ONE of the fiscal wonders of the developed world in the 1990s is the dramatic growth in Irish corporation tax yields. In 1990 some £475 million was paid by this sector in 1996 this had risen to £1,426 million - a threefold increase. The 1996 outturn was actually itself a dramatic 24 per cent increase on the previous year.
So the Minister's well heralded generosity in reducing the main corporation tax rate by 2 per cent with a similar reduction in the lower rate to 28 per cent might be said to be well affordable - particularly since it will cost just £1.5 million in 1997.
Based on 1994 figures, the most recent publicly available, the "small companies rate" will potentially apply to some 20,000 firms. While in absolute terms the additional relief is modest, it will have the important and welcome consequence of increasing the amount of retained earnings for companies in this sector, where cash How is normally tight and borrowing capacity stretched.
The reduction in the 38 per cent rate will be focused on distribution and service companies (high generators of jobs in recent years) and on the mainstream, or non IFSC, financial sector. The 10 per cent tax rate, which is estimated to provide up to 60 per cent of all corporation tax revenues, is unchanged.
A corporation tax rate reduction generates a number of technical spin offs. One is a reduction in the tax credit on dividends paid out of fully taxed profits. The new rate of 21/79ths (previously 23/77ths) will apply to dividends paid on or after April 6th 1997 This will affect gross dividend yield and will be regretted by institutional investors.
It will also increase the effective rate (net of tax credit) of tax on dividends paid to 48 per cent taxpaying individual investors. The tax rate reduction may also make it somewhat more attractive for Irish corporates with overseas interests to repatriate dividends. These are subject to Irish corporation tax at the full rate, but a credit is normally available for tax paid on the profits from which the dividend has been sourced. To the extent that the Irish rate con verges more closely with rates in the more popular territories for Irish overseas investment (US 35 per cent the Netherlands 35 per cent UK 33 per cent), the costs of repatriation are reduced.
But the residual liability still validates the case for a "participation exemption" under which dividends repatriated from profits which have been taxed abroad would be totally exempt from further tax in Ireland. Such a measure is unlikely to have any significant fiscal cost because at present Irish parent companies simply do not normally repatriate overseas profits because of the potential additional costs.
The corporation tax rate may also have a knock on effect on some taxed based lending structures, notably finance leases. Many of these are written on the basis that the lessor is to receive a constant pre determined rate of return over the period of the lease. A reduction in the rate of tax may in some cases have an impact on this. In contrast, interest rates on Section 84 loans will rise because the after tax cost of funds to the lender will increase.
Business will also benefit from the increase by £1,000 to £15,000 in the ceiling for calculating capital allowances on new cars used for business purposes and in respect of allowable running expenses for all cars. The capital allowance threshold for secondhand cars stays at £10,000.
The Budget's impact on employment costs is mixed. The ceiling below which the employer's full rate PRSI contribution is payable increases from £26,800 to £27,900 - representing a £132 per annum additional cost of employing somebody paid in this range. The reduced employer PRSI contribution rate of 8.5 per cent will now be applied where earnings are less than £13,500 per annum, an increased ceiling of £500. This will benefit those sectors where pay rates are at or below the average industrial wage.
Family owned businesses, as well as being the most likely beneficiaries of the new lower 28 per cent corporation tax rate, will also welcome two other measures. One is a reduction to 26 per cent in the rate of capital gains tax applicable to disposals of shares in qualifying companies. The other is an increase in the relief from capital acquisitions tax in respect of property retained in the business by a successor, from 75 per cent to 90 per cent.
Budding entrepreneurs will obtain a useful measure of relief from a proposal to allow for tax purposes certain spending incurred for the purposes of a trade not more than three years prior to commencement. This should be capable of including the costs of feasibility studies and market research. They will also welcome a range of tax incentives which are being proposed for the Developing Companies Market, including the granting of BES status to qualifying companies, the facilitating of investment through Specified Portfolio Investment Accounts and certain borrowing and capital gains tax reliefs.