Word version of the report
Contents
Section 1: Context
Section 2: Impact on the
Estimates and Budget - Quality and Procedural Considerations
Annex:
Alternative Estimates and Budget Decision Making Timetables
Section 3: Implementation
Issues
(a) Taxation Aspects
(b) PRSI Aspects
(c) Social Welfare Aspects
(d) Legislative Aspects
Section 4: The Changeover
to the Euro
Section 5: Assessment of
Alternative Dates and Conclusions
Annex:
Tabular Comparison of Impact of Alternative Budget Dates
Appendices:
Appendix 1: Extract from Press Statement of 20 July
2000 announcing Alignment of Tax and Calendar Years
Section 1: Context
Background
1.1: In July 1998, an Interdepartmental Working Group made up
of representatives from the Departments of Finance, Social Community and Family
Affairs and the Revenue Commissioners completed a report on the Alignment of
the Income Tax Year with the Calendar Year from 1 January 2000. The Group, having
considered the main issues involved, including the administration and systems
aspects, recommended that the changeover should not proceed before 1 January
2001 for a number of reasons. The Minister deferred consideration of the issue
in 1999 in view of the fundamental changes being made to the tax system to accommodate
the introduction of income tax credits.
1.2: On 12 July 2000, the Government authorised the Minister
to proceed with the necessary preparations for the alignment of the Income Tax/PRSI
year with the calendar year from 1 January 2002. In that context, it was also
agreed that social welfare increases, excluding Child Benefit, would apply from
1 January and that there should be further consultation between the Department
of Finance and the Department of Social, Community and Family Affairs on the
date of the Budget (which the Memorandum for Government envisaged would be in
early November) and other procedures to resolve transitional difficulties.
1.3: On 20 July 2000, the Minister issued a press statement
(extract at appendix 1) which announced the alignment with effect from 1 January
2002 and indicated that, from that point, Budget day tax changes and social
welfare weekly rate improvements would be brought forward to 1 January and that
combining the change with the euro changeover would allow necessary changes
to IT systems to be to be made in one go. The statement also said that, in order
to facilitate the change, it would be necessary to have an earlier Budget day
than early December as at present.
1.4: The Minister for Social, Community and Family Affairs brought
a Memorandum to Government on 16 November 2000 on the payment of social welfare
increases from 1 January 2002 where it was decided that Ministers would consult
further.
1.5: In his Budget Statement of 6 December 2000, the Minister
confirmed that the next tax year would be a short year running from 6 April
to 31 December 2001 to accommodate the introduction of the calendar based tax
year from 1 January 2002; he also said that, from 2002, the weekly social welfare
increases would apply from 1 January.
Working Group
1.6: Arising from subsequent discussions between the Taoiseach
and the Minister and officials of both Departments regarding the date of future
Budgets, the Taoiseach requested that a timetable be drawn up for the Budget,
Estimates and the introduction of the euro. At a meeting of the Assistant Secretary
Group on 15 December 2000, it was agreed that a Working Group be established
in that regard to draw up a paper by 12 January 2001 for consideration by the
Management Advisory Committee in mid-January.
1.7: The membership of the Group was:
Joe Mooney (Chair) - Public Expenditure Division
Áine Stapleton - Public Expenditure Division
Dermot Mulligan - Budget and Economic Division
Vincent Palmer - Budget and Economic Division
Philip Hamell - Euro Changeover Board of Ireland
Mary Nash (BED) acted as Secretary to the Group, while Tom Murphy (PED) and
Colm Sweeney (BED) also participated in the Group's deliberations.
Approach of Group
1.8: The Working Group agreed on the following terms of reference:
- Identify possible alternative Budget dates and assess the implications of
opting for those dates.
- Make a recommendation to Management and the Minister on the date on which
the 2002 Budget and beyond should be presented to Dáil Eireann.
- Draw up an Estimates and Budget timetable
The Group also agreed that it would consult with the Revenue Commissioners
and the Department of Social, Community and Family Affairs and would take into
account the issues raised by each organisation in relation to the alternative
Budget dates. Representatives of both organisations made presentations to the
Group on 4 January 2001.
1.9: From the outset, the Group decided to give particular consideration
to the dates of 5 December 2001 and 24 October 2001 for Budget 2002, on the
basis that the former date represented a continuation of the status quo, while
Revenue and the Department of Social, Community and Family Affairs say that
the latter is the latest point at which implementation of tax and most social
welfare changes announced in the Budget could be achieved on 1 January 2002.
While consideration was also given to an interim position of a November date,
it quickly emerged that, notwithstanding the benefits of a somewhat firmer financial
framework than would apply in relation to an October date, it would not be as
sound in that regard as a December Budget; moreover, it would offer few operational
advantages over a December date, at least for 2002.
Section 2: Impact on the Budget and Estimates - Quality and Procedural
Considerations
Purpose of the Budget
2.1: Fiscal policy is the most important economic policy instrument
of Government, and, indeed, has added significance since Ireland's entry to
EMU. The Minister's Financial Statement sets out annually the Government's overall
fiscal policy i.e. its budgetary targets (both revenue and expenditure) together
with the projected Budget Balance for the coming year. In addition, the Budget
contains a multi-annual presentation of the major revenue and expenditure figures
for the following two years on a no-policy-change basis. The Budget is also
the principal forum for outlining the Government's taxation and social welfare
priorities, together with other selected spending measures considered appropriate
for announcement as part of the Budget day package.
