Numerical Index | Alphabetical Index

WARNING:
This Digest was prepared for debate. It reflects the legislation as introduced and does not canvass subsequent amendments. This Digest does not have any official legal status. Other sources should be consulted to determine the subsequent official status of the Bill.

CONTENTS

Passage History
Purpose
Background
Main Provisions
Concluding Comments
Endnotes
Contact Officer and Copyright Details

Passage History

A New Tax System (Indirect Tax Administration) Bill 1999

Date Introduced: 24 March 1999

House: House of Representatives

Portfolio: Treasury

Commencement: Immediately after the commencement of the A New Tax System (Goods and Services Tax Administration) Act 1999, which, if enacted, will commence on 1 July 2000.

Purpose

This Bill proposes to amend new Part VI of the Taxation Administration Act 1953 (TAA), as proposed by the A New Tax System (Goods and Services Tax Administration) Bill 1998 (GSTA Bill), by extending its scope to cover the Wine Equalisation Tax (WET, or Wine Tax) and the Luxury Car Tax (LCT) in addition to the Goods and Services Tax (GST).

Additionally, this Bill proposes to amend new Part VI, as proposed by the GSTA Bill, to:

• Apply a 4 year limit within which there will be an entitlement to a refund for importations
• Replace the fixed rate penalty for unpaid GST with a commercially realistic interest charge based on the outstanding balance of unpaid indirect tax
• Provide penalties for failing to provide information with respect to the WET law(1) and the LCT law(2) as proposed with respect to the GST law(3)
• Exclude from liability to penalty any breach of an obligation resulting from an amendment to an indirect tax law where that breach occurred before the 28^th day after the granting of Royal Assent to the amending law
• Extend the review rights embodied in the TAA to include reviewable wine tax decisions and reviewable indirect tax decisions, and
• Provide that upon any changes to the WET law or LCT law that affects the cost of goods in a contract involving a supply or a taxable dealing in those goods, the contract price will be automatically altered by the difference in the tax payable on the goods as a result of the change, unless the contract otherwise provides.

Background

1.0 A New Tax System (Goods and Services Tax Administration) Bill 1998

The GSTA Bill proposes to amend the TAA to incorporate new provisions concerning the GST relating to:

• Assessments of GST
• Recovery of GST owing
• Penalties for non-compliance with GST obligations
• Special rules for certain entities such as partners of a partnership, participants in a joint venture, liquidators and receivers, and directors of a company
• The evidentiary effect of certain documents
• Reviewable decisions, and
• Miscellaneous administrative matters.

The GSTA Bill will also amend the existing provisions of the TAA concerning secrecy, prosecutions and offences, and taxation objections, reviews and appeals, to incorporate certain matters relating to the GST.

2.0 Taxation Administration Act 1953

The TAA and the regulations thereunder contain important administrative provisions concerning the various taxation laws administered by the Commissioner of Taxation. They include those relating to:

• Providing the statutory authority for the office of the Commissioner of Taxation, including appointment, tenure of office, remuneration, delegation of powers, and related matters
• Secrecy and the provision of taxation information
• Offences and prosecutions
• Exchange control
• Departure prohibition orders
• The public and private rulings system, and
• The set of generic provisions regulating objections, reviews and appeals in relation to taxation decisions made under various Commonwealth tax laws, including income tax, fringe benefits tax and wholesale sales tax.

3.0 Recent History

On 13 August 1998 the Government released details of its long awaited tax reform plan, embodied in the publication entitled Tax Reform: not a new tax, a new tax system (Tax Reform Plan).

A key aspect of the Tax Reform Plan is the introduction of a GST to replace the current Wholesale Sales Tax (WST), as well as a number of State indirect taxes. The Tax Reform Plan as a whole formed a major component of the Government's policy platform leading up to the Federal election held on 3 October 1998.

Following the Governments re-election, a package of 16 Bills were introduced on 2 December 1998 to implement a GST as well as some of the other tax reform measures contained in its Tax Reform Plan. Six of those Bills introduce the GST, namely:

• A New Tax System (Goods and Services Tax) Bill 1998
• A New Tax System (Goods and Services Tax Administration) Bill 1998
• A New Tax System (Goods and Services Tax Transition) Bill 1998
• A New Tax System (Goods and Services Tax Imposition-General) Bill 1998
• A New Tax System (Goods and Services Tax Imposition-Customs) Bill 1998, and
• A New Tax System (Goods and Services Tax Imposition-Excise) Bill 1998.

