22.The exchequer departments define ‘environmental taxes’ as those with explicit environmental objectives. There are currently four that meet this definition (paragraph 17). Other taxes can have environmental impacts. Indeed the 2021 Dasgupta Review on the Economics of Biodiversity (commissioned by HM Treasury in 2019) argues that our economy is embedded in nature and is not external to it, and as such all our fiscal measures have an environmental impact in so far as they either encourage or disincentivise different behaviours. The exchequer departments recognise that both Air Passenger Duty and fuel duty have an environmental impact by increasing the cost of polluting forms of travel. These taxes do not have environmental objectives and thus the exchequer departments’ primary measure for assessing the taxes’ performance has been the revenue they raise. However, HM Treasury told us they do advise Minsters on environmental impacts, including of previous fuel duty freezes, before decisions are taken on tax rates.
23.The March 2021 Budget does not include any new tax measures with environmental objectives but it does include other tax measures that are likely to have an environmental impact. In March 2021 the Office for Budget Responsibility (OBR) said the most significant contributor to the economic recovery measures in the Budget was the introduction of a time-limited 130% capital allowance super deduction from Corporation Tax that will be in place in 2021–22 and 2022–23. The OBR said the deduction provides a very strong incentive to bring investment forward from future periods, supporting economic recovery. The deduction is forecast to cost a total of £25 billion in 2021–22 and 2022–23. HM Revenue & Customs (HMRC) told us that the capital allowance was available to all businesses in the tax system. We are concerned that the capital allowance is not subject to an environmental or green ‘filter’ and it could lead, for example, to an increase in fossil fuel investments.
24.If Parliament is to be able to effectively scrutinise the environmental impact of tax changes it needs good quality information. For each tax policy change, the exchequer departments publish a Tax Information and Impact Note (TIIN) explaining the objective of the change, and its revenue and other impacts. The NAO found that for tax changes with an environmental objective, TIINs described but rarely quantified environmental impacts. We asked the exchequer departments why they did not require the expected environmental impacts of tax measures to be quantified in TIINs. HM Treasury told us that decisions on what analysis to publish were for ministers. However, HMRC told us its analysts quantify impacts whenever they can, and that work depended on analysts having models and methods to do this. It said that progress was being made in quantifying impacts, citing the quantification of expected carbon reductions from the new plastic packaging tax, but it also recognised that it had more to do.
25.The NAO found that HMRC monitors tax receipts for the four environmental taxes it administers but it collects little other data to understand changes in behaviour. Monitoring Landfill Tax receipts enables HMRC to collect and report data on the volume of waste going to landfill sites, which declined by 65% between 1997 and 2014. But monitoring revenue alone does not enable HMRC to understand how the diverted waste is disposed of and whether that is more or less environmentally harmful than it going to landfill.
26.We asked HMRC what it had done to quantify the impact of Landfill Tax on the exporting of waste and fly-tipping. HMRC said that it knew there is a risk that Landfill Tax will incentivise illegal dumping or exports, but said other departments had lead responsibility for these forms of waste disposal, with local authorities also having responsibility for fly-tipping. HMRC said it did not hold information on fly-tipping. But it added that while there is evidence that fly-tipping is a growing problem, it had found no clear correlation between fly-tipping and rates of Landfill Tax. HMRC stated it was supporting the work of other departments on exports, including through the joint waste crime unit, but the witnesses did not know how much Landfill Tax was lost from waste being illegally exported.
27.We also asked about the impact of the Carbon Price Support on the amount of electricity the UK imports. The Carbon Price Support is levied on around 100 electricity generators located in Great Britain on the fossil fuels supplied to them. The departments confirmed that the tax increases the price of domestically generated electricity from fossil fuels compared to imports. They also said they had not assessed the impact of the tax on imports.
28.Evaluations can help the exchequer departments to understand whether environmental taxes are achieving their objectives and how they are changing behaviour. However, since 2010 HMRC has evaluated only one of the four environmental taxes, in part because it has not secured the necessary resources. HMRC confirmed its 2014 evaluation of Landfill Tax was based on qualitative interviews rather than quantified evidence. The NAO found that HMRC had only limited information on the impact of tax reliefs with an environmental impact. These include tax reliefs with environmental objectives, such as those which support energy saving and clean technologies, and large reliefs which are likely to affect the cost of producing or consuming products made from fossil fuels.
29.HMRC told us that it shared with this Committee and the NAO the ambition to evaluate more tax measures. HMRC said it had therefore secured an additional £2 million for evaluation in 2021–22. In 2020–21, HMRC’s central budget for commissioning external research, including evaluations, was £2 million. HMRC also told us that it would be publishing a new evaluation framework later in 2021, to set out the overall principles and approach it will be applying.
30.As we explain in Part One, the Department for Environment, Food & Rural Affairs (Defra) has lead responsibility for all environmental policy areas, apart from climate change mitigation on which the Department for Business, Energy & Industrial Strategy (BEIS) leads. The exchequer departments, HM Treasury and HMRC, are expected to consider the government’s overall environmental objectives when undertaking their work. Other departments also have a role. For example, the Department for Transport leads on the government’s strategy to reduce carbon emissions from cars and make roads less congested and polluted by promoting lower-carbon-emitting transport.
31.The NAO found that some recent environmental strategies mentioned tax measures which have an impact on government’s environmental goals, and some of these strategies included a brief consideration of the impact of tax measures or their interaction with other policy measures. But the NAO also identified gaps, particularly relating to taxes which do not have an environmental objective, such as fuel duty. HM Treasury stated that it worked with other departments when designing taxes, for example working with Defra on the most effective combination of tax and regulation to reduce use of single-use plastic in packaging.
