― i ―
CONTENTS
Page | |
List of Tables | xv |
Preface | xvii |
1. THE NEED FOR TAX REFORM | 1 |
I. Reasons for a Review | 1 |
II. Committee's Approach | 3 |
2. THE AUSTRALIAN TAX SYSTEM IN PERSPECTIVE | 5 |
I. Historical Perspective | 5 |
II. International Perspective | 8 |
3. CRITERIA FOR TAX SYSTEMS | 11 |
I. Terms of Reference and their Interpretation | 11 |
Fairness | 12 |
Simplicity | 15 |
Efficiency | 16 |
Other Objectives | 17 |
II. Appraisal of Particular Taxes | 17 |
Personal Income Tax | 17 |
Company Income Tax | 18 |
Capital Gains Taxes | 18 |
Estate and Gift Duties | 19 |
Wealth Taxes | 19 |
Taxes on Goods and Services | 19 |
Narrow Based Taxes | 19 |
Broad Based Taxes | 19 |
Grants | 20 |
III. Alternative Tax Systems | 20 |
4. THE POSITION OF PROGRESSIVITY | 23 |
I. The Statistical Situation | 24 |
II. Tax and Non-tax Policies in Redistribution | 29 |
III. The Distributional Objective | 32 |
5. THE GOALS OF TAX REFORM | 35 |
I. The Options | 35 |
II. Immediate and Long-term Perspectives | 37 |
6. INFLATION AND TAX REFORM | 39 |
I. Taxes and Inflation Control | 40 |
II. Effects of Inflation on Taxes | 47 |
Tax Payments | 48 |
Tax Drift | 48 |
Total Tax Receipts | 48 |
Tax Mix | 48 |
Income Tax Rates | 49 |
Concessional Allowances | 53 |
Estate and Gift Duty | 55 |
Tax Base | 56 |
Need for Further Investigation | 58 |
7. INCOME TAX: THE BASE | 59 |
I. Problems of Definition | 59 |
The Concept of Income | 59 |
― ii ― Capital Gains |
60 |
Bequests and Gifts Received | 60 |
Lottery and Casual Gambling Winnings | 60 |
Retirement Benefits and Compensation for loss of office | 60 |
Compensaton for physical injury to person received in a lump sum or for injury to reputation | 61 |
Non-money Income | 61 |
Deduction of Expenses | 62 |
Expenses Incurred in Deriving Income | 62 |
Other Deductible Expenses | 62 |
Exempt Income | 63 |
Annual Accounting | 63 |
Income of Particular Industries and Activities | 63 |
Income Moving Through Intermediaries | 64 |
International Aspects | 64 |
II. Specific Issues | 64 |
Compensation for Physical Injury to the Person | 64 |
Compensation for Injury to Reputation | 66 |
Imputed Rent of the Owner-Occupied Home | 66 |
Costs of Travel to and from Work | 69 |
Child-Minding Expenses | 70 |
Expenses of Income Earning Activities Carried on at Home | 72 |
Subscriptions to Trade and Professional Associations | 74 |
Income Protection Insurance Premiums | 74 |
Self Education Expenses | 76 |
Dissection and Apportionment of Composite Receipts and Outgoings | 76 |
8. INCOME TAX: ISSUES RELATING TO BUSINESS AND PROFESSIONAL INCOME | 79 |
I. Cash or Accruals Basis | 81 |
II. Accruals Tax Accounting and Financial Accounting | 83 |
Holding Charges | 84 |
Work in Progress | 84 |
Tax on Basis of Financial Accounting Principles | 85 |
III. Provisions and Accrued Expenses | 86 |
Long-service Leave and Holiday Pay | 86 |
Other Provisions for Liabilities | 89 |
Provision for Doubtful Debts | 90 |
IV. Depreciation and Amortisation of Fixed Assets | 90 |
Plant and Equipment | 91 |
Buildings | 92 |
Classes of Buildings which should qualify | 95 |
The inclusion of Existing Buildings | 95 |
Treatment on Change of Ownership | 96 |
Demolition and Damage | 96 |
Effect on Revenue | 97 |
Leasehold Improvements | 97 |
Other Assets and Costs of a Capital Nature | 98 |
V. Trading Stock | 98 |
Definition of Trading Stock | 99 |
Land Held for Resale | 100 |
