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Tax Base Broadening
Tax Base Broadening
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Research Folio 33
By M. Muneer Qureshi
DG (DOT)(DT)
T he mobilization of tax revenue has a direct nexus with the number of taxpayers
participating actively in the system set up to levy and collect taxes. In the case of
Income Tax the number of persons filing periodic ‘Returns’ vis a vis the total
population of the country, is a key indicator of the ‘Tax Base’ for the direct taxation
of income earned by individuals and other entities including corporate entities recognized as
‘persons.’
Over the years Pakistan’s (Income) Tax Base has been more or less stable at 1% or less
of the total population. In the United States, 72 million Returns of Income are filed annually
with the I.R.S which, given a population of 300 million, translates into a tax base of just over
24%. In Malaysia, the tax base is about 20%. In Turkey, 5%. In India, 2%. The ‘tax to GDP’
ratio has a direct correlation with the tax base size and Pakistan’s poor tax base therefore
means a poor tax to GDP ratio [ 10%] which ofcourse means poor tax revenues. In fact
Pakistan is placed at the lower end of the ‘T2gdp’ spectrum whereas those at the higher end –
typically, the Scandinavian countries led by Sweden and Denmark- score well over 40%.
What are the reasons for this dismal tax base picture?
To begin with, the largest single sector of the Pakistan economy, agriculture, generating
22% of GDP , occupied by 50% of the total population [ ie 80 million plus] and 42.5% of the
total labor force [ ie 20 million] pays zero income tax to the federal exchequer because it is
‘exempt’ from payment of income tax under the statute ie the Income Tax Ordinance of 2001 –
in fact this sector has been ‘exempt’ since 1947 and the Income Tax Ordinance of 2001 is the
third income tax statute to ‘renew’ the exemption originally available for agriculture in 1947
when the Income Tax Act 0f 1922 was adopted as the Income tax Statute for Pakistan.
Secondly, Pakistan’s huge and burgeoning ‘Informal sector’ – also known as the ‘black
economy’ and the ‘parallel economy’- appraised variously at 35 to 55% of formal GDP- and
employing some 20 million out of the total labor force of 47 million. Thus between them, these
two sectors, take away 110 million out of the total population of 165 million from the ‘tax net’
leaving barely 55 million to bear the burden of tax on income.
It is to be noted that in Pakistan there are some 24 million bank account holders. This
means in effect that after accounting for the 1.7 million who do file Returns of Income
annually, more than 22 million do not do so. Why? Is their ‘Income’ Exempt? Is is below the
taxable limit? No body seems to know. The banks ofcourse have all the relevant data regarding
these account holders but the department of Income Tax has no authority to demand these
details ‘en masse.’ Nonetheless this data base is there and is a veritable treasure trove of
information that could have a direct bearing on the income earned by the account holders.
Strictly on merit it is neither fair nor logical to make a distinction between agricultural and
non-agricultural incomes for purposes of taxation. A distinction so made arbitrarily amounts to cre-
ating a preference for one class of income over the other. Instead of creating such a preference for
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which there appears to be no economic justification, it is suggested by the counter exemption lobby
that just as business and salary incomes below a certain level are exempted from income tax, the
same principle should be extended to agricultural cultural income. This would take care of the
subsistence farmers who would be automatically excluded.
Levy of income tax on agricultural income is also recommended to reduce the evasion of income
tax in Pakistan which is by all accounts, considerable. The availability of statutory exemption for
agricultural income has resulted in the systematic exploitation of this exemption by those enjoying
non agricultural income. Through the simple expedient of attributing part of their income to
agricultural activity they are able to secure substantial tax benefits. In reality of course such people
are not actually significantly engaged in agriculture at all. However since they have purchased
agricultural land-which may be marginal land or even wasteland (banjar) for all they care- it is not too
difficult to hoodwink the federal tax authorities on the bonafides of the investments made by them
and attributed to the earnings of their agricultural holdings.
On another and more subtle plane, the "phantom" flow of funds from agricultural to non
agricultural business contrived artificially through the creation of "ghost" liabilities, has pro-
vided legal cover to substantial investments funded by accumulations of untaxed "black"
money. Had agricultural income been subjected to income tax then it would not have been so
simple a matter to create such liabilities as the affairs of the agriculturist would have been as much
subject to scrutiny as the person engaged in business. So far however, the income tax authorities
have no direct record of the agricultural activities. Only sketchy information of dubious origin is relied
upon to decide on the bonafides of a reported liability shown as owing to the agriculturist. Again,
since bank accounts are as a rule not reported to the tax authorities - only those accounts are
reported that "suit" the taxpayer, the cash flow of funds constitute an added impediment in this
context as these cannot be monitored.
