IoD Budget Proposals 2014

IoD Selected Priority Tax Proposals for Budget 2014
Focused Budget 2014 Reforms the Coalition Government Can Afford
IoD Budget 2014 Tax Proposals (February, 2014) Stephen Herring, Head of Taxation
Simon Walker, Director General
James Sproule , Chief Economist & Director of Policy
Stephen Herring, Head of Taxation

Our Discussion Agenda
The Institute of Directors welcomes the opportunity provided to us by both HM Government Ministers and Officials to feed in the
perspectives and priorities of our members.
1. Background, framework & timeline
2. Setting the scene for our proposals
3. Key tax policy questions: an overview & summary
4. Messages from IoD “Top-Line” Summary
5. IoD’s Five Priority Short Term Budget Proposals for 2014/15
6. IoD’s Five Medium Term Budget Proposals (6 to10) for Consultation & Introduction in 2015/16
7. Broader Tax Policy Issues
8. Conclusion
IoD Tax Proposals (February, 2014) Stephen Herring, Head of Taxation
2

Background, Framework & Timeline
The Institute of Directors recognises and accepts the imperative for the elimination of the UK’s excessive fiscal deficit but we do not accept
that this ought to be accepted as a reason for delaying authentic tax reforms which:-
 Are advantageous to UK entrepreneurs, UK listed companies and in-bound foreign direct investment
 Can be estimated within reasonable parameters as regards the net cost to the Exchequer
 Do not further complicate the existing overly complex UK tax system for either businesses or individuals
 Wherever possible, simplify – and reduce the cost of - compliance with the UK tax legislation
 Lead to a simpler, flatter tax system with fewer distortions of economic, business or personal decision making
The principal goals of cutting taxation to no more than 35% of national income, capping marginal tax rates at 35% and abolishing the taxation
of transactions, wealth and inheritance remain the Institute of Directors’ vision for a fairer tax system that would secure addition foreign
direct investment for the UK, stronger economic growth, higher levels of employment, and, as a result of these, additional tax revenues to
finance essential public spending.
We recognise, however, that these reforms would not be introduced in a single Finance Bill and it is vital to acknowledge that both short term
and medium term tax reforms must be identified and enacted as milestones on this road. Accordingly, we have divided our proposals into two
sections focussing upon selected short term priorities and more medium term proposals where further consultation with taxpayers and their
representatives would be appropriate. We define these terms on the following basis:-
 Short Term: Capable of enactment as part of the Finance Bill 2014 with fast track consultation processes
 Medium Term: To be enacted by the Finance Bill 2015 immediately post the next General Election after a fuller consultation process
being completed
IoD Tax Proposals (February, 2014) Stephen Herring, Head of Taxation
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IoD Selected Priority Tax Proposals to BIS for Budget 2014 – Setting the Scene
The Institute of Directors (‘IoD’) continues to recognise and welcome the helpful reforms introduced by the Coalition
Government to UK’s burdensome, uncompetitive and excessively complex taxation system. Our members also
welcomed the announcements in the December 2013 Autumn Statement introducing targeted reliefs from business
rates, capping the increase in business rates at two per cent, the abolition of Employer NICs for under 21 basic rate
taxpayers and the cancellation of the proposed 2014 fuel duty increase. We are becoming increasingly concerned,
however, that the momentum for wide ranging business friendly tax reforms could be lost. In particular, there is an
urgent need for further tax reforms, simplifications and reductions focussing upon mid-sized (or, ‘middleweight’)
businesses.
We are convinced that the ten measures we propose here , which would cost the Exchequer under £12 billion, are both
affordable (in 2014/15 and/or 2015/16) and represent authentic reforms which will lead to accelerated economic
growth and improved employment opportunities. We have divided our proposals into two groups. Firstly, those priority
measures focussed upon businesses and their employees which would not require significant consultation before
introduction in 2014/15. Secondly, those measures where consultation with business and other interested parties
would be appropriate and, accordingly ought to be introduced in 2015/16.
The IoD does not support the premise that small businesses, middleweight businesses and listed/multinational
businesses have mutually exclusive needs. Nevertheless, we consider that there is now a priority for reforms which
focus upon middleweight businesses and their executives. Such reforms are a necessary prerequisite if the UK is to
maintain and, indeed, improve its relative standing in comparison to its competitors in Europe, the other G20 members
and the emerging countries. Our proposals, described on the following pages, are underpinned by what our members
tell us to be necessary reforms to simplify taxation and reduce its burden upon the productive economy.