In addition to introducing the GST, the Tax Reform Plan also proposed to introduce a Wine Equalisation Tax and a Luxury Car Tax. On 24 March 1999 a package of ten Bills introduced the WET and the LCT, namely:

• A New Tax System (Wine Equalisation Tax) Bill 1999
• A New Tax System (Wine Equalisation Tax Imposition-General) Bill 1999
• A New Tax System (Wine Equalisation Tax Imposition-Customs) Bill 1999
• A New Tax System (Wine Equalisation Tax Imposition-Excise) Bill 1999
• A New Tax System (Luxury Car Tax) Bill 1999
• A New Tax System (Luxury Car Tax Imposition-General) Bill 1999
• A New Tax System (Luxury Car Tax Imposition-Customs) Bill 1999
• A New Tax System (Luxury Car Tax Imposition-Excise) Bill 1999
• A New Tax System (Indirect Tax Administration) Bill 1999, and
• A New Tax System (Wine Equalisation Tax and Luxury Car Tax Transition) Bill 1999.

4.0 GST Overview

The GST proposed is a broad-based indirect tax on final private consumption in Australia. It will tax the consumption of most goods, services and any other things, including things imported into Australia, but not to consumption outside Australia. The GST rate proposed is 10%.

The GST is based on the Value Added Tax (VAT) system, which has been adopted by nearly all OECD countries and more than 80 others around the world. The GST concept of taxing final private consumption is achieved by:

• imposing tax on supplies made by entities registered for GST purposes, and
• allowing those entities to claim a full credit for any GST they have paid on business purchases (or inputs). Such credits will be known as input tax credits.

Consistent with other GST and VAT regimes, there will be two types of non-taxable supplies, 'GST-free' and 'input taxed', known in most other countries with a GST or VAT as 'zero rated' and 'exempt' respectively.

GST-free supplies will not be taxed and input tax credits will be allowed on things acquired to make the supply. The main activities that will be GST-free include exports, certain expenditure by tourists, health and medical care, education, childcare, charitable activities and religious services.

Input taxed supplies will similarly not be taxed, however no input tax credits will be allowed on things acquired to make the supply. The main activities that will be input taxed are financial services and residential rents.

The main Bill implementing the GST is the A New Tax System (Goods and Services Tax) Bill 1998 (GST Bill, or GST Act once enacted).

5.0 Wine Equalisation Tax

5.1 Brief History of Wine Taxation

The Australian wine industry has been subject to an array of taxation measures over the years, commencing in 1930.

These measures are summarised in the following table:

5.2 Current Taxation of Alcoholic Beverages

Alcoholic beverages in Australia are essentially subject to either sales tax (which is an ad valorem tax) or volumetric excise or both.

Ad valorem tax is a rate of tax, which is fixed according to the value of the dutiable transaction or item.

A volumetric tax is also an indirect tax but one directly related to the alcohol content of the beverage.

Wine is subject to sales tax at the rate of 41 per cent.

Beer and spirits are subject to a combination of sales tax at the rate of 37 per cent plus a volumetric tax, which is calculated by multiplying the percentage of alcohol content of the beverage by a fixed dollar amount per litre.

5.3 Wine Equalisation Tax Overview

As part of the Tax Reform Plan, the Government proposed that wine, and beverages consisting primarily of wine, will become subject to a wine equalisation tax to replace the difference between the current 41 per cent WST and the proposed GST. The WET will be in addition to any GST that may be payable.

The introduction of a WET will mean that after the abolition of WST and its replacement with a GST, wine prices should be equalised back to current levels.

• WET will be a single stage tax applying generally to assessable dealings in wine, unless an exemption applies, at the wholesale level
• Wine will include any fruit wine or vegetable wine. WET will also apply to any assessable dealings in cider, perry, mead and sake
• WET will be imposed on the wholesale selling price of wine
• If wine is not sold by wholesale:
• tax will be imposed on the retail sale or use of the wine, and
• will be based on alternative values such as the notional wholesale selling price
• If the wine has already been taxed, then a credit for the earlier tax will reduce the tax payable on the later dealing, and
• WET will be calculated on the GST-exclusive value of wine in most cases.

