Abstract

This paper develops a model of tax enforcement in which the tax agency is allowed to make pre-audit settlement offers to taxpayers. Settlements can either take the form of public amnesties or individual plea bargains. In this model, pre-audit settlements allow the agency to overcome its limited control over the enforcement parameters (the agency takes the tax and penalty levels as given) and to increase its net revenue. Public amnesties prove to be superior to individual plea bargains, since they allow the agency to extract from taxpayers, not only the prospective defence cost, but also the risk premium associated with the sampling procedure.