― iii ― Plant Spares and Consumable Stores |
100 |
Shares, Debentures and Similar Assets | 100 |
Methods of Valuing Trading Stock | 101 |
Cost Price | 101 |
Market Selling Value | 103 |
Replacement Price | 103 |
Disposal of Trading Stock | 103 |
VI. Recoupment of Losses | 106 |
Carry-back of Losses | 106 |
Carry-forward of Losses | 108 |
Exempt Income | 109 |
Effect of Dividend Income | 109 |
VII. Implications of Inflation for Business Income | 110 |
VIII. Sundry Costs of Business Operation | 113 |
Lease Transactions | 113 |
Expenditure on Repairs to Income-producing Property | 113 |
Professional Libraries | 114 |
Travelling and Entertainment Expenses | 115 |
Anti-pollution and Ecological Expenditures | 115 |
IX. Conclusion | 116 |
9. INCOME TAX: ISSUES RELATED TO EMPLOYMENT AND INVESTMENT INCOME | 117 |
I. Employment Income | 117 |
Fringe Benefits | 117 |
Adequacy of Present Law | 118 |
Kinds of Benefits | 119 |
Housing | 119 |
Board and lodging | 119 |
Use of motor vehicle | 120 |
Goods and services supplied at discount | 120 |
Low interest loans | 121 |
Prizes and gifts | 121 |
Stock option and stock purchase schemes | 121 |
Goods and services supplied by others and paid for directly by the employer | 122 |
Allowances made available to employees for travel and entertainment expenses | 123 |
Tax Instalment Deductions | 123 |
Other Issues | 124 |
Salary and Wages Adjustments | 124 |
Travel and Removal Expenses | 124 |
Travel within employment for a temporary purpose | 125 |
Travel and removal expenses within an employment for a more permanent purpose | 125 |
Travel and removal expenses to take up a new employment | 126 |
Living away from home | 126 |
Study leave expenses | 126 |
Payments to obtain Release from Employment Contracts | 127 |
Standard Deduction | 128 |
II. Investment Income | 128 |
― iv ― 10. PERSONAL INCOME TAX: THE TAXPAYING UNIT |
131 |
I. Overseas Experience | 131 |
United Kingdom | 131 |
United States | 132 |
South Africa | 133 |
France | 134 |
Canada | 134 |
II. Review of Possible Reform | 134 |
Questions Arising over the Taxation of Family Units | 135 |
Individual Taxation with an Election System | 137 |
Restrictions on Right of Election | 137 |
De Facto Relationship | 138 |
Separated or Divorced Spouses | 138 |
A Proposal for Public Examination | 139 |
Reservation by the Chairman | 140 |
11. INCOME-SPLITTING | 143 |
Income-splitting and Minor Children | 145 |
Income from Gifts of Capital | 146 |
Partnerships, Inter-Vivos Trusts and Arrangements Achieving Similar Income-sharing Results | 148 |
Excessive Payments for Services or Benefits | 151 |
Alienation of Income | 152 |
Family Companies | 152 |
Section 260 | 153 |
Distributions of Income under a Legal Obligaton | 154 |
Distributions of Income under a Moral Obligation | 155 |
Retrospectivity | 155 |
Reservation by R. W. Parsons | 157 |
Reservation by K. Wood | 161 |
12. PERSONAL INCOME TAX: DEPENDANT ALLOWANCES AND OTHER CONCESSIONAL DEDUCTIONS | 163 |
I. Concessional Deductions: Dependants | 163 |
Dependent Spouse | 163 |
Other Adults | 165 |
Dependent Children | 165 |
Student | 166 |
II. Other Concessional Deductions: Issues of Principle | 166 |
III. Concessional Deductions for Education and Medical Expenses | 169 |
Education Expenses | 170 |
Medical Expenses | 170 |
Payments to Medical and Hospital Benefits Funds and Medical Expenses Generally | 172 |
