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Dividend imputation and superannuation are worth fighting for

In this third article which draws on my November 2012 speech to the ASFA Conference, I wish to say something about one of my favourite subjects, the company tax system.

Before I became Treasurer, company income in Australia was taxed twice: once at the company rate, at the time 46%, and then the dividends were taxed at the top personal rate of 60%. On $100 of company income, this left only $21 in the hands of the taxpayer!

In 1985, I changed the system completely and removed the double taxation of company income by introducing full dividend imputation. This meant that company income would only be taxed once. And this concession was reserved for Australian taxpayers.

People should understand that for Australian taxpayers, the company tax is broadly a withholding tax. The government collects it at the 30% rate on company income – and temporarily hangs onto it – before returning it to shareholders (including local superannuation funds) in the form of imputed credits.

In other words, when a company issues its dividends on a fully franked basis, it hands back the company tax paid earlier and staples it to the dividend.

This is my point. If the company tax rate is reduced from 30%, the principal beneficiaries will be foreigners, those who do not qualify for imputation credits. A reduction in the 30% rate, to say 25%, will diminish the value of dividends paid to superannuation funds and self-funded retirees. Such a move would effectively increase the rates of tax applying to superannuation.

The question is: do you know any foreigners you want to give 5% of our national company income to? Any deserving cases out there? Or should we leave the company tax rate where it is, as a withholding tax, for the promotion of Australian investment and for the benefit of Australian taxpayers?

I believe the superannuation industry should have a jaundiced view of reductions in the existing company tax rate but, more than that, remain vigilant in protecting ‘dividend imputation’. Dividend imputation revolutionised capital formation in Australia. The Treasury was uncomfortable with it because of its cost to revenue, and about every seven years it promotes a debate to remove it.

I also wish to say something about the cost of capital.

Before mandatory superannuation, the equity risk premium in Australia was well above the OECD average. Today, it is well under it. Superannuation now massively underwrites capital formation in Australia. Indeed, one of the principal reasons the 2008 GFC was less severe for Australia was our ability, through the super pool, to rapidly and effortlessly fund $90 billion of company re-capitalisations. This would have been unthinkable in earlier financial crises.

This is another reason the Business Council of Australia and its constituency should continue to support the consolidation of mandatory superannuation to the point of maturity. This includes supporting increased levels of the super guarantee as discussed in previous articles. We need a national consensus on this. We need the Coalition to take co-ownership of the system with the Labor Party, and we need the business community’s support for them to do it.

Superannuation is about de-risking the future. In the system I set up, people were encouraged to salary sacrifice in later life, when mortgages had been paid off and they had discretionary income. Under that policy, people could salary sacrifice up to $100,000 a year when over 50 years of age. I believe the current limit of only $25,000 is too low, certainly for those over 50.

This is where long term vision is important. While the government and the Treasury would see an increase in permissible voluntary contributions as a cost to the Budget in revenue forgone due to reduced tax revenues today, such increased limits would provide the government with certainty in the later years by reducing its future funding obligations. This was one of the original intentions when the foundations for the current superannuation system were laid over 20 years ago.

Hon Paul Keating was Treasurer of Australia between 1983 and 1991 and Prime Minister between 1991 and 1996.

 

 

4 Comments
Steve
March 09, 2018

Right on the money Bill.
There is a certain hysteria associated with a possible reduction of the corporate tax rate; the hysteria centres around the loss of franking credits. But as you eloquently point out, assuming the company's dividend payout ratio is the same, the shareholder receives a higher cash dividend. That part of the equation seems to have been missed!

Bill Watson
February 15, 2018

I have trouble seeing why "A reduction in the 30% rate, to say 25%, will diminish the value of dividends paid to superannuation funds and self-funded retirees."

If a retiree's share of say, $100 company profit, then that person would receive $70 dividend and a franking credit of $30 (for a 30% company tax regime).

If the co tax rate was reduced to say 20%, then for the same $100 co profit the person would receive $80 dividend along with a $20 franking credit. Both these amounts (ie $100 would be added to the persons other taxable income (if any) and be taxed accordingly. The end result is the shareholder would be no worse off as a result of the lower co tax rate.

Am I missing something?

Angus Stephen
March 28, 2013

Great article - and simply lowering the tax rate is going to provide a disincentive to companies to improve productivity, which many agree is the main game when it comes to remaining relevant in today's competitive times. Your point regarding contributions caps again points out that the political cycle is a poor master for our life cycle. How do we get them to take a long term view?

Tim Buckley
February 22, 2013

Mr Keating,
I am still left wondering why is it that Wayne Swan continues to bang on about lowering the corporate tax rate? Who does he think this helps in Australia? Yet the SMH's Clancy Yeates on 25 October 2012 reported that "Treasurer Wayne Swan's business tax working group yesterday said a cut in the 30% company tax rate would provide significant economic benefits, and wage earners would be the ultimate winners." Significant economic benefits - how? Exactly as you say, franking makes this irresponsible. How can Swan be given such stupid advice? Lets help foreign investors and super wealthy tax avoiders pay even less tax?? Almost as stupid as not increasing the super contribution rate to 12%.

 

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