similarly, taxpayers agree to accept the implementation
of ETA because of the benefits that they could gain from the arrangements.

Table 2
Variables
Tax agents
Taxpayers
Sig. Sig.
Benefits ( ) 0.422 0.000
*
0.814 0.000
*

Risks ( ) 0.284 0.006
*
0.037 0.744

for tax agents =0.550; for taxpayers =0.812;
*
Significant at 0.05.
Conclusions
The aim of this study is to seek opinion and perception from tax agents and taxpayers on possible ETA
implementation in Malaysia. ETA is considered as an alternative for IRBM in reducing tax evasion and
noncompliance. The finding from the questionnaire indicates that tax agents and taxpayers believe that it is
feasible to implement ETA in Malaysia recognizing the benefits that could be gained from it. For tax agents,
they believe that while ETA has benefits and risks but they hold favorable opinion on ETA implementation in
Malaysia. This is justifiable considering the new service would generate income to their practice. Meanwhile,
for corporate taxpayers, ETA is acceptable for the benefits. Therefore, it can be concluded that the idea to
implement ETA cannot be simply rejected and should be opened for further discussion. Both the respondents
groups in this study represent two major stakeholders in ETA implementation, and thus carry weight in the
decision on whether to implement ETA.
This study however has its limitations. The low response rate particularly for the taxpayers group may
prevent findings from this study to be generalized to the population of taxpayers in Malaysia. Another
limitation is the lack of reference related to ETA resulting in the researchers unable to deeply understand the
practice of ETA and rely on other literature such as outsourcing literature. Future research on feasibility of ETA
implementation should be conducted incorporating the views of the tax authorities and corporate taxpayers
from the large private companies or public listed companies to obtain a more complete view on the matter.
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