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| TFF complexity has come at the expense of transparency, so that few people actually understand how the program works. |
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The need to simplify TFF, make the program easier to understand, and reduce the administrative burden on governments was highlighted in a number of submissions and comments. Concerns were raised that the “overall design of Territorial Formula Financing has become exceedingly complex with successive agreements and adjustments over the past 20 years.”25 This complexity has come at the expense of transparency, so that few people actually understand how TFF works.
On the other hand, the Panel was cautioned against believing that simplicity in itself should be an over-riding objective for TFF. The comparison was drawn to the tax system where “we want everyone to have a basic understanding of our tax system, but who would argue that the tax laws, regulations and rulings should only be two pages long, so that everyone can understand the internal workings.”26 In the case of TFF we could argue that there’s a long way to go before “everyone has a basic understanding” of how the program works.

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