6.0 Luxury Car Tax Overview

As a result of the introduction of the GST together with the abolition of WST, motor cars in general would fall in price.

Luxury cars, however, would fall in price even more dramatically as they are currently subject to 45% WST on the value above a 'luxury' threshold, as opposed to 22% WST which applies generally. The luxury threshold is specified in Schedule 6 to the Sales Tax (Exemptions and Classifications) Act 1992 as being a taxable value more than 67.1% of the motor vehicle depreciation limit, currently $55,134.

WST is assessed on a taxable value known as the uniform taxable value (UTV), which is a set percentage approved by the Commissioner of Taxation for use in the motor vehicle industry. The UTV is 77.75% of the tax-exclusive recommended retail selling price. The UTV is also relevant for the purposes of the luxury threshold test specified in Schedule 6 to the Sales Tax (Exemptions and Classifications) Act 1992.

The resultant effect of the above WST rules is that luxury motor cars for WST purposes are, broadly, those cars with a recommended retail selling price in excess of $47,581 WST-exclusive, or $55,720 WST-inclusive.

The Government does not believe a dramatic price reduction for luxury cars 'is appropriate'. To ensure, therefore, that luxury cars only fall by about the same amount as a car just below the proposed luxury car tax threshold, the Government proposes to introduce the luxury car tax.(4)

The Rate of LCT is to be 25% calculated on the value of the car above a LCT threshold.

The LCT threshold proposed is a GST-inclusive value equal to the car depreciation limit that applies under Subdivision 42-B of the Income Tax Assessment Act 1997 for the year in which the supply of the car occurs. As mentioned earlier, the car depreciation limit for the 1998-99 financial year is $55,134. This is a departure from that proposed in the Tax Reform Plan, which stated that the LCT threshold would be equal to a GST-inclusive value of $60,000(5).

The LCT proposed is a single stage tax that will be imposed on taxable supplies and importations of luxury cars. It will be in addition to any GST that may be payable, but not levied on the GST-inclusive price. It will be levied on the value of the car after GST has been excluded.

The payment of LCT is to be incorporated into the net amount payable under the GST system, or in the case of importations, paid with customs duty. A system of quoting is designed to avoid LCT becoming payable until the luxury car is sold or imported at the retail level. Generally, a recipient will be entitled to quote if the car supplied to them is expected to be held solely as trading stock.

Unlike the GST, an entity that buys a luxury car in the course or furtherance of an enterprise will not be entitled to an input tax credit for any LCT payable.

Main Provisions

Schedule 1 proposes amendments to modify new Part VI of the TAA as proposed to be inserted by the GST Administration Bill.

Most of the amendments proposed by this Bill merely substitute references to 'GST' or 'GST law' with references to 'indirect tax' or 'indirect tax law'(6). A number of amendments also make substantive changes to the provisions of proposed new Part VI of the TAA.

1.0 Substitution References to 'GST' With 'Indirect Tax'

Paragraphs 1.11 to 1.13 of the Explanatory Memorandum (EM) adequately and succinctly identify the proposed amendments that will extend the scope of proposed new Part VI to cover the WET and the LCT.

1.1 Drafting Errors

Several drafting errors appear to have been made in that non-existent or inappropriate provisions have been referred to in the following provisions of Schedule 1 to this Bill:

• Items 6, 8, 9, 11, 40, 41, 42, and 70
• Each of the definitions to be inserted by item 25
• New paragraph 36(1)(c) and new subsection 36(2) to be substituted by item 37
• The references in each item of the table in new subsection 62(2A) to be inserted by item 66, and
• New subsection 62A(3) to be inserted by item 71.

2.0 Substantive Changes

2.1 Time Limit on Credits and Refunds

New section 36 of the TAA, as proposed to be inserted by the GSTA Bill, provides that entitlements to GST refunds will expire 4 years after the end of the tax period to which they relate unless a claim is notified to the Commissioner of Taxation before that time.

Item 37 proposes to substitute the provision proposed by the GSTA Bill with another version of new section 36 that will also apply the time limit to the refund of overpaid WET and LCT included in the net amount for a tax period, and also ensure that the 4 year time limit will apply to indirect tax refunds attributable to an importation.

