BUDGET 2002 Discussion of Tax Proposals TAX POLICY CHIEF DIRECTORATE NATIONAL TREASURY PORTFOLIO AND SELECT COMMITTEES ON FINANCE: CAPE TOWN, 26 FEBRUARY 2002 Contents • Tax Policy since 1995 to 2001 • Tax Structure – SA vis-à-vis rest of the world • 2001 outstanding tax reform measures • 2002 tax proposals • Direct tax • Indirect tax • 2001/02 outstanding technical corrections • The way forward : – Retirement fund tax review – Tax framework for banking sector Tax policy ’95 – ’01 • PIT relief - R34 billion since 1995 • • • • • • • • 1995 - R2 billion 1996 - R2 billion 1997 - R2,8 billion 1998 - R3,7 billion 1999 - R4,9 billion 2000 - R9,9 billion 2001 - R8,4 billion 2002 - R15 billion • Supporting economic activity – – – – 1997: Tax holiday scheme 1999: Corporate rate reduced to 30% 2000: Split rate for SMMEs 2001: • Strategic investment programme • Immediate expensing of investment by Small Business Corporations – Diesel fuel rebates: primary sector Tax policy ’95 – ’01, cont. • Infrastructure development – 2000: Depreciation of oil and gas pipelines; electricity and telephone transmission lines, railway lines – 2001: Depreciation of airport infrastructure • Poverty and inequality – Distribution of PIT relief – Broadening tax base • Residence-based income tax • Capital gains tax – Excise duty elimination on soft drinks – VAT zero-rating of IP – Wage subsidy turned into a learnership programme, effective 1 October 2001 TAX STRUCTURE 20 20 20 20 20 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 04 / 03 / 02 / 01 / 00 / 99 / 98 / 97 / 96 / 95 / 94 / 93 / 92 / 91 / 90 / 89 / 88 / 87 / 86 / 85 / 84 / 05 04 03 02 01 00 99 98 97 96 95 94 93 92 91 90 89 88 87 86 85 Tax mix: 1984/85 - 2004/05 100% Other 80% Stamp duty Customs Adv dom Fuel 60% Sp excise VAT Trade Taxes 40% Transfer SDL Ret funds STC 20% Companies PIT 0% Tax Mix: key features • PIT, CIT and VAT account for about 80% of total tax revenue • Almost 97% if fuel levy and specific excises are included • PIT contributed between 29,5% (1988/89) and 42,8% (1999/00) • CIT contributed between 17,1% (!983/84) and 10,5% (1994/95), 1999/00 = 13,4% • Gold mining contributed 8,9% in 1983/84 and 0,1% in 1998/99. Tax Mix: key features 2 • Fuel levy: currently generate about 7% of total tax revenue (from 1% in early - mid 1980’s) • Specific excise taxes: 8,7% in 1983/84 – has dropped to 4,1% in 2000/01 • Trade taxes: 8,6% in 1988/89 – has dropped to 3,7% in 2000/01 19 84 19 /85 85 19 /86 86 19 /87 87 19 /88 88 19 /89 89 19 /90 90 19 /91 91 19 /92 92 19 /93 93 19 /94 94 19 /95 95 19 /96 96 19 /97 97 19 /98 98 19 /99 99 20 /00 00 /0 1 SA’s Tax - GDP ratio 26% 25% 24% 23% 22% 21% 20% 19% 18% PRELIMINARY OUTCOME & FISCAL FRAMEWORK 2000/01 preliminary outcome • Headline trends: – – – – PIT income up by R878 million Corp tax up by R14 billion STC up by R2,5 billion VAT revenue shortfall of R1,75 billion Summary of proposals 2002/03 R million Effect of Tax proposals Revenue Revenue Estimate of revenue before tax proposals 280,382 Tax proposals Direct tax proposals Personal income tax: Adjust personal income tax rate structure Administrative changes Adjustments to deductions Taxation of trusts at a flat rate of 40 per cent -15,824 -14,855 -15,000 -50 105 90 Corporate income tax: Accelerated depreciation allowances Extend small business corporations tax relief -335 -295 -40 Financial transaction taxes: Exempt certain warrant repurchases from MST and UST Remove stamp duties on certain financial instruments Withdraw levy on Lloyd's insurance premiums Adjust transfer duty rate structure -430 -80 -35 -15 -300 Increase monetary thresholds: -204 Indirect tax proposals Specific excise taxes: Net Impact - Increase in duties on alcoholic beverages - Increase in excise duties on tobacco products (50% incidence) - Remove duties on soft drinks (-6c/l) 659 663 355 443 -135 Extend fuel rebate for offshore vessels Estimate of revenue after tax proposals -4 265,217 DIRECT TAX MEASURES 2002 key features - individuals • R15 billion PIT relief • Interest and dividend income exemption • Transfer duty – R300 million • Taxation of deemed foreign income • Taxation of trusts • Amendment of monetary thresholds and miscellaneous PIT provisions 2002 key features - corporations • Accelerated depreciation for new manufacturing assets • Tax relief for small business • Taxation of trusts – flat 40% rate • Further tax reform: – Taxation of retirement industry – Taxation of banking sector PIT rates and brackets 2001/02 2002/03 Taxable incom e (R) Rates of tax Taxable incom e (R) Rates of tax 0 – 38 000 18% of each R1 0 – 40 000 18% of each R1 38 001 – 55 000 R6 840 + 26% of the amount 40 001 – 80 000 R7 200 + 25% of the amount above R38 000 55 001 – 80 000 R11 260 + 32% of the amount above R40 000 80 001 – 110 000 above R55 000 80 001 – 100 000 R19 260 + 37% of the amount above R80 000 110 001 – 170 000 above R80 000 100 001 – 215 000 R26 660 + 40% of the amount R72 660 + 42% of the amount 170 001 – 240 000 R47 200 + 38% of the amount above R170 000 240 001 and above above R215 000 Rebates R26 200 + 35% of the amount