Chapter 13
Charitable
and Not For Profit Sectors13.1 In its proposed tax package document released
in August 1998 the Howard Government declared that “charitable activities
will be GST free” and “religious activities will be GST free”.
[1] Rather than providing GST zero rating on an institutional
basis to charities, public benevolent institutions, non-profit community groups
and religious organisations, the Howard Government proposes to draw a line between
the various activities of such organisations based on whether the activity falls
into the category of “charitable/religious” or “commercial”.
13.2 The ANTS package sets out that charities, public benevolent organisations,
religious organisations and community groups operate differently from businesses.
They often do not charge for the goods and services they supply, or impose only
a nominal charge. Much of their funding and inputs are provided as donations.
These charitable activities will be GST-free. Where organisations fall below the
$100,000 registration threshold they may opt not to register, in which case their
memberships will not be taxed [2] and they would not
receive GST input credits. 13.3 The Government's aim in relation to charitable
and not for profit organisations is designed to ensure that perceived unfair competition
with profit-oriented business through the commercial activities of the charitable
organisations be eliminated by rendering the commercial activities of charities
subject to the 10 percent rate of GST. [3] 13.4
Currently commercial activities run by charity organisations are not subject to
taxation and nor do the administrative arrangements of such groups attract FBT
penalties. 13.5 The non-commercial activities of the charity sector will
remain free of the GST, provided they are registered accordingly. 13.6
Needless to say many charitable organisations wrote to the Committee in relation
to the proposed changes and a number appeared before the Committee at public hearings.
13.7 The Royal WA Institute for the Blind expressed the concerns of such
groups when they appeared before the Committee in Perth on 25 February 1999. The
CEO of the Institute Mrs Marjorie Harper told the Committee that as service providers
their concerns were that there would be a reduction in the quality and quantity
of service from agencies like the Institute with the additional impost of GST
and FBT. 13.8 As with other charities the Institute made the point that
they were not opposed to rational reform of the taxation system: We would
like to say up-front that we are not opposed to rational reform. We had no argument
with the recommendations that were made from the 1995 Industry Commission report
in terms of emphasising the need for openness and transparency in the funding
process, particularly as related to FBT and in those days, of course, primarily
wholesale sales tax, and that those benefits should be cashed out. However, we
do have a lot of concerns about the impact now, and we do not believe there has
been adequate cost modelling or investigation into the implications for the not-for-profit
sector. Specifically, we are referring to the disability area. [4]
13.9 The Institute made a number of points regarding the way charities
appear to be regarded currently. They told the Committee that there is a perception
that public benevolent institutions are taking advantage of an exception given
previously in good faith and to the extent that the revenue is seriously disadvantaged.
13.10 The Institute agrees that in isolated incidences this may be the
case and referred to the manner in which large organisations such as universities
and hospitals have restructured their affairs to this effect. The Institute does
not believe that this is common throughout the social services industry however
they do believe that abuse must be addressed in order to protect government revenue.
13.11 The Institute also acknowledged that the exemption from Fringe Benefits
Tax accorded to public benevolent institutions has been shown to work as a defacto
funding source. The concession accorded to FBT has enabled the sector to survive
despite limited funds in a competitive labour market by being able to offer salary
packaging to its officers. 13.12 The solution that the Institute would
like to see put in to place is one that would curtail the excesses while at the
same time maintaining the status quo. In relation to FBT they see the need to
enforce a voluntary standard which has been followed by responsible agencies in
the field where a reasonable limit say 30% is applied to the provision of FBT
exempt packaging. 13.13 The problem confronting the Institute is that as
a not for profit organisation they are not able to charge any sort of fees that
would help them to solve the problem of additional taxing costs. 13.14
In relation to fundraising operations such as bingo, the Institute derives $300,000
a year of net income from that source. That funding they regard as absolutely
crucial to the running of their organisation. As they understand the current legislation
the bingo fundraising will be classified as gaming and GST will be paid on the
gross between the wager or sale of the bingo book and the amount of prize money
paid out. 13.15 The Institute estimates that in the last twelve months
that would have cost in the vicinity of $180,000 of net income. [5]
The Institute also raised the issue of fundraising. They told the Committee that
in the last twelve months they had provided somewhere in the vicinity of 86% of
