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Ajit Ranade: Taxing the unborn
Infrastructure is built for the future generations, and hence they must share the burden
Ajit Ranade / Aug 24, 2010, 00:47 IST

Usually facts speak for themselves, but when it comes to economic facts, they seem to vary as per the eyes of the beholder. This variation is often not about the facts themselves, but in their interpretation. Is the glass half full or half empty? (Both, actually!) Is the poverty rate of 35 per cent too high or decently acceptable? (It is 35 per cent). But there are some economic facts about which we have a national consensus. The first fact is that we have a huge backlog of unbuilt infrastructure. This includes not just power, roads, railways, ports but also schools and hospitals. The prime minister recently quantified this backlog as about $1 trillion, to be bridged in the next five years. The second point, on which there is near unanimity, is that India’s tax to GDP ratio is among the lowest in the world, at least among peers such as the largest 20 economies. Granted that 20 per cent of India’s GDP is constitutionally insulated from the taxman, which is the income from agriculture. Hence the ratio of tax to taxable GDP is more respectable, but still lower than most large economies. The third fact on which there is grudging consensus is that India’s infrastructure is far below that of China. Opinions may differ on how we got so behind, or whether China’s strategy of building capacity ahead of demand is a wise one. The fourth fact is that to build that $1 trillion of new infrastructure, we will need a lot of private investment. How much is a lot? It could be between 5 per cent and 30 per cent. That would still be infinitely more than the share of private investment in Chinese infrastructure, which is close to zero.

These four facts taken together — huge backlog, low tax to GDP ratio, limited role for private participation and Chinese benchmark as aspiration — point to an inescapable tax policy prescription. But first some background.

Since we are using China as a comparator, we need to incorporate three pertinent features unique to China. First, Chinese infrastructure was built almost entirely by public money. There was very little private investment. Secondly, China is facing a rapidly aging population. And thirdly, the level of non-performing banking assets (NPAs) in China are disproportionately large. By some estimates, the NPAs could be as high as 30 per cent of total bank assets. These three apparently unconnected features are actually intertwined.

The policy of purely public expenditure ensured there was no need to sweeten infrastructure deals with government guarantees for private investors (remember Enron?). Hence there were no hurdle rates of return to be scaled, no payback periods to be assured. Capital markets for bonds did not exist, and there was no need to hunt for private investors. Infrastructure project funding decisions were probably based less on social cost-benefit analysis and more on gut feel and conviction. Hence it was all public spending, pushed by bank finance. That inevitably led to a build-up of NPAs, since there was insufficient demand. But the Chinese view has been, better NPAs in the form of brick and mortar rather than cash sitting in squeaky clean bank balance sheets. After all, if these asset horizons are very long, then who cares about NPA definitions which recognise horizons of only 90 or 180 days overdue? The high-speed Maglev bullet train, which connects Pudong airport to Shanghai, used up $2 billion, and covers a distance of 40 km in four minutes. But even at the best of times, its occupancy is around 10 per cent. Either the ticket is too high or the demand has not yet caught up. So, this is an NPA, but not as per Chinese accounting. The Chinese rush to build infrastructure is a race against an adverse dependency ratio. The ratio of young workers to old pensioners is declining rapidly. If the rate at which new generation of workers (who are taxpayers) slows down, there is that much less room for public spending, which makes it difficult to postpone the burden to future generations.

The policy takeaway from the “four facts” of India’s infrastructure and lessons from China is that we will need to depend largely on public spending, and that we can increase substantially the tax burden on unborn generations. Infrastructure assets are long-lived, and their beneficiaries span several generations. To the extent that infrastructure has a public good nature (i.e. once built you cannot exclude people), it is inevitable that a large portion will have to be financed by public spending, i.e. tax revenues. Despite the huge push given to public-private partnership, at best we can expect only one-fourth of the funding to come from private sources. Hence, public spending needs to be supported by an appropriate tax base.

Instruments like long-term infrastructure bonds are a disguised form of taxation, since the bonds need to be repaid from future revenues. Thus, public spending is equal to more taxation.

The future, unborn generations as tax base for infrastructure makes sense both morally and rationally. Since India’s dependency ratio will remain favourable for much longer than that of China, passing the buck to the future will be that much easier. Owing to the demography advantage, a rupee postponed from today to tomorrow will be less than a rupee per capita. Thus infra spending is both a gift and a (partial) bill to tomorrow’s generation.

It is also important to note that the fiscal expansion that is implied by infrastructure spending is less susceptible to be stolen by foreigners. Other fiscal stimuli like cash for clunkers in the West, or many other job-creation initiatives can potentially leak away to low-cost economies. According to this view, a bulk of the stimulus in Europe and America was stolen away by China. The emerging market export economies can thus harvest rich economy fiscal stimuli. Not so with infra spending. A road cannot be manufactured in low-cost China to be imported into India. Infrastructure is the so-called non-tradeable sector, and public spending on it will firmly remain within India.

And one last point. Just as we need to increase the tax on the unborn to fund infrastructure which they will enjoy, we also need to tax the dead. The inheritance tax in India is one of the lowest, leading to a big and persistent skew in wealth distribution for many generations. Increasing inheritance tax will help the exchequer, and also lead to greater inter-generational equity. The unborn will thank you.

The author is chief economist, Aditya Birla Group. The views expressed are personal

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Latest Messages
Posted by: Welingkar
Ajit Ranade's has given some good insights into infrastructure development- especially with so much focus and circumspection here in India on China's relatively fast-track growth. However I think he missed a key point, which bedevils India especially in the post-libralisation era. The decision on the type and nature of infrastructure to be developed is often left to the wisdom of politicians and bureaucrats, with almost no public participation. Witness the turmoil in so many parts of the country- especially in rural India where people have been conned into parting away land for projects that benefit a few individuals or companies. When you have limited resources it is important that the project really benefit and give a boost to the economy and not just to the pockets of a few well-connected individuals. Money not spent well is just a drain- something we can ill afford at the moment.
Posted by: K.Mundanad
Another application of the phrase: taxing the unborn: is on foreign technology imports. On lump sum payment of technical know-how fees, foreign technical collaborators insist for net of tax payment, with the result that tax on tax also has to be borne, under section 195A of the Income-tax Act, 1961, by an "unborn company" (i.e. at the pre-project stage). For example, if the TDS rate is 10 per cent (excluding surcharge, etc.) and the amount of fees payable is Rs.100 lakh, then after adding the multiplier effect of tax on tax, the amount of fees would be Rs.111.11 lakh, by applying the formula as follows: P = r +100 * r / 100 - r = 11.11, where ?P' is the tax rate after adding the multiplier effect of ?tax on tax' and ?r' is the rate of tax. In this liberalized era, tax payment should be deferred to post-completion, or the commissioning, date of the project and "tax on tax" must be dispensed with.
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