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Key Tax Policy Questions – An Overview & Summary
We consider that the four overarching concepts which ought to drive fiscal policy to be fairness, incentives, simplicity and sustainability.
Fairness
Our proposals highlight areas where the tax burden could become or has already become unfair:-
• Reversal of significant erosion of basic rate tax band
• Aligning tax thresholds to create a more transparent personal taxation system
• Elimination of economically and fiscally undesirable addition rate of income tax
• Legislating to cap direct taxation so that individuals will always retain the greater part of their income and capital
Business Incentives
Our proposals recognise the need to provide broad based incentives across the business spectrum by:-
• Further business rates reliefs
• An option for all entrepreneurial businesses to opt to become tax transparent
• Removing tax distortions impacting business (or personal) decisions
Tax Simplification
It is important to enhance the stated intention to simplify taxation for both businesses and individuals by:-
• Removing complex requirement for entrepreneurial businesses to estimate taxable profits
• Alternative to the complex, unpopular and expensive saving for pensions
Focus on Sustainability & Fiscal Receipts
It is essential that the capacity for taxation in the economy is continually re-assessed and challenged by:-
• Government capital receipts need to be matched by debt reduction, not spending increases
• Taxes raising less than £5 billion ought to be challenged for fundamental reform if they create economic distortions or are expensive
to collect
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Messages from Institute of Directors “Top-Line Survey”
February 2014
The IoD’s membership exceeds 35,000 and principally comprises executive and non-executive directors of entrepreneurial businesses
and listed companies.
We are delighted that well over 1,000 members responded to our detailed questionnaire looking at tax and related measures the
Chancellor ought to consider for his March 2014 Budget.
a) Selection of One Area for a Tax Reduction
b) Selection of One Focussed Tax Reduction Costing c.£5 billion
c) Special Question Focussed Upon Business Rates Reform
d) Our Comments on Survey
e) Selected/Representative Verbatim Comments by Members
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Messages from “Top-Line Survey” in February 2014
a) Selection of One Area for a Tax Reduction
Turning to the questions prompting members to select one focussed tax reduction from the list provided to them:-
• The ‘winners’ prioritised for the Chancellor’s attention, all scoring between 15% & 17% were:-
• increasing the £31,885 basic rate tax band,
• reducing the employers national insurance contribution rate ,and
• increasing the £10,000 annual personal allowance
• More than 10% prioritised:-
• reducing the 45% additional income tax rate a
• the 20% corporation tax rate
• The following attracted less than 10% support to be the first priority for the Chancellor:-
• Freezing business rates,
• Reducing tax on petrol and diesel,
• Reducing tax on business and domestic fuel,
• Reducing the 20% basic rate of income tax,
• Reducing the full 28% rate of capital gains tax
• Increasing the £325,000 inheritance tax threshold
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b) Selection of One Focussed Tax Reduction Costing c.£5 billion
Our third question asked members to prioritise tax reductions, assuming that there was around £5 billion available to the Chancellor:-
• almost 30% favoured an increase in the basic rate tax band from £31,865 to £40,000; by far the highest score
• a further increase in the personal allowance of £1,000 to £11,000 was selected by over 20%
• approximately 15% selected a 5% reduction in the higher rate of income tax to 35%
• the abolition of inheritance tax was prioritised by 12%
• a reduction in the employees national insurance contribution from 12% to 10.5% scored 12%
• relatively few prioritised a 1% reduction in the basic rate of income tax or the abolition of capital gains tax (both below 6%)
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c) Special Question Focussed Upon Business Rates Reform
Our final tax question in the run up to the Budget 2014 concerned specific proposals for (equally costly in broad terms) reforming
business rates:-
• The two proposals with much the most significant support from members were halving the inflationary increase from 2% to 1%
and doubling the existing 100% relief small business cap from £6,000 to £12,000.
• The next most popular approach with our members (17%) would be to use an independent, published sector index to adjust
valuations for each sector and region
• Few favoured extending the 100% small business cap to up to three properties (under 4%)
• Somewhat more favoured increasing the cap for the more favourable business rates multiplier from £18,000 to £35,000 (11%)
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d) Our Comments on Survey
There is clearly ongoing support from business leaders for measured tax cuts which the Chancellor could announce in the March
Budget for implementation in 2014/15 or 2015/16.