their gross income from their own sources. They have particular concerns about
the GST in relation to this fundraising. It is their understanding that sponsorship
in this way will attract a GST. 13.16 Another cost impost to the Institute
and other charitable organisations is that currently they are able to buy vehicles
at a saving of 22.5% on the wholesale price. Following implementation of the government's
tax reform package the Institute would be exempt from GST which means that they
will actually get a 10% reduction. However the Institute pointed out that the
12.5% margin that currently exists allows them to trade a vehicle every two years
at little or no additional cost whereas with the 10% saving under the GST there
will be a $2000-$3000 penalty each time a vehicle is traded in. This is an added
burden to the funding available to the Institute. 13.17 The Fundraising
Institute of Australia work for and with the not for profit organisations within
the charitable, medical, arts, educational, religious, community and welfare service
and sporting and social fields in the capacity of consultants providing fundraising
services to such organisations. Many of FIA's members hold senior management positions
within their organisations and assist in raising approximately $5 billion of funds
throughout Australia each year. [6] 13.18 The
best estimates are that about $8 billion are raised by not-for-profit organisations
in Australia each year by way of fundraising. Fundraising is not easily defined,
there is a wide range of definitions of it, but the indications are that we have
a pretty sound basis for saying that about $3 billion is transferred by way of
donation, non-reciprocal transfer, and would be outside of the GST. About $5 billion
comes from a variety of sources. We think $600 to $700 million comes from charitable
gambling products of various sorts, between $800 and $900 million from special
events, benefits and that sort of thing, and between $300 and $400 million from
charitable merchandising. So it is a very large sector of the Australian economy
and represents possibly between eight and 10 per cent of the gross national product
of the economy. [7] 13.19 The Fundraising Institute
raised concerns about administration of the GST and the impacts of its imposition
having an adverse effect on the resources flowing to the not for profit organisations.
The Institute makes the point that the advantage of the GST in the commercial
area is that it replaces the indirect tax base and frees them from the cost of
that. For the not for profit organisations they are already tax exempt and there
is no benefit to them by the removal of the indirect tax base. [8]
13.20 The Institute cited a number of examples of the way they believe
that the imposition of the GST will impact on not for profit organisations. 13.21
Membership fees: will attract a 10% GST which must be added to the cost of membership
and then remitted to the ATO. The consequence of this for the organisation will
be the increase of 10% on fees and any additional compliance costs. 13.22
Sponsorship and cause related marketing: sponsors in most cases will be able to
claim the GST as a rebate and the organisation will retain the value of the sponsorship
less the 10% tax. The issue for the organisation is that the sponsorship is reduced
by 10% of the GST so unless sponsors can be encouraged to donate the original
sum plus the GST which they then claim back the organisation is effectively 10%
worse off. 13.23 Special events: ticket sales for dinner dances, film nights,
concerts etc will attract a 10% GST. 13.24 Large raffles and Art Unions:
will attract a 10% GST not on the ticket cost price but rather on the gross margin
between the total value of tickets sold and the values of the prices paid out.
The issue is that the organisation will be worse off by the 10% GST paid on the
gross margin less any GST paid on its input. 13.25 The major concern of
the Institute is the cost and practicality of compliance. The introduction of
a GST will see these organisations needing to collect an extensive range of additional
accounting information. For example each input purchase will need to be recorded
in terms of the price paid and the GST paid. Each taxable sale will need to be
recorded showing the total receipt value and the value of the GST collected and
the data collected as described above will need to be passed to the level in the
organisation which is the registered GST collector. 13.26 The final point
raised by the Institute is the issue of charitable gambling that is bingo, raffles
etc. Not only will sales tax exemption for prizes be removed to be replaced by
a rebatable 10% GST but a 10% tax on gross profit will be imposed that cannot
be passed on to the ticket buyer. [9] 13.27 A
further consequence of the increased compliance requirements is that volunteer
treasurers for such organisations will face additional pressures. A consequence
of these added compliance requirements is that the Institute believes that the
volunteer roles will ultimately have to be supplanted by professional roles and
the professional roles cost money. That will have a direct cost on the net flow
of those funds to the charitable causes concerned. [10]
13.28 In the submission of the Brotherhood of St Laurence they specifically
addressed the effect on the non profit sector of the proposed tax package. The
Brotherhood supports the general approach taken in the legislation to make activities