Thus if incomes generated through agriculture were made taxable, the "facilities" presently
available through the "devices" mentioned above, for securing huge unwarranted tax benefits, would
be effectively neutralized.
The feasibility of mobilizing revenues from the agricultural sector through direct taxation of
income generated there is also apparent from the fact that the agricultural income tax would be more
income elastic than land revenue. With a greater yield per acre, higher procurement prices and
mechanization, incomes in the agricultural sector have risen considerably, but yield, in terms of direct
taxes on agriculture, has lagged behind appreciably. To illustrate the point, it is pointed out that
between 1972 -73 and 1978 -79, the yield from the direct taxation of agriculture (land revenue and
irrigation charges) increased by 78%, while value added in agriculture, at current factor cost,
increased by 157%. There is every reason to say that this trend continues to this day.
That the taxable capacity of the larger farmers (who constitute the rural elite) has improved
over time is evident from the considerable increase in consumption expenditure of the rich farmers.
According to Alavi, even when there are adverse changes in the terms of trade for agriculture, the
rural elite enjoy considerably enhanced real incomes.
The conspicuous consumption of the rural elite is not only an indication of the steadily
increasing affluence of the rich farmer but it is also a pointer to another evil - that of accentuating
differences in income distribution in the agrarian sector. Progressive rates of income tax, if applied to
the income of this rural elite, could, over time, alleviate this malady, the persistence of which can only
bode ill for the social stability of agraria and for the politico economic well being of the country in
general.
However one looks at it, there appears to be little justification for a blanket exemption for
agricultural income. There is no denying that the small farmer with a limited landholding may not be
able to bear the burden of additional taxation.
However barring such exceptions, levy of an income tax would appear to be fully justified -
and even necessary if the negative perception in the other sectors of the economy of such blanket
exemption from levy of income tax for the agriculture sector is to be corrected. It is now
acknowledged that one of the important reasons for tax evasion in Pakistan in the other sectors of the
economy is this ‘unjust preference’ for agricultural income which provides a justification for tax payers
enjoying non agricultural income to justify and rationalize tax evasion on their part.
In a historical context too, in the case of post Meiji era Japan in the 1880’s when the drive to
modernize the country was launched aggressively, taxation of agricultural income was the principal
source of revenue to fund the industrialization drive. Paradoxically, the taxation of agricultural income
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in Japan did not ‘ruin’ Japanese agriculture as many had predicted. Rather, once the agriculturist
realized that agricultural income would ‘have’ to suffer tax, the agriculturist made concerted efforts to
increase agricultural productivity by systematic use of natural and chemical fertilizers, use of
insecticides and pesticides, better crop rotation, use of improved quality seed , improved water
management, use of machinery – the tractor and harvester- , all of which resulted in greatly increased
productivity and consequentially, sharply increased income for the farmer which increase made it
possible for him not only to pay tax but also left him with a healthy surplus. Part of this surplus was
then used to improve the farmers standard of living and quality of life.
It is clear that this improvement in agricultural productivity would not have been possible had
there been no ‘slack’ in the agriculture sector. Prior to the modernization drive launched in Japan in
the 1880’s, agriculture was entirely feudal in it’s organization and structure and absentee landlords
owning vast tracts of land let out to harshly exploited tenant farmers had little impetus to increase
agricultural productivity. All this changed dramatically once reforms were introduced and taxation
levied on agricultural income.
In Pakistan, after almost sixty years of independence, there has been little ‘real’ change in the
traditional, feudal complexion of our agriculture. True, land reforms have been introduced – but these
have been largely cosmetic. The powerful feudal families owning much of the rural land have
succeeded in making a mockery of the land reforms by resort to phoney land re-distribution on paper
with the active connivance and collusion of the provincial revenue authorities whose parasitic
dependence on the ‘largesse’ of the feudals has made them more than willing partners in this
reactionary enterprise. As in pre Meiji era feudal Japan, these feudals have little interest in pressuring
the tenant farmers to augment land productivity. All they want is their ‘ share’ and once they have
received that they call it ‘quits’ and return to their comfortable lives. They know that they will suffer
no tax on their income and this adds to the ‘surplus’ that is available to fuel a cycle of conspicuous
consumption.