In broad terms, business continues to favour broad based cuts in tax rates rather than targeted tax incentives available only to
selected sectors of the economy. So far as business taxation is concerned, we are unsurprised that both business rates reliefs and
further cuts to corporation are scored highly by our members.
Turning to personal taxation, there is an increasing groundswell calling for the Chancellor to reverse the significant cuts to the basic
rate tax band (both in nominal terms and, particularly, in real terms) implemented by both the Coalition Government and its Labour
predecessor.
This is also another tax survey which highlights the unpopularity of inheritance tax which is rightly regarded as a further tax upon
already taxed income and capital which impacts upon the affluent more severely than the mega-wealthy who can safely dispose of
assets during their lifetimes.
Accordingly, three measures which the Chancellor ought to consider as priorities are further business rates relief, increasing the basic
rate tax band and significantly reforming inheritance tax. We consider there is no economic or fiscal reason for the Chancellor to hold
back on such announcements.
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e) Selected/Representative Verbatim Comments by Members
National Insurance
“I think the key issue is that Employer NICs are a tax on employing staff. For investment, development and expansion of SMEs, this needs to be
reduced.”
“People need to be more aware that Employer NICs – the “jobs tax” – is preventing the creation of jobs, and diverting money from salaries to tax.”
“Job creation is the key priority in my view, so reducing the National Insurance Jobs Tax tops my list.”
Tax Simplification
“Given the need for a certain tax-take, the best thing the Chancellor could do is simplify taxation.”
“NICs are just another income tax; why don’t we get real?”
Squeezed Middle
“The middle class have been squeezed the most, increasing the basic rate band to £40,000 would be fairest for most.”
“The squeezed middle class need the basic rate tax band extended urgently.”
“The removal of the personal tax allowance as earnings exceed £100,000 is extremely demotivating. There are many hard-working people earning
just below this figure who will see such a small amount (after tax) of any reward for innovation or enhanced performance that the reward becomes
irrelevant. Not sure how many people understand this extortionate tax band but I know several well paid & educated people who are confused by it.”
Business Rates
“Business rates are not a particularly sensible basis for taxing business in a digital age – the Government should be planning to unwind its
dependence on this tax over the next 10 years.”
Inheritance Tax
“The absurdly low inheritance tax threshold is urgently in need of upward adjustment. As the owner of a small business which I intend to sell before I
die, this really matters. The idea that one should work one’s butt off all one’s life and pay all manner of taxes in the process, and yet be clobbered on
death with another vast bill is a massive disincentive.”
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IoD’s Five Priority Short Term Budget Proposals for 2014/15
Priority #1 - Freeze Business Rates until the 2017 Re-Rating
Priority #2 - Simplify Corporation Tax for Middleweight Business
Priority #3 - Simplify National Insurance Contributions & Align with Income Tax
Priority #4 - Streamline personal and transaction costs with low cost reforms
Priority #5 - Match HM Government Proceeds from Asset Sales with Debt Reductions
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Priority #1 - Freeze Business Rates until the 2017 Re-Rating
Why important?
Our members continue to feed back to us that, in many sectors (including retailing, services and
manufacturing) business rates are becoming an unaffordable cost for entrepreneurial and
middleweight businesses and are discouraging the expansion of existing businesses and the creation
of new businesses.
It cannot be right that the very large number of businesses which will secure lower business rates
after the postponed re-rating should be expected to meet higher business rates in the intervening
years (where the re-rating will highlight that the underlying economic factors justify a reduced rate
being payable). Our members acknowledge and appreciate the Coalition Government’s
announcement in the December 2013 Autumn Statement that the rise in business rates is to be
capped at two per cent in 2114/15 but any increase for a significant number of businesses remains
anomalous and is a bye-product of the government decision to defer the scheduled re-rating.
Our proposal
………is that business rates are frozen until the re-rating is actioned in 2017.
Cost to Exchequer – c £1 billion
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Priority #2 - Simplify Corporation Tax for Middleweight Business
Why important?
