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GST: The International Experience piece      

The Government released its draft white paper and goods and services tax (GST). The draft proposes a dual rate structure which separates central and state rates. However, there are no dates mentioned on the implementation nor is any timeline or rates specified in that white paper.



 

Patrick Walker, Head-Indirect Tax, PwC UK shares his comments on GST:

What I have been asked to do here today is to give you some insights based on working with territories that have had GST in place for many years and also working in some territories to actually implement GST. But I wanted to first of all share with you an insight that I had over the last couple of days is that this is my first ever visit to India and it has been fascinating experience. An insight that came to me was that the term to describe India as an emerging economy really doesn’t do it justice. We see what Dr. Rajan has said in his key note in his key economic speech, we have a country here with some significant global corporations, we have a country here with a significant economy and we have a country that is growing or aspiring to grow at a rated 9-10-11-12% and you compare that with some of the established economies which are aspiring to grow 1%-2%-3%, so my insight is that you should describe India as an overtaking economy, not an emerging economy.

That insight came to me when I was in a Taxi in Mumbai and the driver took the term overtaking right through his driving technique, so that was how it came to me but I think that is very appropriate. So What I want to do is just cover three things, give you some reflections on how GST has been implemented in other territories, try and pickup some of the learning experience from the implementation process and then give you some messages about opportunity because its easy to think about the implementation of GST as a challenge as something to go through but really there are significant opportunities to seize if you know where to look and you know how to go about it and by drawing about experiences of other territories you can really go ahead of them here .

So, India is implementing a dual GST system, now GST as much as tax can be described as popular, GST is a very popular tax, its now in place in over 150 countries worldwide, but if you look around the world, not many countries have gone for a dual GST system. GST is popular with tax authorities because it has relatively low collection costs, relatively easy to administer, the reason for that is that most of the costs of collection rest with the businesses and not with the tax authorities, but its also relatively easy to predict in terms of revenue experience, if you look at the impact of the global financial crisis across the world for the last year or so, business profitability is down and so corporate tax revenues have gone down, asset prices have declined and so capital gains taxes have declined, so the advantage of a GST is that a consistent, predictable revenue stream and that is why its popular and yet only two other countries have gone for a dual GST model. Of the major nations, Brazil and Canada are the ones that spring to mind. Canada has got a smaller number of provinces or states than India and it has got a lower combined GST rate around 13% compared with your 16%, one of the interesting things going for a dual model, you do away with some of the simplicities of administration, you have got two taxation authorities administering the tax in two different areas so it puts compliance costs up. Canada has actually addressed this by gradually moving so although they have a dual GST system in three of the provinces now moving to five in 2010, they will have the federal authority administer even the local provincial GST as well and that is one way of simplifying the administration. I have to say that when Canada implemented GST, they said this was the temporary process the dual GST system, they are going to be evolved to a single harmonized GST, nearly 20 years later they haven’t achieved that. So I don’t know about any comments being made in India about eventually moving it but I think that will be some time.

Brazil I have to skip over I have to say its not a highly regarded market to GST terms, a very complex system, multiple rates and very weak tax administration both at state and central levels and therefore if you have to look for inspiration and guidance I would certainly not be looking at Brazil as my model.

I could have drawn on two particular territories, back down I was brought up UK and I started my career on GST in the UK and then I have worked in Australia. The UK implemented GST in 1973 and however old I may look, I was actually only ten at that time, so its very difficult for me to give some insights in the UK implementation experience. Australia implemented in July 2000 so I think that is more relevant to give you some insights the way the Australian’s have implemented it. Australia is a similarly huge country geographically to India but as my taxi driver pointed out to me yesterday the total population of Australia is only just around the same as Mumbai that is about 20 million, so a big geographical expanse, many states but a relatively small population. What Australia did is that they have implemented a system where the revenue does go to the states because it replaces the number of indirect taxes that were state leveled but its administered and collected by one single authority in the Australian tax office and that’s better further consistency, it reduces compliance costs and reduces complexities.

Source : Moneycontrol.com, India, dated 14/11/2009

 

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