GST free when they are undertaken for the public good and where there is a major
public subsidy. The Brotherhood also supports making health, community services,
childcare and public education GST free as well as limiting the fringe benefits
taxation exemptions currently enjoyed by some non government bodies. 13.29
The Brotherhood believes that the legislation will have significant impacts on
the non government sector particularly in its impact on compliance costs and the
consequences of changes to the FBT arrangements. The Brotherhood recommended that
the Senate should seek to improve the legislation to: Provide greater certainty
regarding the making of “commercial” services GST free by replacing
“50% of market value” test with one of “at cost” or “below
market value”; Ensure that all sectors subsidised heavily by government's
are in fact covered by reference to legislation – it appears that some activities
of for example Supported Accommodation Assistance Program funded agencies may
not be; and Recognise and provide for the additional costs of complying
with the FBT and GST legislation. [11] 13.30
The Senate Community Affairs References Committee also received evidence on the
Government's proposed GST package in relation to the impact of the GST package
on the charitable and not for profit sector. This section represents an edited
extract from that Committee's Report. 13.31 All charitable organisations
raised concerns regarding the impact of the Government's tax proposals on the
sector. Of most significance were concerns that the Government's proposals would
undermine the very purpose of charitable organisations: the provision of services
to the Australian people. It was argued that the changes will: - threaten
viability;
- introduce an artificial distinction between commercial and
non-commercial activities;
- significantly reduce funds available for services
through changes to Fringe Benefits Tax concession provisions;
- introduce
significant compliance costs;
- cause cash flow problems;
- impact
on fundraising activities and membership fees; and
- impact on volunteer
workers. [12]
Commercial activities13.32
As has already been stated, the Government's approach is based on the notion that
commercial activities of charities are taxable `to avoid unfair competition with
business'. [13] The Vos Committee considered the criteria
for a `commercial' or `non-commercial' activity and noted that there were two
ways to go: first, `things that are ultimately done in pursuit of a benevolent
end thereby lack a commercial purpose, even if it results in a profit in a commercial
or accounting sense'; and secondly, `the fact that goods are sold or services
provided at a price, as businesses do, creates a commercial activity, notwithstanding
that any profit is ultimately directed not to the proprietors of the business,
but to charitable ends'. [14] 13.33 The Vos
Committee noted that many submissions preferred the former approach: that activities
of charities should be GST-free because the funds raised are returned to the community.
However, Vos stated that the Government's policy `makes it clear that the ultimate
purpose or end of an activity is not the determinant of the commercial/non-commercial
distinction'. The Vos Committee concluded that `when goods and services supplied
by charitable businesses are supplied at commercial rates and are competing against
other businesses, then those goods and services should be subject to GST' and
`where the services provided have no commercial equivalent, then it is appropriate
for them to be GST-free'. [15] 13.34 Herein
lies the major problem. Charities are not like every other organisation, they
may use commercial means to raise funds, but those funds are used to provide community
services. 13.35 Charitable organisations argued that they are now under
threat because of the Government's lack of recognition of the fundamental difference
between non-profit organisations and for-profit organisations. Charitable organisations,
unlike commercial organisations, do not provide a return for an individual or
investors. Under the law, they are required to direct all their funding and any
surpluses to their charitable activities. Commercial activities are not undertaken
for profit-making but to enhance the capacity of the organisation to deliver essential
services. [16] 13.36 Thus, while charities and
commercial businesses may appear to have similar means of operation, they pursue
very different ends. The Church & Charitable Private Hospitals Association
argued that this `basic point has to be understood in order to see the logical
fallacy of a tax or regulatory policy of so-called “competitive neutrality”
between charitable hospitals and profit-making commercial private hospitals or
clinics'. [17] ACOSS concluded `it is not in the public
interest to tax these activities which return all profits to meeting social objectives'.
[18] 13.37 Welfare organisations, including
ACOSS and Mission Australia, also noted income is used to cross-subsidise services
for those people who are unable to pay – this is very different from the
operation of commercial organisations. [19] Anglicare
Australia argued that under the Government's policy: 13.38 The cross subsidisation
of services to the poor by a charity through applying its surplus from one area
of activity to another area that needs additional resources is being equated with
the profits reaped from a commercial activity for the private wealth of an individual.
