for instance, that a failure to mobilize domestic resources effectively may be excused by sound choices being made in spending. A State which would be increasing spending on social policies (for social security, food, health, education and housing), but that would be doing so relying on a highly regressive taxation policy, may be found in violation of its obligations under the Covenant. To illustrate, consider the assessment this author made in his official capacity as the Special Rapporteur on the right to food following his mission to Brazil in 2009. While praising the country for having consistently increased spending on social priority areas, the assessment added the following cautionary note93: The tax structure in Brazil remains highly regressive. Tax rates are high for goods and services and low for income and property, bringing about very inequitable outcomes. According to one estimate, families with an income amounting to less than two minimum wages pay an average of 46 per cent of their income in indirect taxes, while families earning over 30 times the minimum wage pay around 16 per cent in indirect taxes. A recent report by the Tax Services confirms the very low levels of property taxes. In particular, the rural territorial tax collected, in 2008, a mere R$ 416 million (US$ 239 million) nationwide. As a percentage of GDP, this amounts to 0.01 per cent and, as a percentage of total taxation, the tax accounts for only 0.04 per cent. Given the very high level of land concentration and the large incomes generated by the agricultural sector, this is highly regressive. In contrast, taxes on goods and services, as well as social contributions to pensions and social security accounted for the lion’s share of Government income: over 70 per cent in 2008 [see the figure below]. The Special Rapporteur concludes that, while the social programmes developed under the “Zero Hunger” strategy are impressive in scope, they are essentially funded by the very persons whom they seek to benefit, as the regressive system of taxation seriously limits the redistributive impact of the programmes. Only by introducing a tax reform that would reverse the current situation could Brazil claim to be seeking to realize the right to adequate food by taking steps to the maximum of its available resources. Government Revenue in 2008 by Source of Taxation Property 3% Other 3% Financial transactions 2% Income 21% Goods & services 48% Salaries 23% Figure 2: Government Revenue in 2008 by Source of Taxation, 2009 Mission to Brazil by the Special Rapporteur on the right to food The opposite is equally true, of course: a State that would have a highly progressive tax structure, but that would nevertheless maintain a low level of social spending, would not be acting consistent with its duties under the Covenant. Dedicating the "maximum available resources" to the realization of the rights of the Covenant means both mobilizing sufficient resources and using such resources as effectively as possible, in order to maximize the contribution of public investment to the fulfilment of economic, social and cultural rights. It may be tempting to think that a State making a smart use of its resources could be excused for maintaining a regressive tax structure or, conversely, that a State 93 Report of the Special Rapporteur on the right to food, Olivier De Schutter, to the thirteenth session of the Human Rights Council, Addendum: Mission to Brazil (12-18 October 2009) (A/HRC/13/33/Add.6), para. 36 (footnotes omitted). 21