Expenses of Blind Persons or Persons Confined to Bed or Invalid Chair | 174 |
Funeral Expenses | 174 |
IV. Zone Allowances | 174 |
Zone Boundaries | 175 |
Deduction or Rebate | 175 |
The Amount of the Concession | 176 |
Qualifying Period | 176 |
― v ― 13. PERSONAL INCOME TAX: SOCIAL SECURITY |
177 |
I. Social Security Payments and the Tax System | 177 |
II. Social Security Contributions | 180 |
14. PERSONAL INCOME TAX: RATE STRUCTURE | 183 |
I. Complexity of Rate Scale | 183 |
II. Surcharge on Property Income | 185 |
III. Shape of Rate Scale | 188 |
Low Range | 188 |
High Range | 190 |
Intermediate Range | 192 |
IV. Frequency of Adjustment | 193 |
Purpose of Adjustment | 194 |
Statutory or Discretionary | 194 |
Adjustment Procedure | 196 |
V. Income Averaging | 197 |
The Existing Law | 197 |
Primary producer averaging | 197 |
Drought bond scheme | 198 |
Anti-bunching measures | 198 |
Alternatives to the Existing Law | 199 |
Averaging | 199 |
Cumulative averaging | 200 |
Block averaging | 200 |
Marginal adjustment scheme | 200 |
United States System | 201 |
Income Equalisation Scheme | 204 |
Anti-bunching Measures | 205 |
Appendix A: Tax payable under Alternative Systems: 1974–75 Rates | 206 |
15. INCOME TAXATION IN RELATION TO TRUSTS AND PARTNERSHIPS | 207 |
I. Trusts | 207 |
Present Entitlement | 208 |
Present Entitlement of a Beneficiary under a Disability | 210 |
Net Income of the Trust Estate and Trust Income | 211 |
Accumulating Income | 213 |
Losses of Previous Years | 215 |
II. Partnerships | 216 |
Net Income of a Partnership and Partnership Profits | 216 |
Treatment of Losses | 217 |
Payment by Surviving Partners to Retired Partner or to Estate of Deceased Partner | 218 |
III. International Aspects | 218 |
Trusts | 218 |
Partnerships | 220 |
16. COMPANY INCOME TAX | 223 |
I. Present System of Company Income Taxation | 225 |
Criticism of the Present System | 225 |
II. Unacceptable Alternatives to the Present System | 228 |
Tax the Allocation of Profits | 228 |
Tax Actual Distributions and Accruals in Value of Shares | 228 |
― vi ― Require Distribution of All Profits and Tax these Distributions |
229 |
Tax the Company and Exempt Dividends from Personal Income Tax | 229 |
III. Split-rate and Imputation Systems | 229 |
The Choice of an Imputation System | 231 |
IV. Proposed Imputation System | 233 |
Amount of Imputation | 234 |
Minimum Distributions by Companies | 234 |
International Implications of Proposed Imputation System | 235 |
Investment by Non-residents | 236 |
Investment by Australian Resident in Foreign Countries | 237 |
V. Imputation and Forward Shifting | 238 |
VI. Proposal to Allow Election to be Taxed as a Partnership | 239 |
Eligibility to Elect | 239 |
Amount and Nature of Company Profits | 239 |
Number and Nature of Shareholders | 240 |
Capital Structure of the Company | 240 |
Manner and Timing of Election and Manner of Termination of Election | 240 |
Consequences of Election and Termination of Election | 241 |
VII. Appropriateness of Special Provisions for Small Enterprises | 241 |
VIII. Aspects of Present Company Taxation | 242 |
Minimum Distribution Requirements | 242 |
Income of Private Investment Companies | 245 |
Assessment of Company Groups | 246 |
The Treatment of Company Groups in Other Countries | 246 |
United States | 246 |
New Zealand | 247 |
Canada | 247 |
United Kingdom | 247 |
The Choice of Method of Relief | 247 |
