those living in poverty.173 Some special procedures note that regressive taxation systems constitute an inequitable financing mechanism, something not in accordance with human rights.174 Similarly, the CESCR has stressed that only redistributive and socially fair tax systems make it possible to combat inequalities.175 Furthermore, it has been stressed that tax reform that comes in the form of cuts, exemptions and waivers may disproportionately benefit society’s wealthier segments and discriminates against those living in poverty.176 It has also been suggested that direct taxes, such as personal income tax, would be more in line with principles of equality and non-discrimination than indirect taxes, such as value added (VAT) or sales taxes. The latter are often considered regressive because they generally eat into a larger proportion of the income of those living in poverty.177 For example, on her Paraguay country visit, the Special Rapporteur on extreme poverty noted that, because the country had no income tax, the government relied primarily on sales tax for revenue. This had a profoundly discriminatory impact: the poorest ten per cent of the population was paying 18 per cent of their income in VAT, while this tax represented a mere 4.6 per cent of income among the population’s richest one per cent.178 With a recognition that each country’s situation is different, it has nonetheless been noted that ‘the higher the prevalence of regressive taxes in the mix of revenue-raising sources, the more likely it is that a State will run afoul of the principles of equality and non-discrimination and that the minimum essential enjoyment of rights by the poorest will be threatened’.179 Compliance with the principle of equality and non-discrimination would also require affirmative action measures, such as well-designed subsidies or tax-exemptions in favour of individuals and groups that have suffered from historical or persistent discrimination. This compliance would also oppose flat taxes where all contributors are required to pay an equal proportion of their incomes.180 While the CRC has only rarely considered taxation questions, it did call for a progressive tax policy in its Guatemala report considerations, as well as during its 2007 ‘Day of General Discussion on Resources for the Rights of the Child’.181 173 See, eg, ‘Report of the Special Rapporteur on poverty, Magdalena Sepúlveda Carmona’ (2014) UN Doc A/HRC/26/28 and ‘Report of the Special Rapporteur on poverty, Philip Alston’ (2015) UN Doc A/HRC/29/31. See also CESCR, Concluding Observations Tunisia E/C.12/TUN/CO/3 (2016), para 15; Concluding Observations Burundi E/C.12/ BDI/CO/1 (2015), para 14; Concluding Observations Burundi E/C.12/GBR/CO/6 (2016), para 16; and Concluding Observations Uruguay CRC/C/URY/CO/2 (2007). 174 ‘Interim report of the Special Rapporteur on health, Anand Grover’ (2012) UN Doc A/67/302, para 16. See also ‘Report of the Special Rapporteur on poverty, Magdalena Sepúlveda Carmona’ (2014) UN Doc A/HRC/26/28. 175 See, eg, Concluding Observations Costa Rica E/C.12/CRI/CO/5 (2016), paras 15–16 and Concluding Observations Tunisia E/C.12/TUN/CO/3 (2016), para 15. 176 See, eg, ‘Report of the Independent Expert on poverty, Magdalena Sepúlveda Carmona’ (2011), UN Doc A/HRC/17/34, paras 50–51. 177 ‘Report of the Special Rapporteur on poverty, Magdalena Sepúlveda Carmona’ (2014) UN Doc A/HRC/26/28, para 46. 178 ‘Report of the Special Rapporteur on poverty, Magdalena Sepúlveda Carmona’, mission to Paraguay (2012) UN Doc A/ HRC/20/25/Add.2, paras 43–44. 179 ‘Report of the Special Rapporteur on poverty, Magdalena Sepúlveda Carmona’ (2014) UN Doc A/HRC/26/28, para 47. 180 ‘Report of the Special Rapporteur on poverty, Magdalena Sepúlveda Carmona’ (2014) UN Doc A/HRC/26/28, para 16. 181 Concluding Observations Guatemala CRC/C/GTM/CO/3-4 (2010) and ‘Day of general discussion on resources for the rights of the child – responsibility of States. Recommendations from the Committee on the Rights of the Child’ (21 September 2007), 46th session of the CRC. December 2017   The Obligation to Mobilise Resources: Bridging Human Rights, Sustainable Development Goals, and Economic and Fiscal Policies 53