Memorandum submitted by Roger Cockfield
I set out on a separate sheet my representations,
which can be summarised as follows. To solve the present tax credit
fiasco use an extended version of the PAYE system, so that WTC
and CTC are included in calculating the weekly tax tables. Thus
benefits are automatically adjusted on a weekly basis as earnings
fluctuate. The code number would reflect the family structure.
Provided the correct code has been issued, the total benefits
paid during the year will equal the benefits due for that year.
The cost of the £2,500 dead zone would be removed as no longer
necessary.
I have been working on the integration of income
tax, social security and national insurance contributions for
a number of years. I gave a paper on this at the ATAX Conference
in Sydney in 2000. I also submitted written evidence to the Social
Security Select Committee, which was published in their 7th Report
on Pensioner poverty, 2000 at pages 134-137. I have been cited
as an expert on tax/benefits in House of Commons debates on a
number of occasions. My highly critical article on the proposed
WFTC was published in Tolley's "Practical NIC"
October 1998. Their editorial comment was "WFTC seems a recipe
for a stunning PAYE administrative headache". Prior to retirement,
I was Reader in Taxation at De Montfort University.
SUMMARY
To solve the present tax credit fiasco use an
extended version of the PAYE system, so that WTC and CTC are included
in calculating the weekly tax tables. Thus benefits are automatically
adjusted on a weekly basis as earnings fluctuate. The code number
would reflect the family structure. Provided the correct code
has been issued, the total benefits paid during the year will
equal the benefits due for that year. The cost of the £2,500
dead zone would be removed as no longer necessary. Abbreviations
at end.
FACTORS THAT
CHANGE
The three factors that change are:
The factor that changes the most is fluctuations
in wage levels ( including moving job and being out of work) which
determine the amount of the 37% claw-back of WTC/CTC.
EXTENDED TAX
TABLES
Let us look at Table 1.3a on page 41 of DWP's
"Tax Benefit Model Tables April 2005". These
concern a Lone Parent with two children under 11 paying no childcare
costs. For wages between £160 per week and £440 per
week, the marginal deduction rate [MDR] or marginal effective
rate of tax is 70%.
Suppose HMRC pay the LP £114.97 [being
the total of WTC £39.51 and CTC £75.46 at the £160
gross earnings point]. The correct deduction due is 70% of the
excess over £160. Using extended tax tables, the weekly amount
of WTC/CTC would be correctly adjusted. This takes care of any
wage increase/ decrease within a fairly broad range.
The MDR of 70% is made up of NIC 11% plus Basic
Rate income tax 22% plus WTC/CTC taper rate of 37%.
Once modified to remove the impact of HB/CTB,
Table 1.3a could be used by the employer as extended tax tables
to cover the whole range of wages from £77.60 per week right
up to £900 per week. To start at £77.60 per week, HMRC
would need to pay the LP £137.13 [being the total of WTC
£61.67 and CTC £75.46 at the £77.60 gross earnings
point].
MOVING BETWEEN
EMPLOYERS
Moving between employers would involve the familiar
P45 procedure.
UNEMPLOYMENT
The next problem is how to deal with the individual
becoming unemployed. One option is for HMRC to pay £195.97
to the LP being the level of benefit income on IS/JSA(IB). The
employer would then deduct £30.44 from the opening gross
earnings figure of £77.60, and pay £47.16 to the LP.
This would bring the LP's net income up to the level shown in
Table 1.3a (after removing the HB/CTB amounts). Any earnings above
the opening figure would be dealt with using the extended tax
tables. When the employee left, no further action is required
by the employer beyond the P45 procedure, benefits payable by
HMRC are already at the unemployed level.
HOUSING BENEFIT/COUNCIL
TAX BENEFIT
There is also the option of using one set of
tables to adjust HB/CTB on a weekly cumulative basis. Determination
of amount of qualifying rent and council tax could remain with
the local authority. How much of the rent and council tax should
be paid and then withdrawn through extended tax tables is open
to debate.
CHILDCARE COSTS
One problem is linking childcare costs to fluctuations
in wages so that the taper can operate. Another is how to trigger
withdrawal of the relief if childcare facilities stop being used.
A possible solution might be to operate childcare relief along
the lines of MIRAS: this would mean that the subsidy is paid direct
to the childcare provider by HMRC.
Option 1
All claimants pay 30% to the nursery. The nursery
claims the balance of 70% on a rolling three month basis:
19th Month 1 Provisional payment
19th Month 2 Return of payments actually
recived
19th Month 3 Balance of payment for month
1 made or overpayment deducted from provisional advance for month
3.
Option 2
As above but claimants pay varying percentages
[30, 40, 50, 60% etc] of childcare costs to the nursery. The percentages
would be estimated by HMRC to reflect the estimated taper withdrawal.
COMPUTER SYSTEM
A local system, based on readily available spreadsheet
programs, would improve communication and understanding by recipients.
Many HMRC/DWP's calculations of benefits and tax credits are difficult
to understand let alone follow. Very few people can work out the
impact on their benefits and tax credits position if they save
an extra £1,000.
OTHER PROBLEMS
Call centres and helplines are most frustrating.
For other than general enquiries, contact direct with the caseworker
is essential. The cost of the tax credit fiasco must outweigh
many times all the alleged savings in staff.
OVERPAYMENTS AND
INCENTIVE TO
REPORT
If my extended version of PAYE is not adopted,
the following would reduce the problem of overpayment. If payments
during the year totalled 80% of the expected full year figure,
there would be a strong incentive to file the end of year return
of income to receive the balance of 20%. This balance would be
a useful method of saving for holidays, pension etc. An 80% payment
would remove most overpayments from the system.
ABBREVIATIONS
CTB Council Tax benefit
CTC Child Tax Credit
DWP Department for Work and Pensions
HB Housing Benefit
IS Income Support
JSA(IB) Job Seekers Allowance ( Income Based)
LP Lone Parent
MDR Marginal deduction rate or marginal
effective rate of tax
WTC Working Tax Credit
December 2005
|