Holding and Subsidiary Companies | 248 |
Trading and Consortium Companies | 248 |
Restrictions on Carry-forward of Company Losses | 249 |
Loan Capital and Share Capital | 250 |
Convertible Notes | 251 |
High Gearing | 251 |
17. INTERNATIONAL ASPECTS OF INCOME TAXATION | 253 |
I. The Taxation of Foreign-source Income of Australian Residents | 254 |
Concept of Resident of Australia | 254 |
Foreign-source Income not Subject to Australian Tax | 256 |
Credit for Foreign Tax on Foreign-source Income subject to Australian Tax | 256 |
Exemption and Credit as Methods of Giving Relief Against Double Taxation | 257 |
Equity | 257 |
Efficiency | 258 |
Simplicity | 259 |
― vii ― Committee's Proposals |
260 |
II. Australian-origin Income of Non-residents | 262 |
Justification for Taxing Income of Non-residents on the Basis of Origin in Australia | 263 |
Taxation on the Basis of Source in Australia | 264 |
Tax on Australian-origin Income by Withholding | 265 |
Tests of Foreign Origin of Income | 266 |
Reconstruction of Australian-source Income of Non-residents | 266 |
Reconstruction of Income of Australian Residents from Transactions with Non-residents | 268 |
Taxation of Branch Operations in Australia | 269 |
III. Double Taxation Agreements | 270 |
Appendix A: Rules for Determining Source of Income of Non-residents | 273 |
Income from Sale of Goods Imported into Australia | 273 |
Income from Purchase and Sale of Goods that are at all times in Australia | 273 |
Income from Purchase of Goods in Australia and their Sale Abroad | 273 |
Income from Manufacturing Operations in Australia | 274 |
Income from Sale of Australian Real Property | 274 |
Income from Sale of Shares | 274 |
Income from Services Performed as an Employee | 275 |
Income from Services Performed Otherwise than as an Employee | 275 |
Income in the Form of Rentals in respect of Real Property | 276 |
Income in the Form of Rents of Chattels | 276 |
Income in the Form of Payments for the use of Commercial or Industrial Property | 277 |
Income Arising from Payments for Commercial or Industrial Property | 277 |
Income Arising from Payments for Scientific, Technical, Industrial or Commercial Knowledge or Information | 277 |
Income in the Form of Dividends | 278 |
Income in the Form of Interest | 278 |
18. INCOME TAXATION IN RELATION TO PARTICULAR INDUSTRIES: PRIMARY PRODUCTION | 281 |
The Definition Provisions | 282 |
Valuation of Livestock | 282 |
Spreading and Averaging Provisions | 284 |
Capital Expenditure and Depreciation | 285 |
Losses of Previous Years | 286 |
Restriction of Benefit of Primary Production Provisions | 286 |
19. INCOME TAXATION IN RELATION TO PARTICULAR INDUSTRIES: MINING | 289 |
I. General Mining | 289 |
Conduct of Mining Operations | 290 |
Determination of Net Income from Mining | 292 |
Provisions of the Act | 293 |
Exploration and Prospecting Expenditure | 293 |
― viii ― Development of a Mine and Mining Infrastructure |
294 |
Processing and Treatment of Minerals | 296 |
Overseas Exploration and Prospecting | 297 |
Anti-pollution and Ecological Expenditure | 297 |
Depletion Allowance | 299 |
Purchase of Mining or Prospecting Right or Information | 300 |
Proceeds of Sale of Mining Right or Information | 302 |
Section 23(o) | 302 |
II. Recent Amendments to the Act | 303 |
Exploration Expenditure by General Mining Companies | 304 |
Allowable Capital Expenditure: Costs of Company Formation and Capital Raising | 305 |