2.2: In assessing the impact of the timing of the Budget day
on the budgetary process itself, the Group considered two key aspects:
- the consequences for the Government's financial management system, i.e.
the estimates and budgetary process; and
- the capacity of Departments to produce the Estimates over a shorter time
period.
The respective timetables in relation to the various stages of the Estimates/Budget
which would need to be observed for the two Budget dates considered by the Group
are set out in the annex to this section.
Consequences for the budgetary process
2.3: Advancing the Budget date by six weeks would inevitably
impact on the robustness of the information available to Government in formulating
its budgetary policy. In settling its economic strategy and budget priorities,
the Government needs to have timely and accurate information on developments
in the wider economic environment. The closer the decision making process to
the end of the year, the more accurate will be the available information on
emerging economic trends and projected tax receipts for the coming year. This
is particularly true in the case of inflation, for example.
2.4: A particular risk on the tax forecasting side associated
with an early Budget concerns the possible significant overstatement
of tax receipts for the Budget year in a situation of economic downturn. In
recent years, the dynamic performance of the economy has produced the opposite
effect.
2.5: Particular difficulties would arise on the expenditure
side because a 24 October Budget day would require Government to agree spending
estimates towards the end of September. As a result, there would be less up-to-date
information available to Departments than at present on the emerging spending
outlook in the base year. In the case of the Health Vote, for example, decisions
in September would, of necessity, be based on mid-year returns of actual spending
in the base year by health agencies. Similarly, in the area of capital spending,
almost 50% of total voted expenditure takes place in the final quarter of the
year. The baseline information available to Government has implications for
the quality of the decisions taken in the Estimates.
2.6: In addition, the longer time gap between the point at which
decisions would need to be taken on the Estimates and the start of the financial
year (a gap of nearly three months instead of six weeks) would, inevitably,
mean that more developments with expenditure implications would be likely to
arise during this period. Departments and Ministers would be left in a position
of having to cope with these developments within whatever allocations were decided
by Government in September.
2.7: Both of these aspects (less complete information and post-AEV/Budget
day developments) would have implications for the Estimates and the overall
Budget. To some extent, the present system copes with these issues already via
the REV and supplementary Estimates. The earlier the date of the Budget, the
greater the impact on the Estimates process. The key concern would be to ensure
that the Estimates process would not effectively be re-opened post budget in
the light of emerging trends and new developments as such a scenario would weaken
the standing of published budgetary decisions. Such a development would also,
apart from any other considerations, raise questions at EU level about our adherence
to the EU Stability and Growth Pact as reported on in the Budget.
Logistical issues/Capacity to deliver
2.8: The duration and complexity of the Estimates campaign is
dictated by the process itself (which incorporates no-policy change and multi-annual
budget dimensions), the multiplicity of parties involved (15 Ministers and 44
Votes), the scale of spending (in excess of £16 billion in 2000), the linkages
with other multi-annual commitments (such as the NDP and the PPF) and the level
of detail which is required in terms of projected spending and receipts.
2.9: As indicated above, a 24 October Budget day would require
final decisions on spending to be taken towards end-September instead of end-October.
The reality is that, for various reasons, Departments would not be in a position
to sign off on key decisions before the end of July on the basis of incomplete
information. Meaningful negotiations at official level, Ministerial bilaterals
and Government decisions on the Estimates would all have to take place over
a three week period in September. This would place considerable pressure on
all Ministers and Departments during the period in question and would involve
guaranteed submission of Estimates proposals by end-June. This situation
would, of course, be further complicated by any requirement to adopt a mid-year
corrective spending package to offset emerging expenditure overruns.
2.10: In 2001, Departments will have to produce, for the first
time, their MAB and Estimates figures in euro and to complete the normal analysis
of figures, year-on-year comparisons, etc. in euro. Clearly, it will be easier
for them to do so if the timescale for the process is not shortened by 6 weeks
as it would be with a 24 October Budget.
2.11: Although many of our EU partners operate a fiscal year
beginning on 1 January, it appears that their budgetary systems differ from
that operating in Ireland. Some seem to have a unified tax/expenditure budget,
for example, while others publish only broad macro/departmental level spending
figures at budget time and publish detailed expenditure allocations, within
the previously approved limits, later in the process.
Tax
2.12: On the tax side, an October Budget implies that the timeframe
for submissions to the Minister and meetings of the Tax Strategy Group (TSG)
would be considerably compressed. Submissions to the Minister would have to
be made in the period early-September to early / mid-October. TSG meetings would
have to take place mainly in September. Meetings with interest groups would
take place in late September.
Conclusion
2.13: The Budget and Estimates process is central to the Government's
overall economic strategy and to the orderly management of the public finances.
It is desirable, therefore, that decisions be based on the most up-to-date data
possible, including in regard to the macro-economic environment and that time
be available to complete the considerable logistical and deliberative dimensions
involved. Compressing the timeframe available by moving the Budget date forward
would carry downsides in these respects as well as imposing a requirement for
stricter discipline on the many parties involved; this is particularly the case
where the Estimates are concerned, given the concern that the Budget should
remain the effective final step in the Estimates process. The position for 2002
is further complicated by the short tax year in 2001 and the euro changeover
on 1 January 2002. These various considerations must also be balanced against
the implementation implications arising on the tax and social welfare fronts
which will be considered in the following section.