2.2 Unpaid Tax

New section 40 of the TAA, as proposed to be inserted by the GSTA Bill, provides for a fixed rate penalty for unpaid GST. New section 48 provides that the Commissioner may remit the penalty if it is fair and reasonable to do so in the circumstances of each particular case.

Item 44 proposes to substitute the provision proposed by the GSTA Bill with another version of new section 40 that will replace the penalty with a general interest charge (GIC) on unpaid indirect taxes.

This will make the penalty treatment for the late payment of indirect taxes consistent with that proposed for other taxes by Taxation Laws Amendment Bill (No. 5) 1998, which was passed by the Senate the week beginning 8 March 1999 and is now awaiting Royal Assent.

Paragraphs 1.19 to 1.24 of the EM explain the GIC in more detail as well as the manner in which it differs from the penalty regime originally proposed.

2.3 Penalty for Failing to Provide Information

New subsection 43(2) of the TAA, as proposed to be inserted by the GSTA Bill, provides for a penalty for failure to provide information (other than information relating to a GST return), when required under the GST law, in relation to a taxable supply or taxable importation.

Item 45 proposes to insert new subsections 43(2A) and 43(2B) to similarly provide for penalties for failure to provide information (other than information relating to a GST return), when required under the WET law and LCT law respectively.

2.4 Penalties Imposed by Indirect Tax Amending Acts

Item 49 proposes to insert new section 46A into the TAA so as to remove liability for an indirect tax penalty which may otherwise be incurred in the 28 day period after an Act amending an indirect tax law receives Royal Assent.

The effect of the provision will be that until the 28^th day after Royal Assent is reached for an Act amending an indirect tax law, a person cannot be guilty of an offence or be liable to a penalty that arises from an infringement of the amended law.

The provision will not affect the liability of any person to pay any tax that is payable as a result of the amended law.

2.5 Reviewable Decisions

The mechanisms and conditions for a person dissatisfied with a taxation decision to object against the decision and, ultimately, to request a review or appeal against the decision are set out in existing Part IVC of the TAA. New Part VI of the TAA, as proposed to be inserted into the TAA by the GSTA Bill, will extend the operation of Part IVC of the TAA to reviewable GST decisions.

Items 65, 66 and 70 will similarly provide for review rights to be extended to cover reviewable wine tax decisions and reviewable indirect tax decisions in addition to reviewable GST decisions.

2.6 Alterations to WET or LCT Laws To Affect Contracts

Item 71 proposes to insert new section 62A into the TAA, which will provide that if a change to the WET law or the LCT law affects the cost of goods in a contract involving a supply or a taxable dealing in those goods, the contract price will be automatically altered by the difference in the tax payable on those goods as a result of the change.

The contract price will not be altered if the contract provides otherwise.

2.6.1 Undesirable Ramifications of Proposed New Section 62A

Proposed new section 62A has the potential to effectively render contracts that may be affected by changes to the WET law or the LCT law open-ended with respect to price, and therefore unacceptable from a commercial perspective.

It would appear that the only way to avoid such problems would be for affected parties to make adequate provision in contracts potentially affected to counter the prospect of new section 62A having any unfavourable impact.

Concluding Comments

1.0 Wine Equalisation Tax

1.1 Volumetric - v - Ad valorem

Following the release of the Government's Tax Reform Plan and the inevitability of the imposition of an additional tax on wine, debate turned to the nature of the tax to be imposed. Should the tax be a 'value-based' or 'volume-based' tax?

This has been the subject of considerable debate both within the industry and between the WFA and Treasury.

The WFA, while recognising that they represent members with divergent interests, came to the conclusion that it would support an ad valorem tax and reject a volumetric tax. The WFA came to this policy position after commissioning independent research by the Centre for International Economic Studies at the University of Adelaide on the implications of alternative wine tax options being considered in the context of tax reform.