The values that make a gathering of individuals into a society and a community
are lost in this narrow economic approach. [20] 13.39
It was also argued that charities provide essential services because of market
failure. The commercial sector has not been able or willing to meet the needs
to the community. [21] Uniting Community Services Australia
stated: To assume charitable activities primarily compete for market share
is fallacious. Services provided by charities are generally those that do not
generate a profit but address market failure and meeting of the needs of disadvantaged
people. [22] 13.40 Unfortunately, Treasury seems
to understand the profit motive and privatization but does not seem to understand
mutuality, altruism or charity. It does not seem to understand that they are non-government
institutions such as charities that exist to raise resources in order to meet
the needs of the poor or the sick. To suggest that such organisations should be
taxed in the same way as profit-making trading corporations is illogical. 13.41
The Society of St Vincent de Paul noted that in the last two years its workload
had increased 30 per cent while Government financial support had decreased 16
per cent. [23] One volunteer from Adelaide Day Centre
for the Homeless stated: At the day centre, the number of emergency food
parcels requested has trebled in recent years and the number of people receiving
assistance at the winter soup kitchen has increased by a corresponding figure.
[24] 13.42 The only way organisations can meet
the demand for services is to seek other avenues of fundraising – often of
a more commercial nature. [25] 13.43 It was
also argued that moves into the commercial area are linked to government policies
of competitive tendering and contracting. [26] This
sector has been required to become more `commercial' in order to qualify for government
assistance. Now it will be penalised for it. 13.44 Wesley Mission also
noted that many activities, which the Government believes are commercial activities,
had been initiated by the Church and business has moved into that market: 13.45
Therefore, whilst you are saying we are moving more towards the business sector,
in fact what has happened is that they have intruded into an area that we have
had as our sole domain for many years. For example, the clothing recycling business
was started by the churches. Hospitals and most of the welfare services that are
provided in the community today were initiated by the church, way back in its
history, and many other for-profit operators are now emerging. If that is true,
surely the penalty should be on those who are intruding into an area that we are
[in]. [27] 13.46 It was argued that the Government
has failed to understand the fundamental difference between the end use of surpluses
in the charitable sector and the business sector. In the past, this has been recognised
by Government: charitable organisations have been exempted from paying income
tax and other taxes. Charitable organisations questioned the reason for the Government's
philosophical shift and pointed out the costs to the organisations themselves,
and the adverse impact on the community of the proposed tax changes, would be
high. [28] 13.47 A further matter raised with
the Committee was problems with the definition of `nominal' consideration that
is to be adopted in the tax package. Uniting Community Services Australian (UCSA)
argued that: The proposed definition of non-taxable activities of charitable
organisations is predicated on the ill conceived notion that the difference between
charitable and commercial enterprises is related to the price charged. [29]
13.48 Other witnesses pointed to practical problems. It was argued that
determining the market price of a service will be a complex question, `as it is
largely a subjective determination'. [30] Where there
is no for-profit provider of the good or service the Committee was told that it
was unclear how the market price would be determined. It was also argued that
the uncertainty surrounding these issues is likely to lead to considerable compliance
costs for organisations in obtaining rulings from the ATO. [31]
13.49 The Surf Life Savers stated: This will require the Organisations
to constantly monitor the market in terms of prices charged for goods and services
and to ensure staff and volunteers are informed of this data across all products
and services. We submit that these tasks will be unnecessarily burdensome and
costly and will absorb significant financial resources that would otherwise be
devoted to provision of the Organisation's core community services. [32]
13.50 Arthur Andersen submitted that this aspect of the package is: particularly
onerous as charities will be required to monitor their costs and pricing to ensure
that any given supply is GST-free. Similarly, this effective pricing ceiling does
little to ensure the financial viability of Australia's charitable community.