ANNEX
Alternative Timetables
| |
24 October 2001 Budget
|
5 December 2001 Budget
|
| |
|
|
|
No Policy Change circular to issue
|
8 March 2001
|
5 April 2001
|
|
No Policy Change Government decision
|
15 May 2001
|
20 June 2001
|
|
Estimates Circular issues to Departments
|
1 June 2001
|
4 July 2001
|
|
TSG First Meeting
|
26 June 2001
|
17 July 2001
|
|
Estimates Circular returned by Departments
|
25 June 2001
|
28 July 2001
|
|
Ministerial Bilaterals
|
11-13 Sept 2001
|
4-6 Oct 2001
|
|
Final Government Decision on AEV
|
25 Sept 2001
|
23 Oct 2001
|
|
Minister meets interest groups
|
27-28 Sept 2001
|
8-9 Nov 2001
|
|
AEV sent to printers
|
4 Oct 2001
|
2 Nov 2001
|
|
AEV published
|
10 October 2001
|
15 November 2001
|
|
TSG Final meeting¹
|
2 Oct 2001 (5th mtg)
|
13 Nov 2001 (11th mtg)
|
|
White Paper published
|
20 Oct 2001
|
1 Dec 2001
|
|
Budget Day
|
24 Oct 2001
|
5 Dec 2001
|
|
REV Published
|
mid-February 2002
|
mid-March 2002
|
|
|
|
|
Finance Bill
|
|
|
|
Finance Bill Published
|
10 Jan 2002
|
14 Feb 2002
|
|
Finance Bill 2nd Stage
|
5-6 Feb 2002
|
26-27 Feb 2002
|
|
Finance Bill Committee Stage
|
12-14 Feb 2002
|
5-7 March 2002
|
|
Report Stage
|
26-27 Feb 2002
|
19-20 March 2002
|
|
Senate Stage
|
6-7 March 2002
|
26-27 March 2002
|
|
Deadline for signature
|
12 March 20022
|
5 April 2002
|
1 With the earlier Budget Date, the TSG would probably have to be
curtailed to a maximum of 5 meetings. One meeting would be held in June and
up to 4 in September/October. The later Budget date allows up to 11 meetings.
2 12 March gives a new 140 days deadline from Budget Day and requires
the amendment of the Provisional Collection of Taxes Act.
Section 3: Implementation Issues
3.1: An integral part of any Budget process is the implementation
of the tax and expenditure measures announced. Traditionally, this has seen
a gap of at least 2 months between the Budget itself and its implementation.
The particular issues in relation to income tax and PRSI changes and social
welfare rate improvements are now discussed.
(a) Taxation Aspects
3.2: The Revenue Commissioners currently take 10 - 12 weeks
from the date of the Budget for completion of the issue of Tax Free Allowance
certificates (TFAs) to 1.5m PAYE taxpayers (2m employments) and Tax Deduction
Cards (TDCs) to their 170,000 employers; this period is required both to write
the necessary computer codes and to carry out "user acceptance testing"
to ensure proper output. If the Budget is no later than 24 October, and is straightforward
(i.e. does not involve major structural changes), Revenue envisage that they
will be able to issue Tax Deduction Cards to employers by the end of the second
week of December (14/15 December 2001), in order to provide for correct deductions
from employees' wages in the new tax year beginning on 1 January; the corresponding
TFAs would issue in early January. Given the numbers involved, Revenue do not
anticipate any significant problem for An Post in delivering the relevant material
to employers during the peak Christmas postal period. If the Budget contains
major structural changes requiring significant programming changes (e.g. an
element akin to individual tax bands), then meeting the 1 January deadline could
not be guaranteed.
3.3: If the Budget is later than 24 October (e.g. a 5 December
Budget), TDCs would not reach employers until after 1 January. This would
mean TFAs/TDCs issuing in February and March and would result in (possibly significant)
temporary under or over taxation arising in the early part of the year, because
employers would continue to operate on the basis of the existing tax regime.
This cash flow effect would not be significant from the overall Exchequer perspective
but could be of major concern to individual taxpayers, particularly where arrears
of tax are being clawed back. If significant repayments of tax were made through
employer payrolls, this could impact on their cash flow and create some difficulties
for them. It would also leave taxpayers beginning a tax year not knowing their
tax position for the year, which would represent a deterioration in the service
they have been used to.
3.4: To alleviate these difficulties, which arise in particular
for 2002, Revenue would accommodate a December Budget by issuing interim TDCs
deduction cards in October or November (as close as possible to year end but
before Budget date) to provide employers with the most up-to-date information
possible at that point. Interim TFAs would also issue to employees at this stage.
These interim TDCs and TFAs would continue to apply annualised 2001 personal
tax credits, bands, etc., while removing provisions for mortgage interest, health
insurance (VHI and BUPA), permanent health insurance (PHI), Business Expansion
Scheme (BES) and other non-recurring reliefs3.This would minimise,
but not eliminate, the under / over payment of tax in the first quarter of 2002.
However, Revenue would then have to process a further bulk issue of TFAs/TDCs,
incorporating Budget changes, to all employees and employers in February /March
2002. This would mean duplication of work for employers in setting up their
systems twice for a single tax year, while employees would not get their correct
TFA entitlements for 2002 until into March. This would not give taxpayers or
employers the result they would expect from moving the tax year to a calendar
year and would represent a significant deterioration in terms of providing them
with a quality customer service.
