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Financial Transaction Tax Oral and Written Evidence EU ECONOMIC AND FINANCIAL AFFAIRS AND INTERNATIONAL TRADE SUB-COMMITTEE Financial Transaction Tax Oral and written evidence Contents The Alternate Investment Management Association Limited (AIMA) – Written evidence ....... 1 The Association of Private Client Investment Managers and Stockbrokers (APCIMS) – Written evidence ..................................................................................................................................... 13 Association for Financial Markets in Europe (AFME) – Written evidence ................................. 14 Association of British Insurers (ABI) – Written evidence .............................................................. 22 The Association of Corporate Treasurers (ACT) - Written evidence ....................................... 30 AVIVA PLC - Written evidence ............................................................................................................ 36 BlackRock - Written evidence .............................................................................................................. 43 British Bankers Association (BBA) - Written evidence ................................................................... 56 The British Land Company - Written evidence ................................................................................ 71 British Property Federation (BPF) - Written evidence ................................................................... 73 The Charity Tax Group - Written evidence ..................................................................................... 77 John Chapman- Written evidence ........................................................................................................ 79 Chown Dewhurst LLP - Written Evidence ........................................................................................ 87 City of London Corporation - Written evidence ............................................................................. 89 Confederation of British Industry (CBI) - Written evidence ......................................................... 91 Confederation of British Industry (CBI) – Supplementary evidence ............................................ 99 Confederation of British Industry (CBI) – Oral evidence (QQ 1 – 28) .................................... 103 Frank Cranmer - Written evidence ................................................................................................... 119 Arlene McCarthy MEP, Committee on Economic and Monetary Affairs - Written evidence .................................................................................................................................................................... 121 European Commission Directorate - General Taxation and Customs Union ........................ 127 Institute of Economic Affairs (IEA) – Written evidence ............................................................... 129 Sylvie Goulard MEP – European Parliament - Written evidence ................................................ 136 International Swaps and Derivatives Association (ISDA) - Written evidence ......................... 141 Investment Management Association (IMA) - Written evidence ................................................ 151 Lloyds - Written evidence.................................................................................................................... 168 Mayor of London - Written evidence ............................................................................................... 174 NAPF – Written Evidence ................................................................................................................... 176 New City Initiative - Written evidence............................................................................................. 177 Oxford University Centre for Business Taxation - Written evidence ...................................... 180 Peter Sinclair - Written evidence ....................................................................................................... 187 Stamp Out Poverty - Written evidence ............................................................................................ 194 Trades Union Congress (TUC) - Written evidence ...................................................................... 202 Trades Union Congress (TUC) – Oral Evidence ............................................................................ 206 Unite the Union - Written evidence ................................................................................................. 207 Dr. Bart Van Vooren - Written evidence......................................................................................... 209 Wellcome Trust - Written evidence ................................................................................................. 228 2 The Alternate Investment Management Association Limited (AIMA) – Written evidence The Alternate Investment Management Association Limited (AIMA) – Written evidence PART I General questions on financial sector taxation Q1 Is there a case for the introduction of a tax on financial transactions? Does the current exemption from VAT for most financial and insurance services lead to a tax advantage for the financial sector? 1.1. We see little merit in a FTT as proposed by the Commission and believe that as a method of achieving the Commission’s stated objectives, it is seriously flawed. Further, the FTT could have serious and damaging impacts for both the EU financial services sector and the EU economy as a whole, with a particularly disproportionate impact on the UK’s financial services sector and economy, given the manner in which the proposed FTT is framed. In particular, we do not consider that our hedge fund members should be so adversely impacted by the FTT when they were not responsible for the financial crisis, are not systemically important and have not received any direct form of taxpayer or government support. 1.2. The current VAT exemption for most financial and insurance services does not, in fact, lead to a tax advantage for the financial sector as VAT on costs and overheads incurred by finance and insurance businesses is currently not recoverable to the extent that it relates to their supply of exempt financial or insurance services and therefore represents a cost to the financial services sector. Accordingly, these sectors often bear a higher taxation burden in respect of VAT than other sectors. In addition, it is worth noting that the current exemptions for most financial and insurance services were driven by matters of political expediency and in particular a desire not to introduce a VAT under which end consumers would be required to pay VAT on their mortgage borrowings and insurance premia. Q2 What would be the most appropriate form for a taxation of the financial sector? Would a Financial Activities Tax (FAT) be a preferable means of taxing the financial sector? Would other variations (e.g. a currency transaction tax, a securities transaction tax or a financial tax on derivatives) be a more desirable form of taxation? 2.1 We would argue that no industry-specific taxation on the financial sector is appropriate as the industry already pays significant amounts of corporate tax and, ultimately, income and capital gains tax (on amounts representing profits and gains in the hands of the ultimate investors and other stakeholders such as employees). In addition, salaries paid to employees of financial sector businesses are subject to national insurance contributions (or equivalent social security contributions outside the UK). We also consider that a financial activities tax (FAT), like the proposed FTT, would be very difficult to implement in practice and might create competitive distortions between financial services imported to and exported from the EU. 2.2 It could also be argued that the FTT is not, in fact, a tax on the financial sector as the incidence of the tax is likely to fall on the ultimate pension holders and individual savers/investors. 1 The Alternate Investment Management Association Limited (AIMA) – Written evidence 3 Q3 What lessons can be learnt from the experience of other countries (such as the transaction levy introduced in Sweden in 1984 and abolished in 1991) in relation to a financial sector taxation scheme? 3.1 History suggests that FTTs (or similar securities transaction tax, or “STT”) have been less than successful, with many examples of the tax being abolished within a relatively short time of its introduction. In the last three or four decades, several countries have introduced FTTs similar to that proposed by the Commission and the impairment and loss caused by these taxes have often been permanent and broadly include: • Sharp drops in trading volumes; • Permanent trade migration; and • Hindrance to price discovery. 3.2 We set out below a summary of several examples from recent history. Sweden: 3.3 In 1984, the Swedish government introduced a tax on the purchase or sale of an equity security (1% total tax, i.e. ‘round trip’). This was doubled to 2% in 1986. As a result, 60% of the trading volume of the 11 most actively traded Swedish share classes moved to London and 30% of all Swedish equity trading moved offshore. By 1990, 50% of all Swedish equity trading had moved elsewhere.1 As trading volumes fell, so did revenues from capital gains taxes, to the extent that the lost revenue almost entirely offset the revenues from the transfer tax. A further example is that trading volumes dropped significantly in Sweden
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