Tax Policies towards Charities and the Financial Sector
Submitting Institution
University of WarwickUnit of Assessment
Economics and EconometricsSummary Impact Type
EconomicResearch Subject Area(s)
Economics: Applied Economics
Commerce, Management, Tourism and Services: Accounting, Auditing and Accountability
Studies In Human Society: Policy and Administration
Summary of the impact
Professors Kimberley Scharf and Benjamin Lockwood have influenced public
and policy debate leading to tax policy changes in the UK and EU. Scharf
estimated the impact of proposed reforms to the UK Gift Aid program,
research that improved public understanding, led to the creation of an
open discussion forum for affected parties, and shaped NGO/charity
campaigns. Lockwood estimated the tax effects of removing VAT exemption
from firms offering financial services in the EU. The methods developed
were adopted by EU analysts and underpinned EU estimates of the tax
advantages enjoyed by the sector, leading to the 2011-12 imposition of a
Financial Transactions Tax within 11 EU member states from 2014.
Underpinning research
Charitable organisations have long enjoyed tax exemptions, since
charitable activities substitute for government services, generating a
public benefit and relieving the public purse. Professor Scharf's early
research provided a critical assessment of the tax treatment of charitable
donations in Canada (CPRN, 1997), showing how tax incentives for giving
can be used by a low-income majority to shift the burden of public good
provision towards higher-income minorities (2000, JPubEcon), and how their
presence can promote economic segregation along income lines (2007,
JPubEcon).
UK income tax relief for donations was introduced in 2000 with the Gift
Aid scheme. It has since become the largest source of tax relief for
charitable activities. Gift Aid grants tax relief both in the form of a
`match' that is paid directly to charities and, for high-rate taxpayers,
and as a tax rebate for a portion of the tax due on the value of the
donation.
Initially it was assumed that the match and the rebate would provide
equivalent incentives for giving decisions, but in 2007 HMRC commissioned
Professor Scharf and Professor Sarah Smith (Bristol University) to measure
how giving might vary with changes in Gift Aid rules and report on
alternatives for Gift Aid reform. This research found that the "price
elasticity of giving" for the UK was in line with corresponding US
estimates where the rebate component of Gift Aid was concerned, but was
significantly higher for the match component. This implied that a shift in
the delivery of tax relief from one method to the other may have sizeable
effects on the volume of private donations. It also implied that
reallocating one pound from funding public provision to funding tax relief
could raise the combined volume of public and private provision if that
relief was delivered in the form of a match rather than a rebate.
The financial services sector has also enjoyed special tax treatment, via
an exemption from Value Added Tax (VAT). The exemption was granted largely
for practical reasons: since roughly two- thirds of all financial services
earn profit based on a margin (e.g. a bid-ask spread) rather than a posted
price, it is more difficult to implement the invoice-credit system of VAT
collection. The industry benefits from not having to charge VAT to its
ultimate customers, but suffers from not being able to claim tax relief
for the VAT it pays on inputs, so-called `Stuck VAT'. Following the 2008
financial crisis, policy-makers began to question the merits of VAT
exemption of financial services.
In an influential 2010 paper in Fiscal Studies, de la Feria and
Lockwood (2010) use OECD input-output data to estimate Stuck VAT for the
financial services sector in six EU countries, finding it accounted for
between 0.4 and 1.5% of sector tax revenue. In 2011,
PricewaterhouseCoopers asked Lockwood to extend his analysis of a
financial service sector VAT to 26 EU countries, to a time frame of 2000
to 2007, and to estimate the tax revenue gains and thus the net effects of
a financial sector VAT (Lockwood (2011)). Given assumptions about cost
pass-through and the tax- cascading that would cause any equilibrium
effects, Lockwood predicted that a financial services VAT would lower
ultimate tax revenues as the losses in Stuck VAT exceeded the gains from
taxing retail financial services.
References to the research
The research:
2. Scharf, K. and S. Smith, 2009, Gift Aid donor research: Exploring options
for reforming higher- rate relief, Research Report 91, HM Revenue and
Customs, December 2009, URL: http://www.hmrc.gov.uk/research/report91.pdf.
5. De La Feria, R. and B. Lockwood, 2010, "Opting for Opting-In? An
Evaluation of the European Commission's Proposals for Reforming VAT on
Financial Services," Fiscal Studies, v31n2, pp 171- 202, DOI: http://dx.doi.org/10.1111/j.1475-5890.2010.00111.x.