The Vos Committee received numerous submissions in relation to the equity issues
of imposing GST on supplies by charities to people in need and the financial impact
on charities' ability to provide these services. The Government's response to
the Committee's recommendation is not adequate. [33]
13.51 Financial implications for charitable organisations 13.52
Organisations indicated their concerns about the cost of the proposed imposition
of the GST on commercial activities. For example: Surf Life Saving estimated
revenue loss to all member groups across Australia will be in the order of $3
million; [34] 13.53 The Spastic Centre of NSW
estimated direct costs associated with the GST on commercial activities were estimated
to be in excess of $500,000 per annum and it would have no choice but to close
business services operated by people with disabilities; [35]
13.54 Wesley Central Mission estimated its income will be reduced on its
printing business by $200,000. [36] 13.55 Organisations
will have to decide whether: to pass on the added cost of the GST onto clients,
who in many cases are unable to pay more; to absorb the costs of the GST; or lower
costs to below 50 per cent of the commercial rate and thereby risk the organisation's
long-term financial viability; or to cut the service completely. Charitable organisations
will find it difficult to implement any of these options. 13.56 However,
if organisations do have to cut services, it is clear that Government would have
to step in and provide additional services or funding. This will have major expenditure
implications for future federal budgets. [37] Compliance
Costs13.57 The issue of compliance costs is a major concern. It was argued
that these will exacerbate the difficulties of providing services to the community.
13.58 The Government stated that: GST will remove the impact of
indirect taxes on charities. Industry cost reductions will result in lower operating
costs for these bodies. They will also benefit from the GST-free treatment of
their non-commercial supplies of goods or services. All GST participants who are
in a net refund position will be able to choose a monthly tax period and thereby
get a refund at the beginning of the next month. [38]
13.59 Witnesses argued that there will be significant compliance costs
for charitable organisations. It was pointed out that charitable organisations
would not benefit from the removal of indirect taxes as they are, at the present
time, largely exempt from indirect taxes. [39] For
example, many are exempt from income tax, payroll tax, sales tax and fringe benefits
tax. 13.60 Operating costs will also increase because organisations will
need to establish new accounting systems. It was also argued that far from benefiting
from the GST-free treatment of non-commercial supplies of goods and services,
organisations will face complex accounting procedures where a mix of commercial
and non-commercial activities are undertaken. The Church & Charitable Private
Hospitals Association concluded: We are not-for-profit institutions who
do not pay taxes now and are being asked to pay taxes in the future. Our costs
will go up, both in the payment of taxes and in the administrative cost in collecting
those taxes. They will also go up in the fact that we have to collect the money
before it is refunded. We will have to fund, up front, a lot of money. It is putting
a penalty on not-for-profit hospitals. That is clear, unequivocal and a fact.
[40] 13.61 It was argued that the administration
of the GST for registered non-profit organisations would be more complex than
for some for-profit businesses. Non-profit organisations will have to deal with
a mix of activities and tax treatments: some activities will attract GST, some
are GST-free and some are input taxed. [41] ACOSS noted
that `this was the case in New Zealand, where “partially rated” organisations
face compliance costs on average 10 % higher than business, due to the difficulty
of separating out their activities into different categories'. [42]
13.62 Organisations indicated that the compliance costs under the tax changes
would include: - new accounting systems for recording GST payments
and input tax credits;
- upgrading present computing systems;
- revenue
collection systems needed to identify GST amounts invoiced;
- payment systems
needed to identify and record GST amounts paid;
- establishing what supply
of goods and services are GST-free and which are liable for GST;
- establishing
procedures to assess 50 per cent rule applying to non-commercial goods and services;
- increased budgets to cover the cost differential between purchase prices
of goods which will increase following the GST relative to their present cost
with WST exemption;
- identification and payment of FBT liabilities;
- increased
wage costs due to new FBT requirements;
- training of accounting staff;
- potential need to employ additional staff to deal with extra tasks associated
with compliance;
- increased costs for equipment and motor vehicle insurance
since premiums are based on replacement cost (which will arise given effect of
the price differential between WST and GST); and
- fund the amount of GST
input taxes paid until reimbursed. [43]
13.63
The Government acknowledged that there will be costs with the new tax regime.
DFaCS stated: It is expected that organisations will have administrative
costs associated with registering, and in some cases have to lodge tax returns
for the first time. To assist in the transition, the Prime Minister has stated
that charities will also be able to access a $500 million fund set up to assist
in the implementation of the tax reform. [44] 13.64
Those organisations not registered do not have access to the $500 million assistance
package for small business. [45] 13.65 Concern
was expressed that the Government had not made it clear how the $500 million will
be distributed. Further, it was considered that the compliance costs for non-profit
organisations would far exceed that which the Government had estimated. Organisations
pointed out that, unlike for-profit organisations, they currently do not have
to deal with many taxes and will have to introduce new systems because of the
tax changes. For profit organisations also have professional accounting personnel,
while many charitable organisations rely on volunteers. Compliance costs for training
will be high, especially for organisations reliant on volunteer workers. 13.66
The Australian Catholic Social Welfare Commission noted that the Government, in
its impact statement, had estimated that the gross compliance costs of the GST
at $1,195 per firm. It stated that `this figure is contested as a gross underestimate
of the true costs to those organisations with no existing WST collection system.