(b) PRSI Aspects
3.5: PRSI and Health Levy changes (both employer and/or employee
and whether concerning rates, allowances, thresholds or ceilings) are notified
by the Department of Social, Community and Family Affairs. Employers generally
(circa 170,000) are notified jointly with Revenue of PRSI changes and
changes in the operation of the PAYE system for the new tax year, while, separately,
DSCFA advise payroll/software companies of changes in PRSI arrangements for
all PRSI Classes in the new tax year. It should be noted that amended TFA Certificates
are issued separately by Revenue and that these do not contain any material
on PRSI changes or the appropriate rate or Class of PRSI to be deducted from
an individual taxpayer in the new tax year. A lead in time of up to 10 weeks
is required to enable
the DSCFA notification processes outlined above to be completed;
the necessary software development to be undertaken and completed by the
software companies (a number of the major such companies are based in the
UK); and
(c) new payroll packages to be delivered, installed and tested before the new
provisions can be implemented.
It should be noted that the notification process itself, particularly to the
payroll/software companies, takes the least amount of time. The bulk of the
time needed between Budget Day and implementation is required to enable the
necessary packages to be developed, sold (off the shelf in some cases), installed
and tested so that payroll packages can run seamlessly from the first pay day
of the new tax year. Accordingly, the time needed to develop and install etc.
the relevant packages is not under the control of DSCFA. A December Budget date
would mean that any PRSI changes announced could not be applied from 1 January;
this situation is likely to prevail for the foreseeable future.
3.6: A further difficulty as regards PRSI stems from its weekly,
non-cumulative nature of application which contrasts with the annual nature
of the income tax system: in this regard, the Health Levy is similar to PRSI.
Thus, the PRSI and Health Levy liability of employees is calculated on a weekly
basis and can vary from week to week as a person's earnings move above or below
relevant thresholds (or as they move in and out of employment). Moving to an
annual basis would be a fundamental change for the PRSI system. The Department
of Social, Community and Family Affairs are concerned that any such change,
for which there are no current plans, could be detrimental to more marginalised
workers.
3.7: It would be difficult, if not impossible, to implement
PRSI changes in arrears (i.e. by way of employer recoupment or surcharges) as
can be achieved on the taxation front in the event of a December Budget. In
addition, there would be no mechanism in place to refund PRSI to (or recoup
PRSI from) employees who had left a particular employment before the appropriate
new year changes were implemented by an employer. At the very least, a statutory
change would be required to allow for retrospection and, even then, there would
be likely ongoing significant operational difficulties for employers, the Revenue
Commissioners and, the Department of Social, Community and Family Affairs as
well as confusion for employees generally.
3.8: One consequence of the above situation is to curtail the
scope for announcing PRSI changes (other than those relating to contribution
ceilings) in a December Budget which could apply from the following January.
However, a distinction between first year and ongoing options might also be
worth exploring if the Budget were to be held in December 2001; for example,
a statutory change to allow for retrospection in the first year might be considered.
While an announcement of PRSI changes ahead of the Budget is a further option,
it is assumed that, for wider reasons, this would not be feasible.
(c) Social Welfare Payment Aspects
3.9: Before detailing the implementation implications of the
alternative Budget dates for social welfare rate increases, it is important
to remember that, irrespective of the date finally chosen, the budgetary increases
for weekly social welfare recipients will apply from a significantly earlier
point than up to this - from 2002 onwards, these increases will be advanced
by 4 months compared with 2000 and by 3 months as compared with 2001.
3.10: Weekly social welfare payments fall into two categories,
viz, short-term and long-term, and involve different production and delivery
approaches and timescales.
3.11: Each week
- 280,000 short-term recipients (unemployed, sickness and SWA payments) are
paid by either cheque to their homes (127,000), at their local post offices
either manually or electronically (131,000), or Electronic Funds Transfer (EFT)
into their bank accounts (22,000);
- 620,000 long-term recipients are paid by means of Personalised Payable Order
(PPO) books at post offices (520,000), or EFT (88,000) and cheques (12,000).
Increases to some 110,000 recipients on EFT can be implemented almost immediately
they are announced. From the point of view of putting increases into effect
quickly, and from an efficiency viewpoint generally, EFT would be the preferred
option. However, even with a major drive to promote EFT now (notwithstanding
the attendant problems and implications of such a move, particularly for the
Post Offices), it is unlikely that this would significantly reduce the problem
for the year 2002 whatever about the subsequent years. On the basis, therefore,
that current payment arrangements remain largely unchanged in the short-term,
the following concerns arise:
Short-Term Recipients
3.12: In order to pay the January 2002 increase to short-term
recipients in their weekly cheque or postdraft, 9 weeks notice is required (i.e.
circa 24 October 2001.) Providing for increased payments through a live computer
system, such as the ISTS system, requires a significant level of mandatory development
and testing and the Department of Social, Community and Family Affairs says
that this work cannot be accommodated within a shorter period. This particularly
applies in 2001 in the context of preparations for the euro changeover at the
beginning of 2002. The 24 October date should allow sufficient time to undertake
the system change and test work required to pay increased rates from early January.
This lead in time could perhaps be reduced to 8 weeks for 2003 and subsequently,
when the euro changeover would not be a factor.