That there is a considerable ‘slack’ in the agricultural sector in Pakistan is quite evident from
the available statistics [– Source: F.A.O ]. Thus, (in 2004) with a total land area of 0.9% under
cultivation, Pakistan’s agricultural production index is pitched at 109 [base year 1989-91=100]. With
an identical land area under cultivation, Brazil has a production index of 125. Egypt with 0.5% land
area under cultivation has a production index of 109 – the same as Pakistan’s but with far less land
under cultivation. Russia has just 0.1% of land area under cultivation and it’s agricultural production
index is 114.
In the case of aggregate cereal production [wheat, rice, maize], Pakistan is ranked 18th in the
world [33 mill tons] while in yield it is ranked 87th in the world [2423 kg per hectare]. Similarly, in
the case of cotton production Pakistan is ranked 4th in the world [6.6 mill tons] but in yield is ranked
27th [1935 kg per hectare]. Again, in sugarcane production Pakistan is ranked 5th [57.4 mill tons] and in
productivity is ranked 58th [49576 kg per hectare].
The above indices clearly show that there is considerable scope for improvement in agricultural
productivity in Pakistan and relying on the historical experience of post Meiji era Japan, there is every
reason to expect that the right set of policies – including taxation of agricultural income- will increase
agricultural productivity significantly and will enable the farmer to not only pay tax on his significantly
increased income but to also improve his own standard of life – as has admittedly happened in the
case of Japan – one of the outstanding success stories of our times.
Coming now to the informal sector, compulsory (statutory) documentation of all economic
transactions is probably the single most important step that can make a significant impact in reducing
the size of this sector. A beginning has been made [after 60 years!] and the new income tax
ordinance of 2001 now makes it mandatory for all businesses to maintain ‘prescribed’ accounts.
However much more needs to be done especially in the case of the large ‘illegal segment’ of this
sector where smuggling /hoarding /profiteering and widespread ‘underground manufacture’ and sale
of spurious and counterfeit goods with brazen violation of copyright laws generate huge profits on
which no tax is paid. A great deal of deterrence will have to be built into the tax code by enactment of
appropriate punitive laws. High profile tax evaders need to be taken to task and prosecuted
aggressively. Their successful incarceration in a State penitentiary for a protracted period is essential
if the criminal elements in the informal sector are to be deterred effectively.
With regard to reducing inequalities in the distribution of income, the traditional reliance on the
so called ‘progressive’ tax rate structure alone does not appear to have been very successful and
much more needs to be done by re-introducing Wealth Taxation and also by direct state intervention
to help and facilitate the disadvantaged and underprivileged members of society through better
education facilities and healthcare and easier access to institutional credit so that they are able to
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We have to realize that economic prosperity must ‘trickle down’ to the under privileged sections
of society and if the existing institutional arrangements and market forces do not facilitate such a
‘trickle down’ then the State must intervene and ensure that the fruits of prosperity do flow to all
sections of society and do not remain concentrated in a few hands.
Given greater sectoral equity with regard to levy of tax on income, meaningful reduction in the
size of the informal sector and reduction in income inequalities in the distribution of income, there is
no reason why the tax base should not be greatly enlarged in size and scope so that we have not only
many more taxpayers who file Returns of Income regularly but also declare significantly higher levels
of income and eventually when all is said and done, it is these two aspects that will bring about the
quantum jump in revenues that is presently, only a distant dream.
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According to researchers and government statistics, in Pakistan 40% of the richest landowners own
70% of the arable land
2 Djibouti 166,795
3 Kuwait 34,032
4 Bahrain 28,145
