The budget of 1986 is a very serious attack on investment and I propose to give some precise examples in the first instance of how it has undermined what is already a very weak investment climate. Then I shall deal in more general terms with its lack of direction.
The budget in a mistaken, naive, and ideological attack on financial institutions has succeeded instead in seriously damaging the flow of investment for productive purposes. The most major problem which Ireland faces today is that of mounting unemployment on which we are all agreed, and the ESRI tell us in a recent study that the figure will reach 250,000 by the end of the decade if we continue on our present course. Viable long term jobs can be earned only through the production of goods and the performance of traded services. This means that viable long term jobs can be earned only by enterprises in the private and public sectors. An enterprise cannot even come into being unless there is investment. The budget in attacking the flow of investment to productive enterprises has made a direct attack on jobs and on living standards. There are at least six specific ways in which this attack has been made, although it is undoubtedly possible to find very many more negative points in the budget that I shall deal with later.
In relation to section 84 the stamp duty of 12 per cent on interest paid in respect of section 84 loans must be borne by the industrial and commercial borrower. The conditions under which most of these loans have been negotiated clearly state that any tax, duty, or charge will be met by the borrower. The additional imposition will, therefore, add directly to industrial costs at a time when the competitiveness of Irish industry is being seriously eroded on international markets. The erosion has been intensified in recent weeks because of the strengthening of the Irish pound against sterling which has made the price of our exports to the UK far less competitive than heretofore.
With regard to the second point, capital allowances, it may seem on the face of it that to calculate capital allowances for taxation purposes in business and industry on a basis net of grants is just and equitable. The change does, however, add to industrial costs. What is far more serious is that the change increases significantly the cost of leasing. Many industrialists are forced to acquire plant and equipment through leasing because they do not have adequate capital to purchase the equipment. Financial institutions have been able to give competitive quotations for leased equipment because the institutions were able to obtain the benefit of full capital allowances. In extreme cases, the cost of leasing for industry will now increase by up to 54 per cent. This takes money directly out of industry which could otherwise be used to maintain or expand output and employment, and in other cases it will place the cost of leasing beyond the financial capacity of the enterprise and will thus mean that the project does not proceed.
The third element of disincentive against investment can be seen in the insurance levy. It is a direct attack on policy holders because the vast majority of life assurance companies operating in Ireland are mutualised. This means that the profit, or a substantial portion of it, goes to the with profits policy holders. From the point of view of business and industry, there is another serious detrimental effect. The life assurance companies are significant investors in productive enterprises and in property. Any attack on the funds of the life assurance companies will inevitably lead to a diminution in the funds available for investment. It must be emphasised once again that a diminution in the funds available for investment is a direct attack on jobs and living standards, which is the central theme to which I am addressing myself now — this is an attack on investment, jobs and living standards at a time when this is the fundamental national priority. A fourth element arises in relation to the advance corporation tax. The budget in this instance is silent and this means that unless there is an appropriate transitional provision in the Finance Bill, full advance corporation tax will now be payable. There are a number of serious points which I would like to illustrate in this regard.
First, there is no transitional arrangement for indigenous Irish companies which have invested heavily in the past and which now have a significant volume of unexpired capital allowances. This means that there is no net liability to corporation tax, and such a liability will not arise until all of the unexpired capital allowances have been used. Notwithstanding this, such a company which now pay a dividend will be required to make a payment under advance corporation tax which cannot be offset against a liability to corporation tax until such a liability actually arises. This eventuality could never have been foreseen when the original investment was made, so that the entire viability of the investment is now altered, and the cash flow situation is significantly damaged. Remember that I am talking about indigenous Irish companies which have invested heavily in the past. These are the companies which we are now penalising. The payment of advance corporation tax for a 50 per cent corporation tax company will be 54 per cent of the amount of the dividend, that is, 35-65 tax credit and it will be about 5.56 per cent, that is 1-18 tax credit for a 10 per cent corporation tax company.
There is also the serious anomaly that a company which sutters a current loss and which pays dividends out of accumulated reserves in order to maintain its position on the investment market will have to pay advance corporation tax although it has no profit, and the advance corporation tax cannot be recouped until there is a profit in a future year.
There is a serious anomaly in respect of companies entitled to export profits sales relief. A company in this category which earns a profit will have a zero tax credit, and no advance corporation tax will, therefore, be payable. A company in this category which does not have a profit will not be able to obtain export profits sales relief and will, therefore, become a 50 per cent corporation tax company. Such a company if it pays a dividend will be required to pay full advance corporation tax at 54 per cent. It is obviously the height of nonsense to penalise further a company which is already incurring a loss.