above R110 000 above R100 000 215 001 and above R17 200 + 30% of the amount R73 800 + 40% of the amount above R240 000 Rebates Primary R4 140 Primary R4 860 Secondary R3 000 Secondary R3 000 Tax threshold Tax threshold Below age 65 R23 000 Below age 65 R27 000 Age 65 and over R39 154 Age 65 and over R42 640 PIT relief • • • • • Primary threshold up R4 000 (up 17,4%) to R27 000 Secondary threshold up by R to 3 486 to R42 640 (up 8,9%) Maintain progressivity Significant cuts for all taxpayers Average rate cuts skewed toward lower/middle income groups INCOME GROUP PER CENT OF R15 BILLION <R150 000 57% PER CENT TAX REDUCTION 25% R150 000 – R300 000 37% 14% >R300 000 6% 7% Transfer duty relief 8.0 Old rates New rates 7.0 • R300 million relief • Rates cut at all property values Average rate 6.0 Proposed rates: 5.0 4.0 3.0 2.0 • R0 – R100 000 …… 0% Property value (R 000) 1,250 850 8% 650 …. 450 • R300 001 and above 0.0 250 • R100 001 – R300 000 …… 5% 50 1.0 Other individual tax changes • Domestic interest and dividend income exemption raised – R6 000 under 65 – R10 000, age 65 and over – R1 000 limit on exemption of foreign source income • Monetary thresholds: – Bravery and long service awards – Donations tax up to R30 000 & estate duty up to R1,5 million – Bursaries and scholarships – Medical aid deductions Other individual changes 2 • Limit employee deductions – – – – – – Business travel deduction against car allowance Certain medical expenses Contributions to pension and retirement annuity funds Donations to certain public benefit organisations Specific expenditure against allowances of holders of public office Wear and tear allowances on equipment. • Taxation of deemed foreign income • Eliminate deemed accommodation costs in subsistence allowance • Occasional free services – R500 fringe benefit • Administrative reforms – Single year for all taxpayers – Raising provisional threshold limits – Reviewing SITE Company tax changes 1 • Accelerated depreciation – 3 years – 40% of cost in year 1 – 20% a year for subsequent 3 years • Focus on building manufacturing base • Stimulate investment and create jobs • Small business tax relief: – 15% tax on first R150 000 of taxable income – Limit on small business corporation turnover raised to R3 million – Reduce administrative burden • Immediate expensing: – Manufacturing assets – cost R2 000 – Intellectural property – cost R5 000 • Trusts: 40% tax rate Ongoing tax reform • Taxation of banking sector – Announced in 2001 Budget – Questionnaire highlights sources of reduced tax rates – Better enforcement and compliance – R792 million – Further review in 2002/03: • Taxation of financial derivative instruments • Taxation of financial leases • Taxation of retirement industry – Holistic review during 2002 – Issues paper to be tabled for discussion shortly INDIRECT TAX MEASURES 2002 key features - indirect taxes • Excises duties: – Alcoholic beverages: 8 – 10% – Tobacco: 10,7% - 43,7% • • • • • • • Air passenger tax: no change General fuel levy: no change (RAF: 2c a litre) Extend diesel fuel tax concession Fuel tax regime for environmentally friendly fuel Remove Lloyd’s tax MST/ UST on warrant repurchases Stamp duties FUEL LEVY • No increase in General Fuel Levy • Intended to help limit inflationary impact of significant devaluation of Rand during December 2001 • Road Accident Fund Levy to be increased by 2 cents per litre • Renewable, environmentally friendly diesel fuel (e.g. Biodiesel ) to be taxed at 70% of General Fuel Levy • In addition, such diesel fuels (e.g. Biodiesel) used in certain primary production processes will qualify for diesel fuel levy concession TOBACCO PRODUCTS • 50.0 per cent total tax incidence (Excise + VAT) to be maintained • Average increase of 12.% ( Cigarettes at 10.7%) Other charges and levies • Remove Lloyd’s insurance premium levy • MST and UST on warrants: – Warrants are retail derivative instruments – Account for 20% of JSE trades – To ensure equity, remove MST/UST on repurchase of warrants issued by market maker • Stamp duties, remove: – – – – Listed debt instruments (UST as well) Cession of mortgage bonds Insurance policies against accident, bodily injury, incapacity or sickness Insurance contracts referred to in the Export Credit and Foreign Investments Reinsurance Act, 1957 – Cession of insurance policies. TECHNICAL CORRECTIONS ON CGT & RESIDENCE-BASED INCOME TAX Technical corrections: CGT and residence-based IT • No relief for financial instrument companies • Trade debts in financial instrument definition • Designated country exception – review of list • Foreign asset reporting – deemed inclusion • Foreign currency regulations – individuals • Outbound restructurings – STC technical correction on liquidation – Unbundling – 5% rule • Interpretative guideline Key Tax Proposals • • • • • • • • R15 billion PIT relief Major interest income exemption Accelerated depreciation for manufacturing SMMEs threshold adjustments Transfer duty relief of R300 million No general fuel levy increase Discounted general fuel levy on biodiesel Reduction of financial transaction taxes