3.13: In the case of short-term recipients, payment of the increase
will be delayed by one week for each week's delay in the Budget announcement
after 24 October; an early December 2001 Budget would see implementation of
the increases delayed until around mid-February 2002. Special arrangements would
have to be made for the calculation of arrears payments in these cases, both
at local offices around the country for unemployment payments and at headquarters
for Disability Benefit. The Department of Social, Community and Family Affairs
maintain that such those arrangements would cause severe disruption and would
involve substantial overtime working, particularly in the case of Disability
Benefit, a scheme which is, in any event, subject to unforeseeable fluctuations
caused by, e.g. flu epidemics. It is stated that past experience has shown that
any disruption of the Disability Benefit system can quickly escalate and become
a major public issue.
Long-Term Recipients
3.14: Irrespective of the date of Budget 2002, long-term recipients
(other than those on EFT) will not receive their increases on time next year.
In order for the increases to be reflected in their PPO books, announcement
of the rate to be paid from January 2002 would be required in July 2001. This
arises because the Department of Social, Community and Family Affairs has to
plan a 12-month cycle which involves continuous production of 26-order pension
books for 6 months with start and expiry dates staggered throughout the year.
As a result, changes in the cycle cannot be implemented at short notice and,
given the continuous nature of the production process, order books include payments
into the following calendar year. In the current cycle, the window of opportunity
for change occurs in November, when the printing programme for the next but
one calendar year is settled. The next opportunity for change is November 2001
affecting the increases payable in 2003.
3.15: Given the above circumstances, new arrangements have to
be put in place to pay the 2002 increases either in arrears or part arrears
/ part advance. Discussions are currently proceeding with An Post on the arrangements
to apply regarding the delayed payment to PPO recipients of the increase. Bearing
in mind that there are two main issues of books in the first quarter - widows
and lone parents mainly are renewed in February (300,000) and old-age and related
payments in April (320,000) - there are a number of issues to be addressed,
including:
- the need to put increases into effect as early as possible in 2002 and to
manage the expectations of people who are used to having increases paid at the
due date;
- the fact that, in some cases, the 'arrears' payment contain an element of
payment in advance, this would be unusual and would require specific approval
by Government;
- possible contractual issues arising with an Post because of, inter-alia,
ongoing consideration at EU level of legal issues in relation to the existing
arrangements.
3.16: Consideration and discussion of the possibilities is still
ongoing between the Department of Social, Community and Family Affairs and An
Post. However, current thinking is that an approach along the following lines
may be feasible:
- in mid-February 2002, approx. half of the clients, mainly widows and lone
parents (300,000 cases) will receive renewal books containing the increased
rates. The first order in these books will also contain the arrears from 1 January
to that point.
- At the same time, the remaining clients, mainly old age pensioners (320,000)
will receive, at their local post office, a postdraft containing arrears / part
advance covering the period 1 January to April, at which point they will receive
their renewal books incorporating the increased rates.
3.17: If these options do not materialise, payment will have
to be made by cheque to the customer's home address. There are significant logistical
difficulties associated with this option mainly in the area of unreliable address
information and cheque production, it would also carry serious risks from a
control viewpoint.
(d) Legislative Aspects
(i) Taxation
3.18: The Provisional Collection of Taxes Act, 1927 requires
that Budget Day Financial Resolutions be confirmed within four calendar months
in primary legislation; in the normal course, this is effected in the annual
Finance Act. However, if the Budget is in late October, the Act may have to
be amended in the 2001 Finance Bill to provide that the Financial Resolutions
would remain in effect for longer than the current four month provision. The
timing vis-a-vis the Oireachtas Christmas recess period is the critical factor
in that regard. Retention of a December Budget date would require no legislative
change.
(ii) PRSI and Social Welfare
3.19: Budgetary changes are normally implemented by means of
an annual Social Welfare Bill. In the context of the Government's decision to
implement future social welfare payment increases with effect from January each
year, the Bill would need to be implemented before the Christmas Recess. The
Minister for Social, Community and Family Affairs has explored with the Attorney-General
the possible use of secondary legislation to give effect to the PRSI changes
and social welfare rate increases announced in the Budget. From the Attorney-General's
advice, he has concluded that there are constitutional risks involved in such
a process. In any event, the Minister's powers would only at best partially
cover the range of changes which may be required to social welfare legislation
in order to implement those elements of a Budget package which need to be introduced
at the start of or early in the new tax year. Having regard to these issues,
the Minister for Social, Community and Family Affairs considers it essential
to introduce a basic Social Welfare Bill which provides for the implementation
of any necessary changes which must take effect early in the tax year (rates
increases and PRSI changes). This would require a Budget day of 24 October at
the latest. He also considers that this should make it possible to complete
the notifications to employers of PRSI changes in sufficient time to enable
them to amend their payroll systems in time to implement the changes from January.
3.20: The Group fully appreciates the Minister for Social, Community
and Family Affairs concern to avoid possible risks in relation to the collection
of PRSI revenue arising from the use of secondary legislation. However, as an
alternative to the pre-Christmas passage of a Social Welfare Bill, it suggests
that consideration be given to a legislative solution along the lines of the
Provisional Collection of Taxes Act, which would allow PRSI changes to be applied
by means of Financial Resolution subject to later confirmation. This would require
legal advice. If feasible, such an approach could provide a solution based on
a long standing arrangement in the taxation area.