Immediate Write-off Provisions | 305 |
Housing and Welfare Expenditure | 307 |
Transportation Expenditure: Division 10AAA | 308 |
III. Petroleum Mining | 308 |
Overseas Exploration and Prospecting | 309 |
Exploration and Prospecting Expenditure | 309 |
Development Expenditure | 311 |
Depreciation Allowances | 312 |
Acquisition of Prospecting Information or Mining Right | 312 |
IV. Quarrying | 312 |
Nature of Quarrying Industry | 313 |
Expenditure Incurred in Quarrying | 313 |
Quarrying Plant Depreciation | 314 |
Exploration Expenditure | 314 |
Development Expenditure | 315 |
Anti-pollution and Ecological Expenditure | 316 |
Acquisition Costs and Proceeds of Sale of Quarry | 316 |
Appendix A: Mining Taxation: A Comparative Survey | 319 |
I. Exploration Costs | 319 |
Australia | 319 |
General Mining | 319 |
Petroleum | 320 |
Transfer to Purchaser of Benefit of Deduction | 320 |
United Kingdom | 321 |
Canada | 322 |
‘Principal Business Corporations’ | 322 |
Taxpayers other than ‘Principal Business Corporations’ | 322 |
United States | 323 |
South Africa | 323 |
New Zealand | 324 |
Mining Companies | 324 |
Loss Carry-forward | 324 |
Appropriations | 324 |
Mining Operators | 325 |
Non-resident Mining Operators | 325 |
II. Capital Expenditure on Plant and Development | 325 |
Australia | 325 |
General Mining | 325 |
Railways, Roads, Pipelines | 326 |
― ix ― Petroleum |
327 |
Sale of Prospecting or Mining Rights or Information | 328 |
Disposal of Mining and Petroleum Mining Assets | 328 |
United Kingdom | 328 |
Canada | 330 |
Depletion Allowances | 330 |
Additional Allowances | 331 |
Capital Cost Allowances | 331 |
United States | 332 |
Depletion Allowances | 332 |
Percentage Depletion | 332 |
Development Expenditure | 333 |
South Africa | 333 |
Computation of Deduction | 333 |
Closing Down of Mine | 334 |
Change of Ownership | 334 |
New Zealand | 334 |
III. Investment Incentives | 335 |
Australia | 335 |
Deductibility of Capital Subscription | 335 |
Exempt Income | 336 |
Losses Incurred in Gaining Exempt Income | 336 |
United States | 337 |
Canada | 337 |
New Zealand | 337 |
South Africa | 338 |
20. INCOME TAXATION IN RELATION TO PARTICULAR INDUSTRIES: GENERAL INSURANCE, EXEMPT ORGANISATIONS AND MUTUAL ASSOCIATIONS | 339 |
I. General Insurance | 339 |
Determination of Earned Premiums | 339 |
Claims Incurred but not Reported | 340 |
Catastrophe Fund | 341 |
Reinsurance with Non-residents | 341 |
II. Exempt Organisations and Mutual Associations | 342 |
Local Governing Bodies, Public Authorities and Institutions of a Charitable Kind | 342 |
Non-profit Associations and Societies Formed for Particular Purposes | 342 |
Co-operative Companies | 344 |
Friendly Society Dispensaries | 346 |
21. INCOME TAXATION IN RELATION TO SUPERANNUATION AND LIFE INSURANCE | 349 |
I. The Case for Special Treatment | 349 |
II. Superannuation, Retiring Allowances and Related Matters | 350 |
Background and Present Legislation | 350 |
Taxation of Lump Sum Payments on Retirement | 351 |
Deductibility of Retiring Allowances Paid by Employers | 353 |
Deductibility of Contributions to Superannuation Funds | 354 |
Taxation of Income of Superannuation Funds | 355 |
― x ― Taxation of Benefits Received from Superannuation Funds |
358 |
International Comparisons: A Brief Summary | 360 |
Proposals | 361 |
The First View | 361 |
The ultimate position | 362 |