The compliance costs figures have been based on businesses with recurrent costs'.
[46] Arthur Andersen, for the Australian Catholic Health
Care Association (ACHCA), calculated that the total transition and compliance
costs for the Catholic health and aged care sector will be approximately $29 million.
ACHACA noted that it is difficult to present highly accurate estimates of compliance
costs but the costs are `higher than we would expect for a fully commercial operation
of a similar size'. [47] 13.67 Other organisations
also indicated that compliance costs would be high. Catholic Social Services stated
that its agencies estimated compliance costs to range between $6,000 and $80,000
per agency depending on the size and complexity of the organisation. [48]
St Vincent de Paul estimated its compliance at $2-$4 million. [49]
The Council for Homeless Persons Australia estimated that SAAP services would
require $6 million for one off establishment and transitional costs. [50]
13.68 Many organisations were concerned that they relied on volunteers,
including Honorary Treasurers, with only a small number of paid staff. It was
argued that many volunteers will be poorly equipped to handle the requirements
of the proposed tax system and extensive training would be required. [51]
The Queensland Country Women's Association, for example, indicated that its volunteers
ranged in age from 13 years to 80 plus and that members were still using the same
methods of handling paper work handed down from 76 years ago. [52]
13.69 Surf Life Saving stated: Coping with this burden will present
major problems for the Organisations. In most cases, the volunteers on which we
rely do not have the necessary level of skill and expertise to carry out the compliance
tasks adequately. They want to deliver first aid and safety services to those
in need in the field, not do accounting tasks in the “back room”. It
will take a major effort in training volunteers on the intricacies of the GST,
and will involve high upfront costs in implementing appropriate accounting systems.
[53] 13.70 Evidence from charitable organisations
argued that cash flow problems will be exacerbated by the introduction of the
tax proposals. Many told the Committee that they ran on very tight budgets. While
input tax credits will be claimable, the time lag between reimbursement and the
initial outlay will impose on many organisations a serious cash flow situation.
Organisations will have to find the financial resources to carry those costs.
Funds may have to be diverted from welfare activities. [54]
13.71 The Motor Neurone Disease Association of Victoria estimated, with
the GST and a recovery period of three-monthly claims and a four week turn around,
the organisation will require an additional up-front $15,683 for recurrent expenditure
on an expenditure budget of $475,255. [55] 13.72
Accountants also believed the compliance costs would be substantial. Arthur Andersen
concurred with the evidence to the Committee from charitable organisations and
stated that most GST taxpayers `will be saddled with a substantial compliance
burden but will contribute no net GST revenue'. [56]
The Committee considers that charitable organisations face high compliance costs.
13.73 Another accountant went so far as to state `this is all going to
mean a lot more accountants being able to take early retirement on the Gold Coast'.
[57] 13.74 Unregistered organisations (ie those
with annual sales of less than $100,000) will be GST-free. However, they will
be unable to claim input tax credits. Thus, they must bear the costs of the tax
inputs, while at the same time they lose their traditional input tax exemptions.
This is bound to result in price increases or loss of services. Organisations
may, of course, choose to register and so recover the input tax. However, in doing
so they will take on added costs of compliance and have to add the GST to the
costs of commercial goods and services. Either of these options has cost implications
for small organisations.
Footnotes[1]
ANTS p.95. [2] ANTS, p.95. [3]
ANTS, p.95. [4] Evidence, p.1267. [5]
Evidence, p.1270. [6] Submission No. 800. [7]
Evidence, pp 1528-29. [8] Evidence, p.1529. [9]
Submission No. 800. [10] Evidence, p.1530. [11]
Submission No. 848. [12] See for example Submission
No 68B, p.11 (ACOSS), Submission No.606, p.15 (ACROD), Submission No.624, p.10
(Anglicare), Submission No.738, p.1 (Port Adelaide Central Mission), Submission
No.765, p.1 (Lutheran Community Care), Submission No.922, p.3 (SACOSS), Submission
No.1028, p.3 (Spastic Centre of NSW). [13] ANTS,
p.95. [14] Vos Report, pp.67-8. [15]
Vos Report, p.68. [16] Submission No.68B, p.11
(ACOSS), Submission No.935, p.8 (UCSA). [17]
Submission No.668, p.2 (Church & Charitable Private Hospitals Associations).
