# Reform the tax code-actually do it!



## Orga (30 Dec 2013)

Does it rock the boat too much to move from discussing issues to taking action so that the situation improve? What would it take for a movement to begin to, say, reform the tax code so that an average citizen who had passed their leaving cert could complete their tax return, say a Form 11, in under 2 hours, and without recourse to a tax adviser. For the sake of the example, the average person could have a PAYE job and a small part-time self-employed job, with savings in a few institutions. The Minister for Justice is attempting to codify legislation so that all the historic stuff since and prior to the foundation of the State is current and aligned. Why then is the tax system not being examined? When I read today of 10,000+ cases examined (http://www.thejournal.ie/revenue-pension-tax-1242219-Dec2013/) I have to wonder if the windfall was due to 10,000+ people willfully avoiding tax, or it, in reality it was the labyrinthine nature of our personal tax system which gave rise to this work for Revenue, work which would not be there were the system made clear, simple, and understandable.

So, the question is, HOW should a movement begin to rock the boat...and, secondly, is this boat worth rocking?


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## Joe_90 (30 Dec 2013)

Orga said:


> When I read today of 10,000+ cases examined (http://www.thejournal.ie/revenue-pension-tax-1242219-Dec2013/) I have to wonder if the windfall was due to 10,000+ people willfully avoiding tax, or it, in reality it was the labyrinthine nature of our personal tax system which gave rise to this work for Revenue,



This whole story is bizarre, in principle the issue was that people with a private pension applied to the revenue to have their tax credits and standard rate cut off allocated to their private pension.

  The Revenue claimed that the pensioners did not tell the Revenue that they had a state pension and the pensioner said that the Revenue should have known that the pensioner had a state pension.  I think that it is fair to say that on the basis that pensioners applied to revenue for the tax credits it could hardly be considered to be the pensioners fault.  I don't think that it's due to the complicated nature of the system rather a poor system of integration between departments.


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## Setanta12 (30 Dec 2013)

Orga said:


> Does it rock the boat too much to move from discussing issues to taking action so that the situation improve? What would it take for a movement to begin to, say, reform the tax code so that an average citizen who had passed their leaving cert could complete their tax return, say a Form 11, in under 2 hours, and without recourse to a tax adviser. For the sake of the example, the average person could have a PAYE job and a small part-time self-employed job, with savings in a few institutions.  .......
> 
> So, the question is, HOW should a movement begin to rock the boat...and, secondly, is this boat worth rocking?



The Irish system isn't too labyrinthe and is manifestly fair/simple compared to some of our international counterparts.  You will have to cite examples and comparisons to make your point.

(At the end of the day, tax law is every Budget since the foundation of the State summarised in one place.  When people kick-up i.e. as a result of cuts to OAPs, then things change)


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## Brendan Burgess (30 Dec 2013)

It may well be simple compared to other regimes, but it could be a lot simpler.  But it could also be a lot more complex.   The tax credits system is much simpler than the old Tax Free Allowances. For most people, their taxes are deducted at source and they don't need to make any further return. 

ROS is particularly good. 

Here are some complexities which could be got rid of. 

Why have three taxes - PAYE, PRSI and USC, where one would suffice? 

There seems to be different rules for which types of income , USC and prsi apply to.

Do some people get an exemption from DIRT? 

The  rules applying to pensions are so complex, that I gave up trying to understand them many years ago. 

Investment income can be taxed at different rates - DIRT, income tax, exit tax. 

Why are state pensions paid gross? Why not subject them to PAYE in the same way as other income and thus avoid the problem referred to above. 

I am sure a trawl through the questions asked in the Tax Forum would highlight many other complexities which could be removed from the system.


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## Brendan Burgess (30 Dec 2013)

Orga said:


> So, the question is, HOW should a movement begin to rock the boat...and, secondly, is this boat worth rocking?



Hi Orga

I don't think it would be a movement as such. I can't imagine a mass meeting outside Leinster House
"What do we want?"
"Rationalisation of the income tax system!" 
"When do we want it?" 
"Now!"

Why not start by documenting the problem? 

Make a list of the complexities of the tax system.

Make a list of the Top 10 suggestions to simplify it. 

