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Reforming Mobile Sector Taxation in Pakistan: Unlocking Economic and Social Benefits Through Tax Reform in the Mobile Sector

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Reforming Mobile Sector Taxation in Pakistan: Unlocking Economic and Social Benefits Through Tax Reform in the Mobile Sector Reforming mobile sector taxation in Pakistan: Unlocking economic and social benefits through tax reform in the mobile sector Copyright © 2019 GSM Association 1 About the GSMA EY | Assurance | Tax | Transactions | Advisory The GSMA represents the interests of mobile About EY operators worldwide, uniting more than 750 operators with over 350 companies in the broader EY is a global leader in assurance, tax, transaction mobile ecosystem, including handset and device and advisory services. The insights and quality makers, software companies, equipment providers services we deliver help build trust and confidence and internet companies, as well as organisations in in the capital markets and in economies the world adjacent industry sectors. The GSMA also produces over. We develop outstanding leaders who team to industry-leading events such as Mobile World deliver on our promises to all of our stakeholders. In Congress, Mobile World Congress Shanghai, Mobile so doing, we play a critical role in building a better World Congress Americas and the Mobile 360 Series working world for our people, for our clients and for of conferences. our communities. For more information, please visit the GSMA EY refers to the global organization, and may refer to corporate website at www.gsma.com one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Follow the GSMA on Twitter: @GSMA and Ernst & Young Global Limited, a UK company limited @GSMAPolicy by guarantee, does not provide services to clients. Report published March 2019 For more information about our organization, please visit ey.com. Disclaimer This report (Report) was prepared by Ernst & Young LLP for the GSM Association using information provided by the GSM Association and data from publicly available sources. Ernst & Young LLP does not accept or assume any responsibility in respect of the Report to any readers of the Report (Third Parties), other than GSM Association. To the fullest extent permitted by law, Ernst & Young LLP will accept no liability in respect of the Report to any Third Parties. Should any Third Parties choose to rely on the Report, then they do so at their own risk. Ernst & Young LLP has not been instructed by its client, GSM Association, to respond to queries or requests for information from any Third Party and Ernst & Young LLP shall not respond to such queries or requests for information. Further Ernst & Young LLP is not instructed by GSM Association to update the Report for subsequent events or additional work (if any) performed by Ernst & Young LLP. Accordingly, without prejudice to the generality of the foregoing, Ernst & Young LLP accepts no responsibility to any Third Party to update the Report for such matters. Ernst & Young LLP reserves all rights in the Report. REFORMING MOBILE SECTOR TAXATION IN PAKISTAN Contents Executive summary 5 1. The Pakistani economy, the role of the mobile sector and opportunities for growth 9 1.1 Country overview 9 1.2 Market overview 12 1.3 The socio-economic contribution of the mobile sector 20 2. Tax contribution of the mobile sector in Pakistan 25 2.1 Taxes on mobile consumers 25 2.2 Taxes and regulatory fees on mobile operators 26 2.3 Tax contribution of the mobile sector 29 3. Designing a more efficient tax policy framework for the mobile sector in Pakistan 34 3.1 Principles of taxation applying to the mobile sector 35 3.2 An assessment of the mobile sector taxation in Pakistan 36 3.3 Options for tax reform in the mobile sector to develop the digital economy in Pakistan 38 3.4 Digital opportunities in the field of taxation 40 4. Economic impacts of tax reform on the mobile sector in Pakistan 43 4.1 Options for further tax reform to increase digital inclusion 43 4.2 Approach to assessing the quantitative impacts of further tax reform on the mobile market and the wider economy 43 4.3 Harmonisation of sales tax on mobile services to 17% 45 4.4 Harmonisation and reduction in sales tax on mobile services to 16% 47 4.5 Elimination of the 8% minimum withholding tax on income from mobile services 49 5. Conclusion: Reforming mobile sector taxation in Pakistan 52 Appendix A Methodology 55 Appendix B Scenario estimations 65 REFORMING MOBILE SECTOR TAXATION IN PAKISTAN 4 REFORMING MOBILE SECTOR TAXATION IN PAKISTAN Executive summary Mobile telephone services are playing an increasingly 2008 and 2018.2 Mobile sector expansion in Pakistan important role in supporting economic growth and has been driven by significant capital expenditure by social inclusion across the world. Mobile penetration, mobile operators, who, on average, have made annual and specifically 3G and 4G penetration, enhances digital capital investments equivalent to around 25% of their connectivity by expanding internet and broadband revenue during the last decade.3 access, which in turn facilitates the reduction of barriers for trade, commerce, communication, service