[18] Submission No.68B, p.11 (ACOSS). [19]
Submission No.68B, p.11 (ACOSS), Submission No.681, p.2 (Mission Australia), see
also Submission No. 611, p.11, (YWCA of Australia), Submission No.640, p.3 (NCOSS).
[20] Submission No.624, p.9 (Anglicare Australia).
[21] See for example, Submission No.364, p.12
(Aged Care Australia). [22] Submission No.935,
p.8 (UCSA). [23] Submission No.300, p.41 (Society
of St Vincent de Paul). [24] Committee Hansard,
24.2.99, p.940. [25] Submission No.929, p.11
(Catholic Social Services). [26] Submission No.935,
p.8 (UCSA). Submission No.1028, p.5 (The Spastic Centre of NSW). [27]
Committee Hansard, 10.2.99, p.617 (Wesley Mission). [28]
See for example, Submission No.68B, pp.10-11 (ACOSS), Submission No.300, p.41
(St Vincent de Paul), Submission No.606, p.5 (ACROD), Submission No.866, p.6 (Adelaide
Central Mission). [29] Submission No.935, p.9
(UCSA). [30] Submission No.68B, p.12 (ACOSS).
[31] Submission No.992, p.5 (Tax Reform and Community
Sector Alliance), Submission No.364, p.16 (Aged Care Australia). [32]
Submission No.452, p.12 (Royal Life Saving Society, Surf Life Saving Australia,
St John Ambulance). [33] Submission No.927, p.9
(Arthur Andersen). [34] Submission No.452, p.9
(Royal Life Saving Society, Surf Life Saving Australia, St John Ambulance). [35]
Submission No.1028, p.6 (The Spastic Centre of NSW). [36]
Submission No.896, p.5 (Wesley Central Mission). [37]
Submission No.344, p.4 (Deafness Forum of Australia), Submission No.784, p.5 (Council
for Homeless People Australia), Submission No.1028, p.6 (The Spastic Centre of
NSW). [38] Regulation Impact Statement for
the Introduction of a Goods and Services Tax, p.4. [39]
Submission No.611, p.11 (YWCA of Australia), Submission No.615, p.2 (Youth &
Family Services Logan City), Submission No.848, p.32 (Brotherhood of St Laurence).
[40] Committee Hansard, 11.2.99, p.727
(Church & Charitable Private Hospitals Association). [41]
Submission No.848, p.32 (Brotherhood of St Laurence). [42]
Submission No.68B, p.13 (ACOSS). [43] Submission
No.1034, pp.26-7 (Australian Catholic Social Welfare Commission), Submission No.866,
p.9 (Adelaide Central Mission), Submission No.1053, p.2 (Baptist Community Services).
[44] Submission No.603, p.10 (DFaCS). [45]
Committee Hansard, p.111 (DFaCS). [46]
Submission No.1034, p.26 (Australian Catholic Social Welfare Commission). [47]
Submission No.683A, p.2; Attachment p.30 (ACHCA). [48]
Submission No.929, p.19 (Catholic Social Services). [49]
Submission No.300, p.43 (St Vincent de Paul). [50]
Submission No.783, p.14 (Council for Homeless Persons Australia). [51]
Submission No.642, p.7 (Lifeline Australia), Submission No.1305, p.2 (Volunteering
SA) [52] Submission No.1371, p.3 (Queensland
Country Women's Association). [53] Submission
No.452, p.11 (Royal Life Saving Society, Surf Life Saving Australia, St John Ambulance
Australia). [54] See for example, Submission
No.610. p.12 (YWCA of Canberra), Submission No.906, p.2 (Association of Major
Community Organisations of SA), Submission No.922, p.3 (SACOSS), Submission No.925,
p.4 (Council of DSC Funded Agencies). [55] Submission
No.772, p.3 (Palliative Care Victoria). [56]
Submission No.927, p.1 (Arthur Andersen). [57]
The Canberra Times, 22.3.99, p.21.
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