Try to estimate how much time and money would be saved by such simplifications. 

The Minister for Finance won't suddenly read it and implement it. It will take a fair amount of campaigning over a number of years but you could well be successful. 

Try to find a system in another country which would act as a model, although as Kildavin says, you will probably find ours is relatively simple. 

Make a pre-budget submission every year. 

Do we still have a Commission on Taxation? If so, apply to be appointed to it. 

Ask your local TD to raise the matter in the Dáil where you should get a lot more information on the topic. 

Find out the name of the Civil Servant in charge of the area and ask to meet them.

Tell a few jounalists what you are trying to do and they may well support it.


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## Jim2007 (30 Dec 2013)

Kildavin said:


> The Irish system isn't too labyrinthe and is manifestly fair/simple compared to some of our international counterparts.  You will have to cite examples and comparisons to make your point.
> 
> (At the end of the day, tax law is every Budget since the foundation of the State summarised in one place.  When people kick-up i.e. as a result of cuts to OAPs, then things change)



Well I can certainly confirm that!  On average it takes about a day and a half to complete a typical Swiss tax return!  The biggest part involves assembling and tabulating all the documents needed to actually complete the tax return!


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## Brendan Burgess (31 Dec 2013)

Hi Jim

Is that because Switzerland has low taxes? 

It probably takes a bit more time for an artist in Ireland to complete their return to justify the tax exemption than it does for an ordinary self-employed person.

Brendan


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## Orga (31 Dec 2013)

Some really good ideas already, thanks everyone!

When talking about the tax system, I'm not just referring to the way in which the tax is levied/calculated, though that is a large part of it. I'm also referring to the level of unnecessary duplication involved in filing. I'm also thinking about how information which is available (and shared) across the public service is so poorly connected and so little used. 

At its simplest, the question of taxes surely comes down to: this is what I earned/possess this year, and this is what I spent to be able to earn it, so tell me what to pay in taxes.

Brendan, my question about the how of achieving change was intended to get thinking going that might take a route different to the traditional models of change: revolution (no one pays taxes until things change-tried for the LPT and failed) and the model of influence and persuasion, working within the system that you propose. In any political system there's a balance, and a tension, between these two types of change processes. But, surely there's a better way for change to happen, one which isn't reliant on the ideological dogma of a group with sufficient mass and one which doesn't require the long-run approach of persuading and influencing within a system that is at once mired in lobbying and wary of lobbying. So, how can you rock the boat? Is there a better way, a more effective way? Just a question...


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## Jim2007 (31 Dec 2013)

Brendan Burgess said:


> Is that because Switzerland has low taxes?



Well first of all we pay taxes at three levels:
- Local Taxes (the main part)
- County (a small amount)
- Federal (a very small amount)

Next there are *no* allowances, everything must be supported by documentation:
- Travel to work
- Lunch costs at work
- Business expenses
- Insurances etc....

And of course since most Swiss are heavily invested in equities and bonds there is usually a lot of dividends and interest to be documented.

We also do not have any PAYE system, we are paid gross, so you pay one lump sum or per quarter, your choice.


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## Jim2007 (31 Dec 2013)

Orga said:


> At its simplest, the question of taxes surely comes down to: this is what I earned/possess this year, and this is what I spent to be able to earn it, so tell me what to pay in taxes.



Do you have any appreciation of how difficult it is to draft a tax code that is covers most of the basis, while remaining fair and reasonable to all...


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## Orga (31 Dec 2013)

Jim2007 said:


> Do you have any appreciation of how difficult it is to draft a tax code that is covers most of the basis, while remaining fair and reasonable to all...



Yes, I do!


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## Setanta12 (31 Dec 2013)

Orga said:


> Yes, I do!


 
Right so! Away you go!    Looking forward to your efforts.


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## RainyDay (31 Dec 2013)

Jim2007 said:


> Next there are *no* allowances, everything must be supported by documentation:
> - Travel to work
> - Lunch costs at work
> - Business expenses
> - Insurances etc....


Surely allowances are simpler, and should be part of the reform. If you have a sales rep on the road 5 days a week, surely it is easier to have a fixed lunch allowance of €10 per day, rather than to be collecting receipts and taking away the pint of beer that he bought with his own money but is on the same receipt etc.