The Winegrape Growers' Council of Australia Inc. (WGCA) supports the WFA in rejecting a volumetric tax.(8)

The Vineyards Association of Tasmania Inc. (VAT) opposes an ad valorem based wine tax arguing that 'the ad valorem nature of the proposed WET adversely impacts on the small (less than 500t) regional winery.'(9)

The National Small Wineries Coalition (NSWC) similarly rejects an ad valorem tax and argues for a volumetric tax on the basis that an ad valorem tax increases the price of quality wine and hurts small wineries.(10)

1.2 Rate: Does it reflect revenue neutrality and is it 'locked-in' at 29%?

The WFA recommended that the WET rate be set at a maximum of 24.5 per cent. It concluded that the true WET level for revenue neutrality would be somewhere between 19.6 per cent and 24.5 per cent.(11)

The rate has been set at 29 per cent.

The WFA also stated that the major influence of taxation reform on the Australian wine industry will be the rate of WET applied to wine under the package. The level will be critical for the continued viability and competitiveness of the industry.

The WFA continued to state that 'as long as the rate of the WET is set so that there is no increase in the tax burden on the industry'(12) the industry would accept the additional tax in the short term.

According to the WFA data, it appears that by setting the rate at 29 per cent the tax burden imposed on the industry has increased.

Additionally, there doesn't appear to be anything in the Bill to suggest that the WET will not be increased above 29 per cent, even though the GST will purportedly be locked-in at the rate of 10 per cent.

1.3 WET: Should it be short term - to be removed in the long term?

WET is a distinct tax imposed on the wine industry in addition to the GST. The goal, with respect to indirect taxes, was stated to be a system that taxes a broad range of goods and services at a single low rate.(13) WET will mean, however, that the wine industry will still be subject to a differential tax burden following the introduction of the GST.

The WFA support WET, but only in the short term, and has stated:

The NSWC, WGCA, VAT and The Victorian Wine Grape Growers' Council Inc.(14) all oppose the introduction of a wine tax, arguing strongly for a GST-only tax on wine, based on the Federal Government's own rationale, namely that any new indirect tax (GST) must be simpler and more equitable than the current WST. A new tax should therefore apply equally across all goods and services. Additional taxes are incompatible with these principles.

1.4 Exemption for Small Business for Cellar-door Sales and Promotional Activity?

1.4.1 Cellar-door Sales Exempt?

The WFA recommended that cellar-door sales for small winery producers should be free from WET, although they should be subject to the GST.

Apparently the amount of revenue raised from small operators' cellar-door sales is small in aggregate terms but on an individual basis is particularly important to the viability of small wineries.(15)

Traditionally State governments levied a tax of approximately 15 per cent on alcoholic beverages through State business franchise fees. However, cellar-door sales were not subject to these fees. In 1997, following a High Court decision,(16) the State business franchise fees were considered unconstitutional and the Commonwealth government introduced measures to collect the revenue on behalf of the States. (Hence the WST rate on wine increased from 26 per cent to 41 per cent).

The revenue is returned to the States. All States then apply a 15 per cent rebate to wineries for all wine sold through the cellar-door and have indicated that they will continue this practice after the introduction of GST and WET.(17)

Therefore, as long as the States continue to honour a liquor subsidy scheme to wineries in respect of cellar-door sales the small wineries will generally be in the same position as they are now. (This assumes the rate of 29 per cent does, in fact, reflect a revenue neutral position for the wine industry.) It is unlikely, however, that relying on State based subsidies is the most desirable and least complicated form of effective exemption from WET.

For small wineries to remain in the current position also assumes that potential distortionary effects of the imposition of an additional tax on the industry over and above the GST will not adversely impact on wine sales. The WFA is of the view that the increased burden from the additional level of tax over the GST is likely to have a serious adverse impact on investment and viability in the small winery sector.

1.4.2 Promotional Activity Exempt?

There are some benefits to the wine industry from the introduction of the GST, including the fact that GST will not apply to promotional activity (eg promotions, tastings and samples). WET will, however, apply to such applications for own use.

Currently, as with cellar-door sales, the States rebate 15 per cent to wineries in respect of wine used in promotional activity. The rebate is intended to continue, however, the WFA remain of the view that promotional activity for all wineries should be exempt from WET. Such a position would, they believe, be consistent with the spirit of the Tax Reform Plan.