delivery, Total mobile sector revenues were $3.4 billion in 2017,4 and human development. Examples of these benefits are equivalent to 1.1% of Pakistani gross domestic product seen in the form of financial inclusion via mobile payment (GDP), while the sector contributed approximately platforms, digitally enabled local entrepreneurship, $1.8 billion of direct economic value to Pakistan in 2017 innovative health and education delivery systems, and (0.6% of GDP).5 This contribution to GDP is relatively growing numbers of e-government initiatives. low compared to international benchmarks, suggesting considerable scope for expansion. Conducive regulatory conditions offer the mobile industry the support it needs to thrive and maximise the The majority of the population (59.7% of the population, opportunities available to consumers, businesses and or 120 million people) is still unconnected to a mobile governments. Within this, taxation is an important factor, network. Unique subscriber mobile penetration in and there is a need to achieve the right balance between Pakistan stood at 40.3% in Q3 2018, which is the lowest tax revenue maximisation, and incentivising investment level in South Asia. and economic growth. Further significant investment is required to drive the In order to assess the potential benefits of a more expansion of the mobile market, and to improve the efficient tax structure in the mobile sector, one which affordability of services for consumers. In particular, a focuses on facilitating investment and unlocking digital focus on expanding network coverage, and investments inclusion, the GSMA1 has commissioned EY to undertake in the quality of data services, could accelerate the a study of the impacts of potential tax reforms on the growth of the sector in Pakistan. Pakistani mobile sector and the wider economy. Facilitating the growth of the mobile sector aligns with This report analyses recent developments and the tax the new Government’s economic objectives, which are structure in Pakistan’s mobile market, sets out potential set out in the PTI Manifesto and the PTI Digital Policy options for tax policy reform, and estimates the impacts 2018.8 These include achieving inclusive economic of these policy options on the mobile sector, the wider growth, creating new jobs, and transforming Pakistan economy and the Government’s fiscal position. into a knowledge economy. The mobile market in Pakistan has demonstrated In this context, incentivising further investment to significant growth over the past decade, however improve the availability and quality of mobile networks, a significant share of the population remains as well as improving the affordability of mobile services, unconnected to mobile services should become a policy priority for the Government, particularly given the low level of unique mobile The mobile market in Pakistan has expanded rapidly subscriber penetration, and a very low level of fixed over the past decade, with the number of unique broadband penetration in Pakistan (9 subscriptions per subscribers increasing by 37.4 million (85.1%) between 1,000 people in 2017).9 1. GSMA, https://www.gsma.com/asia-pacific/. 2. GSMA Intelligence database. 3. ibid. 4. ibid. 5. ibid. 6. There is an important difference between the number of mobile connections – the metric traditionally used by the industry to measure market size and penetration – and the term 'unique mobile subscribers'. The latter refers to a single individual that has subscribed to a mobile service and that person can hold multiple mobile connections (i.e. SIM cards). 7. Pakistan Tehreek-e-Inshaf (PTI), 2018, PTI Manifesto 2018, https://www.scribd.com/document/383487528/PTI-Manifesto-Final-2018#from_embed#. 8. PTI, 2018, PTI Digital Policy 2018, http://insaf.pk/public/insafpk/sites/default/files/PTI%20Digital%20Policy.pdf. 9. World Bank databank. 5 REFORMING MOBILE SECTOR TAXATION IN PAKISTAN Further improvements in affordability of mobile In a sample of South Asian countries, Pakistan (40%) services and devices would contribute to mobile has the second highest proportion of sales or value market expansion and development of the digital added taxes as a percentage of overall tax revenues economy in Pakistan (only below India at 47%). Pakistan has the highest proportion of corporate income tax (32%). In addition to For the bottom 20% and 40% income groups of the high tax burden, the large number of different taxes the Pakistani population, the total cost of mobile that apply to the mobile sector increases the complexity ownership (for both low and medium consumption and costs of tax administration and compliance. baskets) is above the “1 for 2” United Nations (UN) affordability target (1 GB of data costing less than Through policy reform, the Government of Pakistan 2% of monthly income). 10,11 Moreover, an upfront cost has the opportunity to simplify and rebalance the of a handset represents an affordability challenge for taxation of the mobile sector, supporting job creation those lower-income Pakistanis who do not have access and a better business climate to finance, which would enable them to pay the cost of a mobile phone in instalments.
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