Conclusion
3.21: Efficient and timely implementation of tax and social
welfare changes are an integral part of the Budget process. From the viewpoint
of achieving this in the most customer friendly way vis-a-vis 170,000 employers,
1.5 million PAYE taxpayers and the maximum possible number of social welfare
recipients, an October Budget date would be clearly preferable; equally, the
administrative burden on both the Revenue Commissioners and the Department of
Social, Community and Family Affairs would be less under the October date. Legislative
changes may be required whichever date is chosen.
3 In future, mortgage interest and health insurance reliefs will
be granted at source while PHI will be on a net pay basis; these items, therefore,
will not normally be included in TFAs.
Section 4: The Changeover to the Euro
Background
4.1.: The euro is already the currency of the State, and the
Irish pound, which is currently a subdivision of the euro, will lose even that
legal status on 1 January 2002. On that date too, euro notes and coins will
be introduced and IR£ notes and coins will begin to be withdrawn. The changeover
will require substantial preparations by the public administration - including,
especially, Revenue and Social, Community and Family Affairs - and by companies
and employers. The euro changeover will also involve a significant change for
citizens, including employees and social welfare recipients. The euro changeover
is not a postponeable event : it will happen on 1 January 2002.
The Tax Year / Calendar Year Alignment : Desirable Outcome from a Euro Changeover
Viewpoint
4.2: The following briefly summarises the desirable outcome,
from a euro changeover point of view, as regards the timing and other arrangements
relating to Budget 2002 for the parties identified above:
Revenue and Social, Community and Family Affairs It is clear
from the rest of this report that the tax year/calendar year alignment has
significant administrative and customer service implications for Revenue and
Social, Community and Family Affairs. It is important that these should be
such as to be manageable so that they do not hinder timely completion of these
organisations' preparations for the changeover to the euro.
Employers The arrangements for Budget 2002, and for its implementation
by employers, should be made known to employers as soon as possible. As regards
the measures in the Budget itself, any tax and PRSI changes that employers
are to put in place for January 2002 should be made known to them, in as much
detail as possible, as early as possible. This is in order to facilitate planning;
to enable the changes to be coordinated as necessary with other changes required
by the euro changeover; and as far as possible to avoid "bunching"
of implementation by large numbers of employers at the last minute.
Employees It is desirable that employees be given clear and
timely information about any changes to the tax and PRSI systems that are
to take effect from January 2002.
Social Welfare Recipients Surveys of public awareness of the
euro show that the groups most at risk of low awareness include older people
and people on low incomes. People in these categories are likely to be highly
represented among social welfare recipients. Accordingly, it is especially
desirable that social welfare recipients receive clear, timely and comprehensible
information about what is going to happen their social welfare payments in
January 2002.
Budgets on 24 October and 5 December : Impact for employers, employees and
social welfare recipients
4.3: The following briefly outlines the impact of the two different
Budget dates considered in this report on employers, employees and social welfare
recipients from a euro changeover point of view.
Budget on 24 October: Employers: Some employers (probably the
larger ones) will have changed their payroll systems to euro (and probably completed
most of their other changeover preparations) in advance of 1 January 2002. In
their case, implementation of revised TDCs, and any PRSI rate changes for 2002,
received before the start of 2002, should be a relatively routine matter. Other
employers (probably the smaller ones) will have left their payroll changeover
until the end of 2001. In their case, implementation of revised TDCs and PRSI
rates, received before the start of 2002, can presumably be combined with their
payroll changeover.
Employees: Employees would not receive their TFAs for 2002 until
early January 2002, although the tax changes would be implemented by their employers
from 1 January, coinciding with the euro changeover. Employees tax position
from 1 January would be an amalgam of the Budget changes plus the removal of
mortgage interest etc. reliefs from TFAs. This would need to be explained to
ensure that it is not ascribed to the euro changeover but is associated with
the accompanying reduction of employees' mortgage etc. payments. Any PRSI changes
would be implemented in the normal way for January wages/salary payments.
Social Welfare Recipients: General For convenience, social welfare
payments are made in round pounds, 50p, 20p and 10p, and from 1 January 2002
will be in round euro, 50, 20, and 10 cent. So the changeover of social welfare
payments to euro will not be an exact conversion, but will be a "smoothed"
conversion (always in favour of the recipient, of course). This point will require
explanation no matter what date is chosen for the Budget.
A 24 October Budget would mean
for all EFT and short-term recipients, there will be 1 January implementation
of the new social welfare payment rates, with a significant length of time
in which to explain the Budget changes.
for long-term recipients other than EFT. The arrangements currently
envisaged would mean that half the recipients would receive the increase in
February, with arrears reflected in the first order of their new PPO book,
while the other half would receive in February an order covering arrears/advance
January to April, with their new PPO books arriving in April. The rate actually
being paid from January would thus be a "smoothed" conversion.
Budget on 5 December: Employers Employers would, in October/Novemebr,
receive TDCs reflecting the latest known position of their employees under tax
year 2000, less any allowances for mortgage interest etc. Implementing
these TDCs would not seem to be any more or less complicated than implementing
the TDCs they would receive following an October Budget. (Of course, 5 December
would mean that employers would receive a further
TDC, for implementation in March, but that would be after the changeover.)
Any PRSI changes would not be notified to employers in time for implementation
in January 2002.
Employees: Employees would receive an interim TFA cert in advance
of the start of the 2002 tax year reflecting the elimination of mortgage interest
etc. relief (though mortgage etc. payments would have been reduced by a similar
amount). These aspects would have to be explained, in order to ensure that they
were not ascribed to the euro changeover. Any PRSI changes would not be implemented
for January wages/salaries payments.