We are convinced that there are some ‘quick wins’ in business taxation which the Coalition
Government ought to introduce in Finance Bill 2014 without the need for extensive consultation under
the business taxation roadmap. Our members increasingly comment upon the complexity of business
taxation for ‘plain vanilla’ medium size companies with mainly UK turnover and, perhaps, a modest but
increasing element of export sales.
Our proposals
1. Allow entrepreneurial companies to simplify their tax compliance and reduce compliance costs by
electing to deduct accounting depreciation (under UK GAAP or IFRS) for corporation tax purposes
rather than file capital allowances claims
2. Allow groups to elect to prepare and file a single consolidated tax return and corporation tax
computation
3. Recognise that businesses ought to be able to set off all bona fide realised businesses losses against
their taxable profits by relaxing the existing unduly complex and restrictive tax legislation for loss reliefs
4. Substantially increase the taxable profits threshold for requirement for quarterly payments of
corporation tax from £1.5 million to £25 million to assist cash flow of medium size businesses
Cost to Exchequer – c. £1.5 bn
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Priority #3 - Simplify National Insurance Contributions & Align with Income Tax
Why important?
There is no need for confusing differences between the income tax and national insurance contribution
thresholds and systems which do not deliver fiscal simplicity or fairness. Simplification and alignment
are manifestly overdue.
Our proposals
Merge and align national insurance contributions as follows:-
• Earnings below £10,000 – No Employee/Self Employed NICs payable
• Earnings between £10,000 & £50,000 – Employee/Self Employed NICs due at 12%
• Earnings over £50,000 – No Employee/Self Employed NICs payable
• Class 2 NIC fixed contribution national insurance fixed levy of £2.75 per week - Abolished
Cost to Exchequer – c. £1.5 bn
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Priority #4 - Streamline personal and transaction costs with low cost reforms
Why important?
No opportunity ought to be lost to reform taxes to make them fairer, simpler to administer and reduce the extent to
which taxation distorts economic activity. A valuable consequence of this would be to allow HMRC to focus upon the
administration of major taxes and counteracting tax evasion and abuse.
Our proposals
• Replace the slab/precipice system of stamp duty land tax rates by progressive bands where the advantage of the
lower rate bands is not lost at each trigger point
• Merge Bands C & D into Band B for airline passenger duty, thereby increasing the competiveness of UK airports for key
long haul destinations & simplifying APD into one short haul and one long haul band at cost to Exchequer of <£200m
• Increase the annual capital gains tax exemption to £25,000 enabling HMRC to focus upon challenging, where needed,
the taxation of larger, more tax generative disposals
• Incentivise middle managers by extending the smoothing of the withdrawal of the annual personal allowance for
taxable income above £100,000 to £150,000 (2013/14 - £118,880) to align threshold with that for the additional rate.
Within the new band the effective income tax rate would become 48% (2013/14 - 60%)
• Reduce the CGT rate for all assets to 10%, thereby removing the need for Entrepreneurs Relief
• Align the tax reliefs for enterprise investment schemes (‘EIS’) and venture capital trusts (‘VCT’) so that there is a
merged cap (of £1.25 million) and common qualification criteria providing income tax relief at 40% and full capital
gains tax exemption and inheritance tax business property relief after two years ownership
Cost to Exchequer – c. £4 bn
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Priority #5 - Match HM Government Proceeds from Asset Sales with Debt Reductions
Why important?
We are concerned that the proceeds from future sales of HM Government assets could be diverted
from an equal reduction the United Kingdom’s excessive accumulated government debt to finance
capital projects or, even more damagingly, into financing excessive current account spending by future
governments.
Our proposals
Introduce a Matching Asset Sales & Debt Reduction Bill requiring proceeds from future asset disposals
to be fully utilised to reduce government debt. A provision should be included that this is independently
verified by the Bank of England, National Audit Office and the Office for Budget Responsibility reporting
to the Chief Secretary to the Treasury.
Cost to Exchequer – c. £Nil
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Five Medium Term Budget Proposals for Consultation & Introduction in 2015/16
Priority #6 - Simplify Taxation of Entrepreneurial Companies
Priority #7 - Reform Personal Taxation to Incentivise Middle Earners
Priority #8 - Introduce a flexible alternative, pension savings scheme
Priority #9 - Cap Direct Taxation on Personal Income
Priority #10 - Replace inheritance tax by a capital gains tax upon death
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Priority #6 - Simplify Taxation of Entrepreneurial Companies
Why important?