Transitional provisions: lump-sum retirement benefits | 365 |
The income of superannuation funds | 367 |
Contributions to approved superannuation funds | 369 |
Provision for self-employed persons | 369 |
Transitional provisions for superannuation funds | 370 |
The 30/20 requirements | 370 |
The Second View | 370 |
The amount of tax-assisted saving | 372 |
Contributions to the fund | 372 |
Approved funds | 372 |
The taxing of receipts from an approved fund | 372 |
The phasing out of funds approved under the old law | 373 |
Comparison of the Two Views | 373 |
III. Life Insurance | 375 |
Background and Present Legislation | 375 |
Deductibility of Premiums | 375 |
Taxation of Life Insurance Companies | 376 |
The 30/20 Requirements | 377 |
Taxation of Policy Proceeds | 377 |
International Comparisons: A Brief Summary | 378 |
Conclusion | 379 |
22. INCOME TAX ADMINISTRATION | 381 |
I. Legislature, Appeals and Prosecutions | 381 |
The Commissioner's Discretion | 381 |
Amendment of an Assessment | 383 |
Objections to an Assessment | 384 |
Powers and Procedures of a Board of Review | 385 |
Appellate Powers and Procedures | 388 |
Costs of Objections, Reviews and Appeals | 390 |
Interest Upon Pre-paid Tax Liabilities | 391 |
Taxation Prosecution Procedures and Penalties | 392 |
Hardship Relief | 394 |
Public Interest in Taxation Legislation | 396 |
Independent Standing Committee | 396 |
II. Procedures and Compliance | 397 |
Adjustment Sheets | 397 |
Supply of Information | 397 |
Return Forms | 397 |
Information Bulletins | 397 |
Advance Rulings | 398 |
Non-taxable ‘Assessments’ | 398 |
Taxpayer Compliance | 399 |
Registered Tax Agents | 400 |
III. Payment of Tax | 401 |
Tax Instalment Deduction System | 401 |
Excess Instalment Deductions | 401 |
― xi ― Limited Effectiveness |
402 |
Other Aspects | 404 |
Provisional Tax System | 405 |
Company Tax System | 409 |
Withholding Tax | 411 |
23. CAPITAL GAINS TAX | 413 |
I. The General Issue | 414 |
II. The Method of Taxing | 416 |
III. Specific Issues | 419 |
Transitional Provisions | 419 |
Bunching and Spreading | 420 |
Determination of Amount of Gain | 421 |
Treatment of Companies | 422 |
Treatment of Trusts | 423 |
Treatment of Gifts | 424 |
Treatment of Unrealised Gains at Death | 425 |
Exemption on Retirement, Death or Disablement | 425 |
Treatment of Taxpayer's Principal Residence | 426 |
Exemption of Small Gains | 427 |
Exemption of Certain Assets | 427 |
Life Assurance Policies | 428 |
Superannuation Rights | 428 |
Depreciable Assets | 428 |
Intangible Assets | 428 |
Roll-over for Certain Assets | 428 |
Treatment of Losses | 429 |
IV. The Distinction Between Capital and Income | 430 |
Section 26(a) | 430 |
Section 26AAA | 431 |
Replacement of Sections 26(a) and 26 AAA upon their Repeal | 431 |
V. Development Gains Tax | 432 |
VI. Conclusion | 433 |
Reservation by R. W. Parsons | 435 |
Reservation by K. Wood | 438 |
24. ESTATE AND GIFT DUTY | 439 |
I. The Form of a Death Tax | 441 |
II. Proposed Reforms | 442 |
The Tax Base | 442 |
Integration of Gift Duty with Estate Duty | 443 |
Deductions in Determining the Estate Duty Base | 444 |
Rate Structure | 444 |
Concessions for Dependants | 445 |
Other Concessions | 447 |
Adjustments for Inflation | 447 |
Advance Provision for Payment of Tax | 448 |
Quick-succession Relief | 448 |
Fall in Value of Assets after Death | 450 |
Valuation of Assets | 451 |