Social Welfare Recipients: A 5 December Budget would mean
for EFT recipients, whether short or long term, immediate implementation
of their social welfare payment rates, with a short length of time in which
to explain the Budget changes.
for short-term recipients other than EFT, 5 December would mean that
implementation of the increases would not occur until mid-February 2002. Their
payments in January 2002 would thus be a "smoothed" conversion.
for long-term recipients other than EFT, there is no difference between
what would happen under a 5 December Budget and what would happen under a
24 October Budget.
Conclusions
4.4: From a euro changeover perspective in the tax area, there
seems to be no great difference in implementation for employers between
the alternative Budget dates, while, as regards PRSI, a 24 October Budget would
allow implementation of any rate changes in December 2001 and a 5 December Budget
would mean implementation would be delayed until after the changeover. For employees,
24 October allows implementation of any tax and PRSI changes from 1 January
2002, while 5 December means an interim tax deduction, not reflecting the Budget,
and unchanged PRSI rates, for some weeks after that date. For social welfare
recipients on EFT, there is, in effect, no difference; for short-term recipients
other that EFT, 24 October allows implementation from 1 January, while 5 December
means deferral until February; for long-term recipients other than EFT, there
is no difference between the two dates.
4.5: From a changeover point of view, it is highly desirable,
whatever date and implementation arrangements are decided, that they be announced
early.
Section 5: Assessment of Alternative Dates and Conclusions
Assessment
5.1: The previous sections have outlined the implications of
alternative Budget dates on 5 December and 24 October under various headings.
For convenience, these are summarised in tabular form in the annex to this section.
It has to be accepted, from the outset, that, given the tension between operational
constraints on the one hand and the need for a robust foundation for Budget
decisions on the other, whatever date is chosen will represent a compromise
between these requirements.
5.2: The Group was keenly aware that the key decisions underpinning
the Estimates and the Budget should be based on the most up to date data possible
and that sufficient time should be available to complete the considerable administrative
and decision making stages involved. These considerations point to the Budget
being held as late as possible in the year.
5.3: On the other hand, in light of public commitments already
given, the Group was conscious of the expectations among taxpayers and social
welfare recipients that budgetary measures would be implemented in a timely
fashion and of the desirability of not imposing an unreasonable administrative
burden on the various interests involved. These latter factors point to the
Budget being held earlier than at present.
5.4: The Group also noted that the position for Budget 2002
needed to take account of the consequences of shortening, for the first time,
of the period available for completion of the Estimates and Budget process and
of the euro changeover which will occur on 1 January 2002.
5.5: Taken together, the Group considered that these various
factors made the choice of Budget date less than straightforward, especially
for 2002.
Conclusions
5.6: In general, the Group favour moving to an earlier Budget
date than at present for the years subsequent to 2002 when once-off factors
such as the short tax year and the euro changeover will not apply.
5.7: The Group recommend that, in the interim, the scope for
systems development in Revenue and in the Department of Social, Community and
Family Affairs should be actively examined with a view to allowing greater flexibility
in the choice of date than currently. The Group also recommend that a review,
involving both the Department of Finance and other Departments, of the current
Estimates and Budget process should be undertaken with a view to accommodating
the revised timetables required for an earlier Budget.
5.8: For Budget 2002, the Group considered matters to be more
finely balanced. Moving to an October date would be problematic for the management
of the public finances due to the conjunction of a number of factors. These
are concerns about the robustness of the data on which key expenditure and tax
decisions are made, the requirement that, for the first time, the Estimates
be prepared in euro and, also for the first time, the compression of the time
available to prepare and consider Estimates and Budget policy options and, finally,
the risk that, given the earlier point in the year at which decisions are taken,
the Budget would not be the effective final step in the Estimates process. Also,
even with an October date, rate increases for some 60% of social welfare recipients
could not be paid on 1 January 2002. Choosing a December date would not carry
the public finance management downsides but would mean that PAYE tax and most
social welfare changes would be implemented some 6 to 8 weeks after 1 January
2002, with arrears/advance payments, as appropriate, and would involve an added
administrative burden for the public service and employers. Of course, the feasibility
of a December date assumes that the legal concerns raised in relation to social
welfare /PRSI can be resolved.
5.9: On balance, the Group considered that, for Budget 2002,
the December date might minimise the potential risks for this year and allow
time for consideration of the initiatives in paragraph 5.7 which the Group recommend
should be undertaken.
5.10: In order to facilitate planning, not least in relation
to the euro changeover, and to promote public awareness, the Group strongly
recommend that, whichever date is chosen for the Budget 2002, it should be announced
as soon as possible. This announcement should include details of the manner
in which any tax and social welfare changes will be implemented.
ANNEX
Comparison of Impact of Alternative Budget Dates
|
Consideration
Category
|
24 October 2001
|
5 December 2001
|
|
Impact on Budget/Estimates Process
|
Budget would be constructed on less robust economic and tax receipt
forecasts than at present. The further the decision making process from
the end of the year, the less accurate will be the available information
on emerging economic trends and tax receipts and base year expenditure.
Concern to ensure that the Estimates process would not effectively
be re-opened post Budget, with repercussions for Government's Budgetary
arithmetic
Ministers and Departments would be under considerable pressure to complete
the Estimates process within a compacted time period, with final Government
decisions on the Budget required by 25 September.