Orga said:


> Does it rock the boat too much to move from discussing issues to taking action so that the situation improve? What would it take for a movement to begin to, say, reform the tax code so that an average citizen who had passed their leaving cert could complete their tax return, say a Form 11, in under 2 hours, and without recourse to a tax adviser. For the sake of the example, the average person could have a PAYE job and a small part-time self-employed job, with savings in a few institutions. The Minister for Justice is attempting to codify legislation so that all the historic stuff since and prior to the foundation of the State is current and aligned. Why then is the tax system not being examined? When I read today of 10,000+ cases examined (http://www.thejournal.ie/revenue-pension-tax-1242219-Dec2013/) I have to wonder if the windfall was due to 10,000+ people willfully avoiding tax, or it, in reality it was the labyrinthine nature of our personal tax system which gave rise to this work for Revenue, work which would not be there were the system made clear, simple, and understandable.
> 
> So, the question is, HOW should a movement begin to rock the boat...and, secondly, is this boat worth rocking?



This touches into a broader issue of simplification of public services, which goes way beyond the tax code. The new UK website https://www.gov.uk/ has done a great job of simplifying access to public services, using Plain English. They are doing a few transactions through that site also, taking a similar approach. I understand they are working on integration UK tax and social services in the same way.

If public bodies would just commit to using Plain English on all correspondence and websites, that would be a huge step in the right direction.


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## Setanta12 (31 Dec 2013)

RainyDay said:


> Surely allowances are simpler, and should be part of the reform. If you have a sales rep on the road 5 days a week, surely it is easier to have a fixed lunch allowance of €10 per day, rather than to be collecting receipts and taking away the pint of beer that he bought with his own money but is on the same receipt etc.


 
In fact we already have what you suggest in Ireland.  (In fact, we have two sytems to make it easier on such sales reps - one of an actual amount with a limit, and the other for actual costs incurred.)




RainyDay said:


> This touches into a broader issue of simplification of public services, which goes way beyond the tax code. The new UK website https://www.gov.uk/ has done a great job of simplifying access to public services, using Plain English. They are doing a few transactions through that site also, taking a similar approach. I understand they are working on integration UK tax and social services in the same way.
> 
> If public bodies would just commit to using Plain English on all correspondence and websites, that would be a huge step in the right direction.


 
Unfortunately the UK doesn't have a Consolidated Tax Act like we do for most of our main taxes.  Their HMRC website is good  - as an Irish reader of same - if you know what you're looking for, and have an idea re itsequivalent in Irish taxation. 

Domestically, there are plenty of plain Engish taxation resources.


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## RainyDay (31 Dec 2013)

Kildavin said:


> In fact we already have what you suggest in Ireland.  (In fact, we have two sytems to make it easier on such sales reps - one of an actual amount with a limit, and the other for actual costs incurred.)


Yes, I'm aware of that. Jim's suggestion seemed to be a retrograde step to me, which is why I queried it.



Kildavin said:


> Domestically, there are plenty of plain Engish taxation resources.


Any examples?


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## Orga (2 Jan 2014)

Summarising the discussion so far in a "scaled way" it would seem to me  that there's an 8 out of 10 happiness level with the tax system. The  main areas where improvement may be needed are around explanation and  information. 

I didn't want to "seed" the discussion too much at the  outset but it is striking that no one raised the issue of reforming the  fundamentals of the tax code i.e. the why, which and where of taxes that  are levied. Instead, and perhaps understandably, the discussion has  revolved around the how of paying taxes. But, surely, the purpose of  taxes is to raise revenue to enable the State provide the services  necessary for its citizens. If this is the case then where is the  visibility and transparency around the use of tax revenue? Granted the  recent changes to government accounting systems have given more  granularity around budgets, yet the distance to travel is still  considerable. But, even more basically, if you really want to rock the  boat you need to find a sufficient mass who believe in values which  resonate with the population to a degree which leads to action. 