5 Andorra 23,310
6 Brunei 12,396
7 Iceland 10,396
8 Malta 10,153
9 Maldives 8,632
10 Oman 8,384
13 Japan 6,879
16 Egypt 5,361
18 Bangladesh 4,284
41 China 2,168
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61 Pakistan 1,694
71 India 1,562
83 Italy 1,357
99 Iran 1,116
187 Australia 98
2 Benin 133
3 Brunei 133
5 Tajikistan 131
6 Brazil 125
7 Romania 125
8 Kuwait 125
9 Nicaragua 124
10 Morocco 122
18 China 118
25 Sudan 115
26 Indonesia 115
30 Russia 114
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40 Iran 111
52 Pakistan 109
55 Egypt 109
62 Mexico 108
89 India 105
93 Bangladesh 105
95 Turkey 105
159 Italy 95
2 Canada 1,454.2
3 Kazakhstan 1,287.1
4 Argentina 901.4
5 Russia 851.4
6 Lithuania 811.5
7 Latvia 771.8
8 Guyana 688.5
9 Ukraine 667.8
35 Turkey 358.0
39 Brazil 337.4
46 France 309.8
51 Afghanistan 295.0
65 Iraq 246.4
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66 Mexico 243.4
76 Iran 215.8
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57 Iraq 169,235
66 Malaysia 127,320
70 Italy 116,341
91 Bangladesh 56,977
3 India 249,486,120
4 Russia 82,083,611
5 France 76,804,642
6 Indonesia 71,054,053
7 Brazil 70,844,274
8 Germany 56,009,539
9 Canada 55,286,644
10 Ukraine 46,117,398
11 Bangladesh 43,245,877
13 Australia 38,859,229
14 Turkey 37,441,855
16 Mexico 33,345,896
18 Pakistan 32,681,325
24 Italy 24,653,192
26 Iran 24,372,103
27 Egypt 22,134,251
44 Afghanistan 6,102,395
52 Iraq 4,506,800
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73 Malaysia 2,489,746
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3 India 7,936,641
4 Pakistan 6,613,868
5 Brazil 3,993,872
6 Uzbekistan 3,891,159
7 Turkey 2,832,940
8 Turkmenistan 2,425,085
9 Australia 1,304,034
10 Greece 1,212,542
12 Egypt 826,733
24 Iran 341,717
29 Mexico 205,192
42 Afghanistan 61,178
47 Bangladesh 49,604
57 Iraq 21,605
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2 India 269,845,810
3 China 102,735,410
4 Thailand 70,225,246
5 Pakistan 57,364,280
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6 Mexico 49,743,451
7 Colombia 40,895,749
8 Australia 40,666,468
9 Philippines 30,864,716
11 Indonesia 27,116,858
17 Egypt 18,006,255
20 Iran 7,165,024
21 Bangladesh 7,147,387
50 Malaysia 1,322,774
81 Iraq 71,650
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2 India 79,432,552
4 Russia 46,517,537
5 France 43,696,722
6 Germany 27,939,182
7 Canada 26,965,070
8 Australia 24,802,004
9 Turkey 23,148,537
10 Ukraine 22,279,585
11 Pakistan 21,789,387
12 United Kingdom 17,312,901
14 Iran 15,432,358
19 Egypt 7,912,231
21 Brazil 6,653,000
28 Afghanistan 4,807,180
35 Mexico 2,755,778
48 Bangladesh 1,381,196
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2 India 137,127,530
3 Indonesia 58,532,845
4 Bangladesh 41,788,621
5 Vietnam 39,132,051
6 Thailand 27,778,245
7 Myanmar 25,353,160
8 Philippines 15,652,820
9 Brazil 14,722,800
10 Japan 12,566,349
12 Pakistan 8,344,497
14 Egypt 6,613,868
18 Iran 3,747,858
24 Malaysia 2,407,073
38 Australia 589,737
41 Afghanistan 477,301
43 Turkey 440,925
55 Mexico 211,137
59 Iraq 165,347
2 China 145,350,770
3 Brazil 46,238,657
4 Mexico 22,046,226
5 France 17,353,687
6 India 15,432,358
7 Romania 14,584,714
8 Argentina 14,330,047
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9 Indonesia 12,521,208
10 Italy 12,478,164
13 Canada 8,889,369
22 Turkey 3,306,934
32 Pakistan 1,984,160
2 Burkina Faso 92
3 Rwanda 92
4 Uganda 90
5 Guinea 87
6 Mali 86
7 Guinea-Bissau 85
8 Tanzania 84
9 Chad 83
10 Mozambique 83
27 Afghanistan 70
33 India 67
38 Bangladesh 62
52 Pakistan 48
53 China 47
57 Indonesia 44
65 North Korea 38
69 Turkey 33
75 Egypt 30
89 Iran 23
95 Brazil 21
105 Mexico 18
106 Malaysia 18
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148 Italy 5
150 Australia 5
163 Denmark 3
164 Germany 3
165 France 2
170 Canada 2
6 Grenada 29.4
7 Maldives 26.7
8 Samoa 24.4
9 Comoros 23.3
13 Malaysia 17.6
29 Italy 9.4
37 Indonesia 7.3
52 Israel 4.0
55 Turkey 3.4
59 Bangladesh 3.1
63 India 2.8
95 Mexico 1.3
96 Iran 1.3
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98 China 1.2
2 India 556,592
3 Indonesia 92,596
4 Bangladesh 77,387
5 Pakistan 75,883
6 Ethiopia 57,319
7 Vietnam 53,797
8 Nigeria 37,977
9 Myanmar 34,278
14 Brazil 26,471
15 Egypt 24,977
18 Mexico 22,442
19 Turkey 20,630
22 Iran 17,253
23 Afghanistan 15,761
25 Russia 13,890
89 Germany 1,804
90 France 1,736
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