Understandably, the controlling directors of entrepreneurial companies focus upon the aggregate
tax liabilities arising from their business activities. Accordingly, corporation tax must be considered as
well as the income tax and national insurance liabilities (both employers and employees) arising upon
the business’s profits when distributed by way of remuneration or dividends. The interaction of these
taxes is invariably complex, variable over time and uncertain which both incurs professional fees for
the business and its owners and impacts upon investment decisions. Other developed countries,
notably the United States, allow entrepreneurial companies to elect not to pay corporation tax
provided that the profits are assessed upon the shareholders upon a similar basis to the existing UK
tax treatment of partnerships and limited liability partnerships.
Our proposals
Allow all companies with, say, twenty or fewer individual shareholders to elect to be treated for
taxation purposes as if they were tax transparent partnerships. This proposal would significantly
simplify the taxation of owner-managed companies and reduces their cost base, including
professional fees necessary under the existing system. Companies which distribute a relatively small
percentage of their profits to their shareholders would not be disadvantaged as they would not need
to elect for tax transparency.
Cost to Exchequer - £ Negligible.
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Priority #7 - Reform Personal Taxation to Incentivise Middle Earners
Why important?
Both the previous Labour Government and Coalition Government have
‘raided’ the basic rate tax band in recent years to reduce the cost of the
increase in the personal allowance. In real terms, the reduction is over 20%.
Executives and other employees now suffer an income tax rate of 40%
(plus 2% national insurance) before their incomes exceed twice median
earnings; this is both too high a rate and too low a threshold. It represents a disincentive for aspiring junior managers and
professionals to accept promotions or move jobs and, accordingly, it is damaging to UK plc.
The higher rate income tax payable in 2014/15 is 40% in comparison to:-
• a rate of 25% in the United States up to $87,850 and,
• as the French Ambassador has recently pointed out, “in France people benefit from a 30% tax rate until income reaches
€71,397”
Whilst the IoD believe that the additional (45%) income tax rate is similarly damaging and collects little in additional tax revenue,
we appreciate that the Coalition Government may believe that there are reasons that reducing the additional rate cannot be
prioritised during the remainder of this Parliament. However, we consider there are very strong economic and fiscal grounds to
prioritise an increase in the basic rate tax band.
Our proposals
The basic rate income tax band should be increased (re-instated) to at least £40,000 in 2015/16 (or, preferably, for 2014/15)
Cost to the Exchequer - £[6 ]billion
Tax Year Personal
Allowance
Basic Rate
Tax Band
Tax at 40%
from
2008/09 6,035 34,800 40,835
2009/10 6,475 37,400 43,875
2010/11 6,475 37,400 43,875
2011/12 7,475 35,000 42,475
2012/13 8,105 34,370 42,475
2013/14 9,440 32,010 41,450
2014/15(p) 10,000 31,865 41,865
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Priority #8 - Introduce a flexible alternative, pension savings scheme
Why important?
There is an increasingly groundswell for more flexible pension savings arrangements for employees and
other individuals which are free from the restrictive drawdown rules and any residual requirement to
purchase an inflexible, expensive and poor value pension annuity. Our members are appear to be fully
aligned with this view and would welcome the opportunity to consider alternative savings products
alongside occupational pension schemes, SIPPs and ISAs
Our proposals
An additional individual retirement savings account ought to be introduced which prohibited withdrawals
before age 55 but otherwise offered unfettered and untaxed access based upon the ISA model.
Contributions by employers would be free of national insurance but there would be no income tax savings
for any employee or employer contributions, thereby increasing the Exchequer’s short term and medium
term tax receipts.
In principle, conversions of existing pension funds ought to be allowed, subject to a flat rate conversion
charge paid to HMRC at, say, ten per cent. This would, of course, raise substantial taxation receipts for the
Exchequer which could be channelled into additional broad-based tax cuts.
Cost to Exchequer - £ Negative
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Priority #9 - Cap Direct Taxation on Personal Income
Why important?