Evidence of research quality:
For Professor Scharf, there are two academic papers published in a top
field journal, a working paper, and a research report sponsored by Her
Majesty's Revenue and Customs office. The Journal of Public Economics
is ranked 28th in the Association of Business Schools (ABS)
rankings, 19th in the Kalatizidakis et. al. (2003, JEEA)
rankings, and 29th in the REPEC rankings. For Professor
Lockwood, there is one academic paper and one sponsored research report. Fiscal
Studies ranks among the 2* journals at 99th in the ABS
rankings and 173rd in the REPEC rankings. Lockwood (2011) was
research sponsored by a leading business consultancy and was the primary
piece of evidence used in their analysis of the effects of introducing VAT
in the banking sector (PwC (2011)).
Details of the impact
Professor Scharf's research shaped public and policymakers' views about
Gift Aid reform and the favourable tax treatment of charitable
contributions.1
Jeremy Sherwood, Branch Head, Charity Tax at HM Treasury, stated "[the
Scharf and Smith] research provides very valuable evidence on a topic
where robust UK data is surprisingly scarce... The research has been
enormously helpful in providing analytical information to help explore the
various proposals and their likely impacts on donor behaviour" (2009). In
response to the Report, HMRC and HM Treasury officials invited sector
representatives to participate in an open forum (HM Treasury (2010)), and
the final report of this forum drew on the 2009 report to outline
proposals for Gift Aid reform (Fanning (2010)). More recently, Scharf's
research underpins the entire section of "Coalition Government proposals
to encourage philanthropy" in their plans regarding Gift Aid reform (House
of Commons (2012a)).
Scharf's research also triggered a spirited public discussion about the
role of charitable donations in public life and their tax treatment. This
came to a head in late Spring 2012 when the Government proposed to cap tax
relief for deductions, including charitable deductions.
The uproar from charities and their donors was immediate. 19 charities
cited Scharf and Smith (2009) in making public statements or policy
proposals since 2008 about Gift Aid or the cap on charitable deductions.
Scharf provided non-academic presentations and blog posts, several of
which were prominently reported in the media. The Guardian editorial of 17
April 2012 concluded Scharf and Smith (2009) offered the "best evidence"
on tax incentives (Guardian (2012)) and both authors discussed their
research on the Today programme (BBC Radio 4). In response to the uproar,
the Government did a quick U-turn: while the cap on deductions was indeed
introduced in April 2013, charitable deductions are excluded from this
limit (House of Commons (2012b)).
Karl Wilding, Head of Policy, Research, and Foresight at the National
Council for Voluntary Organisations, reflected, "The recent disagreement
between HMT and the charity sector in relation to unrestricted tax reliefs
and Gift Aid highlighted the ongoing difficulties faced by the sector in
the battle for evidence-informed policy... The sector needs... more work
such as the economic analysis by Smith and Scharf on the price of
giving... Smith and Scharf had an impact on the debate by providing a
balanced, independent commentary. I am confident that Smith and Scharf
made a contribution to the debate and, as such, ... had a real impact in
the charity sector" (Wilding (2012)).
Lockwood's methods for estimating the impact of a financial services VAT
also had an immediate effect on government policy, this time in the EU.
Lockwood's methods for analysing the costs and benefits of a VAT were
adapted by the European Commission (EC) to calculate whether the financial
sector receives favourable tax treatment. Finding that it did, the EC
subsequently used this result to justify a novel Financial Transactions
Tax (FTT). Mr. Gaetan Nicodeme, Head of Sector in the Directorate-General
for Taxation and Customs Union in the EC, noted "The approach taken in
[Annex 5 to the 2011 FTT proposal] to calculate the share of irrecoverable
VAT is similar to the one taken by De la Feria and Lockwood (2010) in
Appendix A of their study. The only difference is that they used OECD IO
tables instead of Eurostat's tables" (Nicodeme (2013)). It concluded that
the financial sector has a tax advantage of at least €14 billion, or 0.11%
of Euro area GDP.
