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Australia has undertaken a major reform of business taxation, the The New Business Tax System (NBTS), aimed at making the system simpler and more consistent, broadening the tax base and introducing a more internationally competitive rate of company tax. The reform process commenced with the establishment of a Review of Business Taxation (the Ralph Committee), which conducted an extensive review and delivered its final report July 1999.

Fuel type Energy content

(petrol, diesel, biodiesel, GTL diesel) Above 30 38.143 19.1 (biodiesel)

Mid-energy content fuels

(e.g., LPG, LNG, ethanol, dimethyl ether) 20-30 25 12.5 (LPG, ethanol, LNG)

Low-energy content fuels (e.g., methanol) Below 20 17 8.5 (methanol)

Other (e.g., CNG) 38-41 megajoules

High-energy content fuels 0 0 0 0 0 3.8 7.6 11.4 15.3 19.1

Mid-energy content fuels 0 0 0 0 0 2.5 5.0 7.5 10.0 12.5

Low-energy content fuels 0 0 0 0 0 1.7 3.4 5.1 6.8 8.5

Other 0 0 0 0 0 3.8 7.6 11.4 15.2 19.0

The Ralph Committee identified a number of concerns with the previous system, including that it was seen to be complex, unstable and inconsistent and that investment decisions were taken more on the basis of tax-preferred status than economic worth, generating a bias towards investments with low pre-tax returns. The main reason for these concerns was an inconsistent treatment of business entities (companies, trusts and life insurers) and an inconsistent treatment of amortisation of physical assets and changing value of financial assets and liabilities.

The Government delivered its response to the Ralph Committee’s recommendations in September 1999 announcing a broadly revenue neutral package of reforms, combining reductions in the tax rate with base-broadening initiatives. The reforms have been implemented in several steps, starting in September 1999.

The statutory company tax rate was reduced from 36 per cent to 34 per cent for 2000-01 and further to 30 per cent from 2001-02 onwards.

The main base broadening initiative was the removal of accelerated depreciation and balancing charge offset, replacing it by effective life depreciation and allowing a write-off for indefeasible rights of use. Under the effective life system, taxpayers will now be able to reassess the effective life of an asset if it is expected to have a shorter effective life than originally anticipated. Simplified depreciation arrangements were introduced for small businesses that elect to join the simplified taxation system (see below). These arrangements offered small businesses an exemption from the effective life system by introducing a pooling arrangement for depreciable assets valued A$ 1 000 and over. In addition, a pooling arrangement of low value depreciable assets was introduced. In 2001 a Uniform Capital Allowance System replaced the many amortisation regimes in the previous system, a simplification of the tax law which is expected to reduce compliance costs. This system does not apply to small businesses that elect to participate in the Simplified Tax System.

There have also been a number of changes to the treatment of taxpayer entities.

In 2002 a consolidation regime was established, which allows groups of wholly-owned companies to be treated as a single taxpayer entity. The tax base for life insurers has been broadened.

The Ralph Committee also recommended changes to taxation of financial arrangements to remove anomalies, distortions and gaps in the existing tax treatment of such arrangements (debt/equity borderlines, foreign currency gains and losses, commodity hedges etc.). Some of these changes have already been implemented and it is proposed that the remaining reforms will be implemented by 2004.

The Government has also introduced a number of integrity measures in order to contribute to the fairness and equity of the tax system, and to increase tax compliance.

This includes limiting the extent to which non-commercial losses can be used to reduce tax paid on other income, restricting the ability of individuals to reduce tax by diverting the income they earn from their personal services to an entity and other measures relating to prepayments, losses and lease assignments, loss duplication and value shifting. New thin capitalisation arrangements have been introduced to prevent multi-national companies allocating a disproportionate amount of debt to their Australian operations. The Government is also considering measures that will streamline the general anti-avoidance rule in the income tax legislation.

The Government established a non-statutory Board of Taxation, in August 2000, to advise on the development and implementation of taxation legislation as well as the ongoing operation of the tax system. The Government also established an Inspector-General of Taxation in 2003 to provide an independent source of advice to the Government on systemic problems with the tax administration system.

In the 2003-04 Budget the Government announced the outcome of a review of Australia’s international tax arrangements. The aim of the reform is to improve the offshore competitiveness of Australian companies, by reducing Australian taxation of foreign “active”

business income. They will also reduce the costs of complying with the controlled foreign company (CFC) rules and the compliance costs of Australian based managed funds, and revise Australia’s tax treaty practice. The major reforms arising from the review include:

● Simplifying the application of the CFC rules and better targeting the foreign investment fund (FIF) rules.

● Providing an across-the-board exemption for foreign non-portfolio dividends received by Australian resident companies, and a CGT exemption for the sale of certain non-portfolio interests in non-resident companies.

● Moving towards a more residence-based treaty negotiation policy, further aligning Australia’s treaty practice with the OECD Model Tax Convention.

2.4.1. Simplified tax system for small business

In order to reduce compliance costs, a Simplified Tax System for small business was introduced in 2001. The system applies to businesses with a three-year annual average turnover of less than A$ 1 million. About 95 per cent of all active small businesses will benefit from the system.

The main features of the system are:

● A cash accounting regime as an alternative to an accruals system.

● A simplified depreciation regime, including access to accelerated depreciation for assets with an effective life of less than 25 years and immediate write-off for assets costing less than A$ 1 000. Under this regime all eligible assets will be pooled and the pool will be depreciated at a declining balance rate of 30 per cent.

● A simplified trading stock regime, as an alternative to an annual requirement for stocktaking and stock valuation.

In order to ensure that large businesses do not divide their operations into several small units to gain access to this regime, certain grouping provisions apply.

2.4.2. The taxation of capital gains and dividends

In order to improve the operation of the Australian capital markets, the Government reformed the taxation of capital gains and dividends as part of the NBTS.

The capital gains tax was substantially reformed commencing from 1999. The new system of taxing capital gains operates by including 50 per cent of the nominal value of realised gains on assets held more than a year by individual taxpayers 2/3 for superannuation funds) in their assessable income. This replaced the previous system which taxed the full value of the gains on assets in excess of the rate of inflation was included in assessable income, subject to a 5 year averaging arrangement. Under the new system, the maximum rate of capital gains tax is 24.25 per cent for individuals and 10 per cent for superannuation funds.

The new capital gains tax arrangements include special provisions for small businesses. These include:

● a 50 per cent general capital gains exclusion for all active assets in addition to the general 50 per cent exemption (meaning that only 25 per cent of the capital gain is taxed);

● a full exemption from capital gains tax on the disposal of a business asset which has been held continuously for 15 years and where the taxpayer is at least 55 years of age and intends to retire or is incapacitated; and

● special concessions in the capital gains tax for venture capital and scrip-for-scrip rollovers.

The tax reforms included changes to the taxation of dividends received by individuals and superannuation (pension) funds by allowing refunds of unused franking credits.

In 2002, the Government introduced further measures to simplify the way the imputation system is applied by companies, although they did not change the tax treatment of dividends received by individuals.