The Institute of Directors considers that it is imperative that the United Kingdom seeks to align its personal tax rates with
the more successful global economies rather than focusing exclusively upon its less successful European competitors. The
highest income tax rate in the United States is 39.6%, in Singapore it is 20% and in Hong Kong it is 17%. It is both quite
understandably and perfectly proper that both entrepreneurial companies and global corporations considering foreign
direct investment in the UK calculate the impact of personal taxation upon their key executives and employees. It is far
better that the UK seeks to optimise inbound investment, economic growth and employment opportunities for its citizens
which lead to increased tax revenues than to adhere to misleading and invariably politically driven assertions which have
little or no merit. The additional rate of income tax (now 45%) does not collect additional tax revenues for the Exchequer.
The OBR has already acknowledged in its Forecast Evaluation Report that the then additional rate of 50% collected little,
if any, additional income tax.
Our proposals
• The additional rate should be abolished in 2015/16 (or, preferably, 2014/15) and the authentic case for its abolition
ought to be made by the Coalition Government calling upon the support of business organisations (including the IoD)
and other commentators willing to and capable of making the case for its abolition, and
• To enhance fairness, legislation ought to be introduced such that direct taxation in aggregate cannot exceed 50% of an
individual’s annual income in any tax year as this would mean that the state benefitted more than the individual from
their earnings and investment returns.
Cost to Exchequer - £ Negative
22

Priority #10 - Replace inheritance tax by a capital gains tax upon death
Why important?
The Institute of Directors is disappointed that insufficient progress has been made on tax simplification since
the Coalition Government established the Office of Tax Simplification in July 2010. We do
not, however, consider that this to be a criticism of the valuable work it has undertaken which has resulted
in a number of sensible tax reforms in targeted areas. To achieve substantial tax simplification however, we
consider that the Coalition Government needs to be bolder and look to repeal or merge significant
taxes, thereby removing hundreds of pages of tax law from the statute books.
The area of capital taxation offers ample scope to simplify taxation. The total tax collected by capital gains
tax and inheritance tax is less than £8 billion so any residual risk to the Exchequer is minimal. Our members
have consistently viewed inheritance tax as a tax on already taxed income; a third tier of taxation between
the tax charged upon income and gains and the indirect taxes paid upon consumption.
Our proposals
• Abolish inheritance tax, thereby saving at least 600 pages of tax legislation
• Recognise death as an occasion of charge for CGT upon the difference between the probate value and the
acquisition cost of each asset
• Introduce a CGT exemption (for the year of death only) of £350,000 to mirror the existing IHT exemption
• Apply the same exemptions available at death for IHT purposes to the CGT charge upon death to protect
trading businesses
Cost to Exchequer - < £1 billion
23

Broader Tax Policy Issues
Tax Abuse, Avoidance & Planning
We continue to be disappointed that, with very few exceptions, the Coalition Government, HM Opposition and Parliament
generally are too ready to accuse businesses of undertaking ‘tax avoidance’ without defining what is meant by this term. The IoD
continues to be supportive of appropriately targeted measures to prevent aggressive tax avoidance and, in particular, the
enactment of the GAAR legislation by Finance Act 2013 which provides an additional weapon to HMRC to combat tax abuse.
Unfortunately, such abuse continues to be used as a pretext for attacking businesses which, quite understandably and rightly,
take account of the tax treatment of structures and transactions before deciding upon the implementation of business decisions.
There ought to be more willingness to defend the rights of businesses to consider taxation as a cost of doing business which, like
other costs, needs to be considered and planned. Otherwise, there is a very real danger that the impact of the business friendly
measures introduced by the Coalition Government (such as the controlled foreign company reforms, the patent box legislation
and the finance company legislation) will be significantly eroded by the political climate being viewed as anti-business, thereby
eroding the attractiveness of the UK both to entrepreneurs and for inbound foreign direct investment.
Future of Corporation Tax
We are concerned that the outcome of the OECD/G20 review of ‘BEPS’ (Base Erosion, Profit Sharing) could be damaging to UK
business. We recommend that the Coalition Government considers its response to potential outcomes from these reviews and, in
particular, whether a preferable route, more responsive to the increasing globalisation of trade and e-businesses, would be the
replacement of corporation tax by alternative taxes.
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Conclusion
We are convinced that our ten proposed measures are affordable, consistent with the need to eliminate the structural fiscal
deficit, will accelerate economic growth and employment opportunities and will lead to a fairer, more competitive and simpler
taxation system for both businesses and their managers and owners.
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IoD Budget Proposals 2014

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