Speaking
on the need for more inclusive growth at the recently held National
Development Council meeting to approve the Approach to the XIth Plan,
Prime Minister Manmohan Singh reportedly said: ''We cannot escape the
fact that the Centre's resources will be stretched in the immediate
future and an increasing share of the responsibility will have to be
shouldered by the States.'' More generally, his view on resources for
the Plan was that much of the investment needed for rapid growth would
come from the private sector. This, in his opinion, called for a sound
macroeconomic framework, an investor-friendly environment and a strong
and innovative financial sector capable of responding to the needs of
new entrepreneurs.
Implicit in this position are two contentious issues. The first is the
validity of the view that reliance on the private sector to deliver
investment and growth would not imply an inequalising and less inclusive
path of development, especially if private initiative is combined with
social expenditures financed by the government. There are indeed many
who believe that the crisis in agriculture (which the Prime Minister
referred to) and the evidence of exclusion (which he emphasised) are
partly the result of the shift to a private sector-led strategy of growth.
In the event an 8 per cent growth rate notwithstanding, large sections
of the population garner few benefits and even experience deterioration
in their economic position.
The second contentious issue is that in the process of creating an investor-friendly
environment—which in practice implies substantial tax concessions and
reduced tax rates—the Centre may be engineering an environment when
it finds itself resource-stretched to finance even crucial capital and
social expenditures, encouraging it to call upon state governments to
take a larger share of the responsibility.
We are here concerned with the second of these propositions. One striking
feature of the period since 1989-90, which incorporates the years of
accelerated economic reform is that despite evidence of high and accelerating
growth rates and signs of growing inequality, there has been no improvement
in the Centre's ability to garner a larger share of resources to finance
expenditures it considers crucial. Even when corporate profits and managerial
salaries are reported to be rising sharply, taxes do not appear as buoyant.
The Central tax-to-GDP ratios in India have been declining for much
of this period. And despite the increase in the ratio in recent years,
their 2005-06 values were at around the same level they were at in 1989-90
(Chart 1).
This
failure to significantly improve the tax-to-GDP ratio, in a period when
there has also been a widening of the tax net through various means, is
largely due to the tax concessions provided during the years of liberalisation.
While inequality increases, marginal tax rates have come down sharply
during the liberalization years. In 1985-86, the marginal rate of taxes
on personal income was brought down from 62 to 50 per cent and the corporate
tax rate from around 60 to 50 per cent. In the budgets of the early 1990s,
especially those of 1992-93 and 1994-95, the marginal rates were further
reduced to 40 per cent. Today, they stand at around 33 per cent.
As can be seen from Chart 1, the tax-to-GDP ratios were at their lowest
in 2001-02, when they stood at 8.2 per cent in the case of the Centre's
Gross Tax Revenue and 5.9 per cent in the case of Net Tax Revenue, having
fallen from 10.6 and 7.9 per cent respectively in 1989-90. This decline
has occurred despite some improvement in the collection of Corporation,
Income and Service taxes (relative to GDP) because they could not cover
the loss suffered in customs duty collections and excise duty revenues
as a result of trade liberalisation and the ostensible ''rationalisation''
of excise duties (Table 1).
If we decompose the decline in the tax-GDP ratio between 1989-90 and 2001-02,
the contribution of the decline in customs duties relative to GDP amounted
to 80 per cent and that of Excise Duties to 58 per cent. Hence, despite
the neutralising effects of the improved contributions from Corporation
Taxes (26 per cent), Income Taxes (15.4 per cent) and the newly introduced
Service Tax (6 per cent), the decline in the overall tax-GDP ratio could
not be stalled.
It is indeed true that, subsequently, buoyant corporate profits, a widened
tax base and improved collection of dues and arrears, have helped raise
the tax-GDP ratio. But despite high growth, improved profitability and
signs of increased inequality (which should improve tax collection), the
increase has just been adequate to put the tax-GDP ratio back to its immediate
pre-liberalisation levels. This is because, while Corporation, Income
and Service tax revenues (particularly the first) contributed to the increase,
their effect was inadequate to raise the level above that which prevailed
in the late 1980s.
In
the event, the Centre has indeed been strapped for resources to finance
its expenditures. As Chart 4 shows, the ratio of central budgetary expenditures
to GDP fell sharply between 1989-90 and 1996-97. While the ratio regained
some of the lost ground in the latter part of the 1990s and immediately
thereafter, the decline resumed in 2003-04 and was at its lowest level
since 1989-90 in 2005-06.
Much
of this is on account of curtailment of capital expenditure. Revenue expenditures
as a percentage of GDP, while fluctuating over time, have more or less
retained their level across the period as a whole. Thus the fall in total
expenditure relative to GDP has been largely on account of cuts in capital
expenditure, which stood at less than 2 per cent of GDP in 2005-06 as
compared with 6 per cent in 1989-90.
What is noteworthy is that the decline in capital expenditure has been
particularly sharp over the three years ending 2005-06, when the central
tax-GDP ratio has been on the rise. This was because these where the years
when, armed with the Fiscal Responsibility and Budget Management (FRBM)
Act, the government has been finally realising its ambition to substantially
curtail the fiscal deficit (Chart 5). With revenues not rising adequately
and the fiscal deficit being curtailed significantly, expenditures had
to be cut to fulfil the FRBM Act, and the axe fell disproportionately
on capital expenditures. This is the reason why the Prime Minister has
to declare that investment and growth in the coming years will have to
be driven by the private sector.