2.0 Luxury Car Tax

2.1 Rationale for Luxury Car Tax Questionable

One of the problems with the current WST system identified in the Tax Reform Plan was the multiple rate structure; exempt or one of six different tax rates.(18) The goal, with respect to indirect taxes, was stated to be a system that taxes a broad range of goods and services at a single low rate.(19) One of the advantages of the GST was that it would apply only one rate to taxable goods and services.(20)

The indirect tax system proposed includes the GST, the LCT and a Wine Equalisation Tax, introduced at the same time as the LCT. Together, there will be three different tax rates, GST-free supplies and input taxed supplies.

It could be argued that differential rates of tax have potentially distortionary effects, as well as compromise administrative simplicity leading to increased compliance costs.

Furthermore, it could be argued that it is wrong to differentiate between persons on the basis of preferences, as results with multiple rates. In fact, Fact Sheet No: 201 implies that multiple rates are unfair.(21)

3.0 Naming of Wine Equalisation Tax and Luxury Car Tax Bills

Presumably, the titles of the WET and LCT Bills have been used to make it easier for the Parliament to identify those which form part of the Tax Reform Plan package. From a practical perspective however, the titles appear to be unnecessarily lengthy and indeed cumbersome. The words 'A New Tax System' could be deleted from each title without affecting the relevance of the title to the particular piece of legislation.

Endnotes

2. Wine tax law is defined in the A New Tax System (Wine Equalisation Tax) Bill 1999 to mean:

2. Luxury car tax law is defined in the A New Tax System (Luxury Car Tax) Bill 1999 to mean:

4. GST law is defined in the A New Tax System (Goods and Services Tax) Bill 1998 to mean:

5. Costello, P., MP, 1998, Tax Reform: not a new tax, a new tax system, at p 89; Explanatory Memorandum to the A New Tax System (Luxury Car Tax) Bill 1999, at paragraph 1.22 and 5.3.

6. Costello, P., MP, 1998, Tax Reform: not a new tax, a new tax system, at p 89.

7. Indirect tax law is defined in item 5 of this Bill to mean any or these:

8. Senate Select Committee on A New Tax System, Winemakers' Federation of Australia Submission No. 938, at pp 27 to 29.
9. Senate Select Committee on A New Tax System, Winegrape Growers' Council of Australia Inc., Submission No. 880.
   
   'WGCA's policy is one of strong support for the current ad valorem system for the wholesale sales tax be maintained for the WET. The alternative, a volumetric tax based on the volume of alcohol in wine, would have a significant negative impact on the industry as a whole, but particularly the three regions of the Riverland, Riverina and Sunraysia because they produce the vast majority of grapes used for wine at the lower end of the market. The three regions also account for over 60% of all winegrape production in Australia and to destroy the economic viability of these regions would have a disastrous impact on the rest of the winegrape growing areas of Australia.'

10. Senate Select Committee on A New Tax System, Vineyards Association of Tasmania Inc., Submission No. 84, Executive Summary.

11. Senate Select Committee on A New Tax System, National Small Wineries Coalition, Submission No. 1322, Executive Summary.

12. Senate Select Committee on A New Tax System, Winemakers' Federation of Australia Submission No. 938, at p 28.

13. Ibid., p 18.

14. Costello, P., MP, 1998, Tax Reform: not a new tax, a new tax system, at p 77.

15. Refer to endnotes 8, 9 and 10 and to the Senate Select Committee on A New Tax System, Victorian Wine Grape Growers' Council Inc., Submission No. 1359.

16. Senate Select Committee on A New Tax System, Winemakers' Federation of Australia Submission No. 938, at p 39.
17. Ha and Anor v State of New South Wales and Ors 97 ATC 4674.
    
    Held. By Brennan CJ, McHugh, Gummow and Kirby JJ, Dawson, Toohey and Gaudron JJ dissenting, that the licence fees were duties of excise within section 90 of the Constitution and hence were invalid.

18. Senate Select Committee on A New Tax System, Winemakers' Federation of Australia Submission No. 938, at p. 38.

19. Costello, P., MP, 1998, Tax Reform: not a new tax, a new tax system, at p 72.

20. Ibid., p 77.

21. Ibid., p 80.

22. Costello, P., MP, 1998, Tax Reform: not a new tax, a new tax system, Fact Sheet No: 201.

Contact Officer and Copyright Details

Simon Lang
28 April 1999
Bills Digest Service
Information and Research Services

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ISSN 1328-8091
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