In 2001, Departments and Offices will be required to produce their
MAB and Estimates figures in euro for the first time. Shortening the
time available for compilation of Estimates would not be welcome in
this context.
Assessment: Carries downsides in terms of quality of
data on which decisions are made and lessens the timeframe for considerable
logistical and decision making process involved. Also poses risks for
the current Estimates process.
|
Provides a firmer basis for tax and expenditure decisions having regard
to developments and trends in the wider economy
Ensures the Budget remains the effective final step in the Estimates
process
In light of the complex nature of the Estimates process, allows more
time for consideration of Estimates and decision making at official
and Ministerial level
Avoids shortening the period for processing the Estimates which, in
2001, must be prepared in euro for the first time
Assessment: Decisions based on more up to date information.
Maintains existing timeframe for logistical and decision making process.
Greater assurance in relation to Government's financial management system.
|
| |
Tax Changes
|
Tax Changes
|
|
Employers
|
Provided Budget is straight forward, Tax Deduction Cards (TDCs)
will be received by mid-December in time for 1 January 2002 implementation
PRSI Changes (if any)
As with tax position
Assessment: Facilitates one change to employer payroll system,
including euro changeover.
|
Preliminary TDCs (effective from 1 January 2002) received October/November
2001.
Final (i.e. post- Budget) TDCs received February/March 2002.
PRSI Changes (if any)
Notifications received late February 2002
Assessment: Would require more than one change to employer
payroll systems.
|
| |
Tax Changes
|
Tax Changes
|
|
Employee
|
Post-Budget TFA certificates received in early January 2002
(but correct deductions applying from 1 January 2002)
PRSI Changes (if any)
Change implemented from 1 January 2002
Assessment: Tax and PRSI changes effective from due date
|
Interim TFAs received in October/November which will be operative from
1 January 2002. Post-Budget TFAs received in February/March
PRSI Changes (if any)
Change not implemented on time and retrospective corrective action
would be problematic due to weekly, non-cumulative nature of system
Assessment: Tax deductions for early months of 2002 will be
incorrect as they will still be based on the 2001 tax regime: correction
required in February/March. Limits scope for PRSI changes
|
|
Social Welfare Recipients
|
(i) EFT Paid (110,000)
Paid correct amount on time
(ii) Short term (260,000)
Paid correct amount on time
(iii) Long-term (520,000)
Paid in arrears or part arrears / part advance in mid-February 2002
Assessment: Best possible implementation given book printing
schedule
|
(i) EFT Paid
As 24 October
(ii) Short-term
Paid in arrears around mid-February 2002
(iii) Long-term
As 24 October
Assessment: Delayed implementation for short-term recipients
with associated systems difficulties.
|
|
Administrative
|
|
|
| |
Rates
|
Rates
|
|
DSCFA
|
Would allow timely implementation of rate increases for maximum possible
number of recipients
PRSI
Changes implemented on time
Assessment Strongly preferred position
|
Special arrangements required to pay arrears to 240,000 short term
recipients. Additional costs and administrative disruption.
PRSI
Changes not implemented on time
Assessment Not supported. Additional administrative burden
and poorer customer service
|
|
Revenue
|
Preferred administrative outcome from customer service viewpoint
Assessment: Preferred outcome
|
Assessment: - Increased administrative burden arising from
production of two sets of TDCs and TFAs (preliminary in October/November;
final in February/March)
|
|
An Post
|
- Extra pressure on mail deliveries during peak Christmas period.
- Additional generation of post-drafts for long-term SW recipients
Assessment Concerns about contractual compatibility
|
Additional generation of post drafts for short and long term recipients
Assessment As 24 October
|
|
Legislation
|
May require:
(i) amendment of the Provisional Collection of Taxes Act to allow Budget
Day Financial Resolutions to remain in effect for longer than 4 months
(ii) the passage of a basic Social Welfare Bill before Christmas (Minister
for Social, Community and Family Affairs is strongly of the view that
this is essential)
|
Requires clarification as to whether or not SW improvements and PRSI
changes could be implemented by Financial Resolution
|
Appendix 1
20.7.00
Tax Year to change for first time in 250 years |
|
Minister for Finance, Charlie McCreevy TD, announced today (20th July
2000) that from 2002 the income tax year will be aligned with the calendar
year. From that point, Budget day tax changes and social welfare weekly
rate improvements will be brought forward to 1 January. This will be of
importance to taxpayers and social welfare recipients who will benefit
earlier from Budget day changes compared to the current position where
tax changes apply from April and social welfare changes from May. [It
has been announced already that, in 2001, social welfare increases will
apply from April.]
The Minister said "Using the calendar year will put the collection
of income tax on a more rational and simplified basis. Combining this
change with the Euro Changeover will allow necessary changes to IT systems
to be made in one go".From 1 January 2002, the tax year will run
from 1 January to 31 December. This means that next year there will be
a tax "year" of nine months from 6 April 2001 to 31 December
2001. In tandem with the changeover to the calendar year there will be
a change in dates for filing of tax returns and payment of tax for self-employed
taxpayers. The new dates are attached as an appendix to this press release.
In order to facilitate the change, it will be necessary to have an earlier
Budget day rather than early December as at present.
There will be some timing costs to the Exchequer from the rephasing of
tax and social welfare changes.
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