Does
the pattern of movement of the different components of tax revenue suggest
that the Centre has exhausted the possibilities of improving it tax revenues
relative to GDP? It could be argued that the decline in customs revenues
was inevitable, since that was an outcome of unavoidable trade liberalisation.
And since corporation, income and service taxes have increased, it could
be said that the government had made an effort to partially neutralise
the impact of reduced customs tariffs, but could not completely deal with
the problem.
There are a number of difficulties with that argument. To start with,
it does not question whether tariff reductions that have such a significant
impact on revenues were justified. In fact, when tariff reductions were
being made, one of the arguments was that trade buoyancy would ensure
that revenue losses would be marginal. This has not really occurred. Second,
it glosses over the fact that what was considered mere ''rationalisation''
of the excise duty structure, as part of a process of fiscal reform, has
amounted in practice to the provision of significant excise duty concessions
that have had extremely adverse effects. Third, it does not raise the
question, which has been raised by the Planning Commission itself, whether
there is any rationale for sharply curtailing the fiscal deficit, despite
its extremely adverse impact on capital and social expenditures.
Finally, it does not answer the criticism that the Centre has not gone
even part of the way in tapping resources from direct taxes of various
kinds, but in fact has doled out concessions that are unjustifiable. A
striking example is the income earned from equity investment. There are
two principal ways in which income is garnered through such investment:
dividends and capital gains. Both have them have benefited from recent
tax concessions. To start with, on the grounds that corporate incomes
are already taxed so that taxing shareholder dividend income would amount
to a form of double taxation, it was decided in 1999-2000, that dividends
paid out to shareholders should be made tax-free. Being controversial,
this decision was reversed in the budget for 2002-03, only to be reinstated
again in the Budget for 2003-04.
What has been the fall-out of this exemption? An extremely revealing analysis
by B.G. Shirsat (Business Standard, July 14 and 22/23, 2006) of 1,050
major dividend-paying, listed companies has found that dividends paid
out during the three years ending 2005-06 amounted to Rs. 29,532 crores.
Since the beneficiaries of these dividends are likely to be in the highest
marginal tax bracket, if this dividend income had been subject to tax,
the revenue earned by the government over these three years would have
been an additional Rs.10,000 crore (if we assume that the dividend pay
out rate would have been the same even if the tax was effective). This
is by no means a small sum.
What is noteworthy is the inequality in the distribution of this tax benefit.
It is known that a miniscule proportion of the domestic population invests
in equity. But even among them, the distribution of dividend and therefore
the benefit of the tax exemption is highly skewed. Of the close to Rs.30,000
crore of dividends paid out by these companies, Rs.14,000 crore or around
45 per cent accrued to the promoters of the companies themselves. In fact,
small or so-called ''retail'' shareholders received a relatively small
share of this benefit. Over ninety per cent of the shareholders holding
up to 500 shares each received just over Rs.4000 crore of dividend income,
while public shareholders with equity holding in excess of 500 shares
garnered Rs.7,575 crore as dividends. A significant amount of the dividend
paid to public shareholders went to foreign investors. Foreign institutional
investors (FIIs) received Rs.12, 808 crore of dividend income during this
period and investors in GDRs and ADRs, NRI investors and other overseas
bodies received Rs.4,567 crore. In sum, a combination of promoters, high
net worth domestic investors and foreigners were the main beneficiaries
of the dividend tax hand out.
There remains the argument that the exemption of dividends from taxes
was not a hand out but the redressal of an unjust scheme of double taxation.
Even if this is accepted, there remains the fact that there is a high
degree of inequality in the distribution of incomes in the country, which
the accrual of record dividend incomes seems to aggravate substantially.
If the idea was for the government to garner a fair share of the surplus
for social and capital expenditures, then the removal of the tax on dividends
should have been accompanied by an increase in the marginal corporate
tax rate. The fact that the government has not chosen to resort to such
an increase only strengthens the perception that it has failed to tax
a section of the rich adequately and effectively.
The evidence on unwarranted benefits to investors in equity does not end
here. It is visible in the case of the other form of return from equity
holding—capital gains—as well. The budget for 2003-04 also decided that,
''in order to give a further fillip to the capital markets'', all listed
equities that were acquired on or after March 1, 2003, and sold after
the lapse of a year, or more, were to be exempted from the incidence of
capital gains tax. Capital gains made on those assets held by the purchaser
for at least 365 days were defined for taxation purposes as long term
gains. Long term capital gains tax was being levied at the rate of 10
per cent up to that point of time.
An analysis of share price movements of 28 Sensex companies found that
if we assume that all shares purchased in 2004 were sold after 365 days
in 2005, the total capital gains that could have been garnered in 2005
would have amounted to Rs. 78,569 crore. If these gains had been taxed
at the rate of 10 per cent prevalent earlier, the revenue yielded would
have amounted to Rs. 7,857. That reflects the revenue foregone by the
State and the benefit accruing to the buyers of these shares. It is indeed
true that not all shares of these companies bought in 2004 would have
been sold a year-and-one-day later. But some shares which were purchased
prior to 2004 would have been sold during 2005, presumably with a bigger
margin of gain. And this estimate relates to just 28 companies.
In sum, the stock market alone has become the site for tax-exempt gains
of a magnitude which suggest that a more appropriate tax policy relating
to dividends and capital gains could have yielded substantial revenues
for the government. This is only one area. There are many more such which
the central government should look to when looking for money to finance
crucial expenditures. But what the instances quoted prove is that in the
effort not just to facilitate but ''induce'' private investment with tax
concessions, the government is engineering a fiscal situation which is
by no means indicative of a macroeconomic framework that is ''sound''
from a growth and equity point of view.
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