32.We found the picture for cross-government working on the operation of a tax was more complex when we looked in detail at Landfill Tax and the Carbon Price Support. Landfill Tax has had both positive and adverse impacts, and HMRC described it, and by extension all environmental taxes, as “a relatively blunt financial incentive”. A 2018 independent review of serious and organised crime in the waste sector said that since its introduction in 1996 the tax had “been transformational in commoditising waste as a resource, but a consequence of its introduction has been to increase the attractiveness of the market to organised crime”. HMRC estimates that the misclassification of waste at authorised landfill sites and waste disposed at unauthorised sites reduced Landfill Tax revenue by around £275 million in 2018–19 (28% of the tax due). This figure does not include tax lost from the illegal exports of waste and from fly-tipping.
33.HMRC expressed the opinion that Landfill Tax “needs to be complemented by regulation and effective enforcement of that regulation” to deal with the negative behaviours incentivised by the tax. When we asked HMRC about both exports of waste and fly-tipping, it told us that other departments had lead responsibility for these areas. We asked HMRC with whom it had engaged on the impact of Landfill Tax. It said that it was in contact with a range of different departments and in particular it worked with the Environment Agency. It gave the example of how it had worked with the Environment Agency to react to the increasing use of unauthorised landfill sites that HMRC said had been seen around four or so years ago. HMRC said this joint work had resulted in a legislative change which from 2018 had brought unauthorised sites into the scope of tax. HMRC also referred to the new joint unit on waste crime that has been set up to work in partnership with organisations such as the National Crime Agency to deal with criminal gangs. This unit was established in 2020 in the Environment Agency, in partnership with HMRC, the National Crime Agency and others, and was in response to a recommendation by the independent review into serious and organised crime in the waste sector in 2018.
34.The Carbon Price Support is one of a number of policy interventions which has contributed to the large reduction in coal used by electricity generators based in Britain. However, the Mineral Products Association told us that the environmental outcome of the Carbon Price Support must be set against its wider impact on competitiveness, especially considering the impact of carbon leakage (which is the offshoring of carbon generating activities in response to domestic policies to control emissions). As explained above, the Carbon Price Support gives a price advantage to imports over domestic electricity generation from fossil fuels. As there are large untapped renewable energy resources in the UK, we asked HM Treasury whether it was happy for the UK to carry on importing electricity. HM Treasury said that BEIS lead on energy policy, and it had a constant dialogue with BEIS on energy issues, including renewable energy. However, it could not say what the government’s position was on imported electricity or whether it had discussed with BEIS the impact of the Carbon Price Support on imports.
35.The apparent lack of leadership and coordination on environmental tax measures, mirrors findings in our recent reports examining how the government is organised to deliver environmental goals. In our February 2021 report, Achieving government’s long-term environmental goals, we found that Defra had not shown that it had the clout to lead the rest of government. While in our March 2021 report, Achieving Net Zero, we found that government did not have a coordinated plan for net zero by 2050 despite setting the target almost two years ago.
40 C&AG’s Report, para 1.6
41 Q 87
42 Q 45; The Dasgupta Review, The Economics of Biodiversity: Headline Messages, February 2021, page 2
43 Qq 50, 82: C&AG’s Report, para 2.5
44 Q 1
45 Office of Budget Responsibility, Economic and Fiscal Outlook, CP 387, March 2021, paras 1.34, 3.11
46 HM Treasury, Budget 2021: policy costings, March 2021, page 18
47 Qq 1, 4
48 C&AG’s Report, paras 1.15–1.16
49 Qq 42–43
50 C&AG’s Report, paras 19, 1.21
51 Q 22: C&AG’s Report, paras 13, 1.23, Case study 1
52 Qq 23, 54
53 Qq 23–24, 54, 60, 83
54 Qq 67–68; C&AG’s Report, Figure 2
55 C&AG’s Report, paras 1.30–1.31, 1.33
56 Q 25; C&AG’s Report, para 1.31
57 C&AG’s Report, paras 16, 2.9–2.10, 2.12, Figures 12–13
58 Q 74; C&AG’s Report, para 1.33
59 C&AG’s Report, para 3
60 C&AG, Reducing carbon emissions from cars, Session 2019–2021, HC 1204, 26 February 2021, para 2
61 C&AG’s Report, para 2.14, Figure 14
62 Q 14
63 Qq 21, 54
64 Serious and organised waste crime review, Independent review into serious and organised crime in the waste sector, November 2018, page 1
65 C&AG’s Report, para 13
66 Q 54
67 Qq 24, 54
68 Qq 21–22; C&AG’s Report, para 13
69 C&AG’s Report, para 13; Department for Environment, Food & Rural Affairs, Environment Agency, HM Revenue & Customs, National Crime Agency, Natural Resources Wales, Press release, Clock is ticking for waste criminals as new taskforce launched, January 2020
70 C&AG’s Report, para 1.28, Figure 8
71 Ev 4, Mineral Products Association, para 15
72 Qq 69–70
73 House of Commons Committee of Public Accounts, Achieving government’s long-term environmental goals, Fortieth Report of Session 2019–21, HC 927, February 2021, page 3
74 House of Commons Committee of Public Accounts, Achieving Net Zero, Forty-Sixth Report of Session 2019–21, HC 935, March 2021, page 3