Jurisdiction of Integrated Estate and Gift Duty | 451 |
Incidence of Integrated Estate and Gift Duty | 452 |
― xii ― Assessment Procedures |
453 |
A National Estate and Gift Duty | 453 |
Appendix A: The Base of an Integrated Estate and Gift Duty | 455 |
I. Powers Over Property | 445 |
II. Options | 457 |
III. Settled Property | 459 |
Life Estates | 460 |
Estates for a Term of Years or for the Life of Another Person | 462 |
Discretionary Trusts | 462 |
Accumulating Income | 463 |
Special Cases | 464 |
IV. Annuities | 465 |
V. Gift of Services | 466 |
VI. Use of Property | 467 |
VII. Debts | 468 |
VIII. Partnerships | 468 |
IX. Companies | 469 |
Transfer of Assets to a Company | 469 |
Power or Control in Relation to Companies | 469 |
Benefits from a Company | 470 |
Gifts in Transactions Involving Companies | 470 |
Gift to a company | 471 |
Gift by a company | 471 |
Allotment of shares | 472 |
Variation in share rights | 472 |
Change in share rights without concurrent company action | 472 |
An obligation to sell shares to specified persons at a price specially determined | 473 |
Declaration of dividends | 473 |
Definition of a ‘Family’ or ‘Closely Controlled’ Company | 474 |
X. Involuntary Gifts | 474 |
XI. Insurance and Superannuation | 475 |
XII. Joint Ownership | 475 |
XIII. Exempt Transactions | 475 |
XIV. Interrelation of Income Tax and Gift Tax | 476 |
Appendix B: Rate Structure | 479 |
I. Present Duties and Grossing-up | 479 |
II. Illustration of a Scale of Integrated Duty | 479 |
III. Adjusting the Rate Scale | 480 |
IV. Quick-succession Relief | 481 |
Appendix C: Situs of Assets | 483 |
Reservation by R. W. Parsons | 485 |
Reservation by K. Wood | 487 |
25. CHARITIES | 489 |
I. Deductibility from Income of Gifts to Charities | 489 |
II. Income of Charities | 490 |
III. Charities in Relation to Gift and Estate Duties | 491 |
IV. Issues of Principle | 492 |
Subsidy by Deduction | 492 |
Subsidy by Exemption of Income | 493 |
V. Uniformity of Tax Treatment | 495 |
― xiii ― Appendix A: Extract from Income Tax Assessment Act |
497 |
Appendix B: Extract from Estate Duty Assessment Act | 501 |
Appendix C: Tax Treatment of Charities | 503 |
26. WEALTH TAX | 505 |
I. Overseas Experience | 505 |
II. Appraisal | 506 |
III. Conclusion | 510 |
27. TAXATION OF GOODS AND SERVICES | 511 |
I. Existing Taxes on Goods and Services | 511 |
II. Broad-based Taxes | 515 |
Turnover Tax | 516 |
Wholesale Sales Tax | 517 |
Retail Sales Tax | 517 |
Value-added Tax | 518 |
III. Level of VAT and Transitional Problems | 520 |
Appendix A: Sales Tax as a Continuing Tax | 523 |
I. Tax Base and Rates of Tax | 523 |
II. Structure and Administration of the Law | 523 |
Simplification of the Law | 523 |
Time for Lodgment of Returns | 524 |
Objections and Appeals | 524 |
Freight Charges | 526 |
Avoidance of Tax | 526 |
28. CONCLUSION | 529 |
Advertisement of Terms of Reference and Invitation to Submit | 533 |
List of Authors of Submissions | 535 |
List of Commissioned Studies | 547 |
Treasury Taxation Papers | 549 |
Members of the Professional Staff who assisted the Committee for varying periods | 551 |
Professional Firms, Universities and Organisations who made Professional Staff Available to the Committee | 551 |
Members of the General Services Staff | 551 |
Important Statutory Alterations to the Taxation Legislation since the Taxation Review Committee commenced its work | 553 |
Index | 559 |