Lockwood's Fiscal Studies article also formed the basis of a
consultation with PricewaterhouseCoopers (PwC) on the appropriate taxation
of the financial sector. Frans Oomen, partner for Indirect Taxes at PwC,
concluded, "During the project, Lockwood added significant knowledge,
insight, conceptual thinking, and quality in ... developing a conceptual
framework as well as using statistical information to build an economic
model and a methodology [to assess] whether the VAT exemptions for banking
services in the EU lead to a lower level of VAT revenues as compared to a
full VAT taxation system of banks. In [PwC's] view, the findings of the
report have contributed to a wider and better understanding of the
financial and economic implications of the EU VAT system and to the
discussions around the EU's tax policy introducing a Financial
Transactions Tax as an additional tax for the financial sector" (Oomen
(2013)). Another project sponsored by a separate division within the EC
also relied on de la Feria and Lockwood's methodology to quantify the
effects of the taxation of financial services (IFS (2011)).
Scharf's and Lockwood's research have had significant and meaningful
effect in debates about the tax treatment of charities and financial
services. Scharf's research played a significant role in the debate that
ultimately prevented charitable donations from being included in a
deductions cap. It also has influenced public and policymaker
understanding about the likely impact of changes in Gift Aid rules in an
environment where more than 50% of UK residents make charitable
contributions worth over £4 billion on an annual basis.
While the primary beneficiaries of Lockwood's research have been EC
policymakers, the public at large will benefit from the increased tax
revenues the FTT will bring. From 2014, the FTT will tax exchanges of
shares and bonds at a rate of 0.1% and derivative contracts at a rate of
0.01% and is estimated to raise €57 billion annually, approximately 0.4%
of EU GDP (EC (2012)).
Sources to corroborate the impact
European Commission, 2011, "Is The Financial Sector Under-Taxed?
Empirical Part," p2, Annex 5 in European Commission, 2011, "Proposal for a
Council Directive on a common system of financial transaction tax."
Available at ("impact assessment" link):
http://ec.europa.eu/taxation_customs/resources/documents/taxation/other_taxes/financial_sector/summ_impact_assesmt_en.pdf
European Commission, 2012, "Revenue Estimates," Available at ("revenue
estimates" link):
http://ec.europa.eu/taxation_customs/resources/documents/taxation/other_taxes/financial_sector/fact_sheet/technical_fiches.pdf
European Commission, 2013, "Implementing enhanced cooperation in the area
of Financial Transaction Tax," 14 February 2013, p4. Available at
("presentation" link):
http://ec.europa.eu/taxation_customs/resources/documents/taxation/other_taxes/financial_sector/ftt_under_ec_en.pdf
Fanning, P., 2010, Gift Aid Forum: Report to Economic Secretary to the
Treasury, p21. URL:
http://tinyurl.com/o96b9ct
Guardian, The, 2012, David Cameron: charity case (Editorial), 17 April
2012. URL:
http://www.guardian.co.uk/commentisfree/2012/apr/17/david-ameron-charity-case.
HM Treasury, 2010, "Government response to the Gift Aid Forum," URL:
https://www.gov.uk/government/news/government-response-to-the-gift-aid-forum
House of Commons Library, 2012, "Gift Aid scheme for small donations," at
6. URL:
http://www.parliament.uk/briefing-papers/SN06330.
Institute for Fiscal Studies (2011), "A retrospective evaluation of
elements of the EU VAT system," URL:
http://ec.europa.eu/taxation_customs/resources/documents/common/publications/studies/report_evaluation_vat.pdf.
Head of Sector, Directorate General for Taxation and Customs Union,
European Commission 2013, email to Professor Gregory Crawford, Director of
Research Impact, Department of Economics, University of Warwick, received
3 June 2013.
Partner for Indirect Taxes, PriceWaterhouse Coopers 2013, email to
Professor Gregory Crawford, Director of Research Impact, Department of
Economics, University of Warwick, received 16 July, 2013.
Sherwood, J., 2009, Gift Aid Donor Research, HM Treasury Presentation,
URL:
http://www.bristol.ac.uk/cmpo/events/2009/giftaid/hmtreasuryspeech.pdf.
Head of Policy, Research, and Foresight at the National Council for
Voluntary Organisations, email to Sarah Smith and Kimberly Scharf,
received 26 June 2012.
1 Note that, but for some blog posts by
Scharf alone, the impact of the Scharf and Smith research for HMRC
described here is equally shared between the two authors. For
convenience, we will report this as "Scharf's research," with the
equal contribution of Smith implied but not stated.