Ask  yourself if you support the value and dignity of human life, of all  people as deserving of a basic standard of living. If you do, then do  you believe that a national responsibility is the elimination of  poverty? But, do you still believe it if you have to pay more taxes, if  you must pay fees for your kids to go to school, if you won't be able to  afford Sky TV any more, if your mother/father/siblings have to cut back  their private health insurance, if hospital waiting lists get longer?  So, who decides what matters, what values are important to us as a  nation-where is the conversation at a national level, because I know it  doesn't happen in Leinster House? If you can judge values by actions  then what values do you see when you look at the Celtic Tiger era? You  see, I believe that taxes, like so much of governing and government, are  not a financial exercise, they are a social function and I believe  that, for the most part, this most necessary of perspectives has been  lost in the busy-ness and business of government and politics.


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## RainyDay (2 Jan 2014)

Orga said:


> If this is the case then where is the  visibility and transparency around the use of tax revenue?


I'm not clear on what additional visibility or transparency is required, beyond the current reporting of expenditure by public bodies?


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## Orga (2 Jan 2014)

RainyDay said:


> I'm not clear on what additional visibility or transparency is required, beyond the current reporting of expenditure by public bodies?



Rainyday, there are two aspects to the visibility: first, the visibility around why the decisions are made in respect of tax policy and secondly, visibility around reporting outcomes, which relates to both administrative issues and the social good achieved through the use of the generated revenues. 

As a simple example (of where "good" is done IMO), basic foodstuffs are zero rated for VAT (in general) while cars carry a high rate of tax - the decision to zero rate foodstuffs while rating cars more highly stems from a view which aims to generate revenue from those who have the greatest means to pay while also ensuring that those who are of lesser means are not disadvantaged from attaining a satisfactory standard of living because of taxation. 

Unfortunately, policy decisions which arise in the course of budget discussions tend to focus more on the art of the possible, with phrases such as "low-hanging fruit", "easy/quick wins" being more prevalent than discussions about social balance. An example where there was little visibility of what informed the policy was the decision around the changes to jobseekers' allowances in the 2014 budget i.e. those aged 18-24 get €100/wk, if aged 25 you get €144, and aged 26 you get €188 and then this becomes more complex if you take part in a BTEA scheme. Compare this with the decision to facilitate NAMA to expend €2 billion in the period 2011-2015 and the transparency around this decision. For example, key policy decisions which have significant budgetary impacts and potentially wide-ranging social effects are not accompanied by dialogue/information/narrative. P8 of a joint IMF, OECD, World Bank and UN report for the G20 states:
Taxation is integral to strengthening the effective functioning of the state and to the social contract between governments and citizens. By encouraging dialogue between states and their citizens, the taxation process is central to more effective and accountable states. Reforms which begin in tax administration may spread to other parts of the public sector.

Link:http://www.imf.org/external/np/g20/pdf/110311.pdf

I know...I'm writing too much...


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## T McGibney (3 Jan 2014)

This discussion reminds me of a wise comment that Albert Reynolds made about the tax system during his time as Minister for Finance.

"Tax reform is a complex task requiring a balanced approach.  The  solutions are not always simple.  Very often simplicity is the enemy of  equity."
[broken link removed]

Reynolds also said once (I'm paraphrasing, and maybe not doing him full justice) "the only meaningful tax reform is tax reduction".  Again, wise in its own way.


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## T McGibney (3 Jan 2014)

ps Orga, this discussion is great but the lack of paragraphs in your two most recent posts makes them very difficult to read. Can you maybe please edit them? Thanks


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## RainyDay (3 Jan 2014)

OK, I see your point now Orga. Your concern is not so much around transparency of where public money is spent, but transparency of policy decisions about where public money is to be spent.

I suspect (though I have no direct knowledge) that in the example you give about cutting dole for younger people, there would be policy papers prepared and reviewed in Dept Social Protection around a policy change like this. It would be great if these papers were published by default. If not, you could probably get your hands on them via FOI if you were so minded.

On the other example of VAT on cars vs VAT on food, I suspect there would be no policy papers existing that compare these two options, because no Minister ever had to make a choice between these two options.


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## Nermal (4 Jan 2014)

T McGibney said:


> This discussion reminds me of a wise comment that Albert Reynolds made about the tax system during his time as Minister for Finance.
> 
> "Tax reform is a complex task requiring a balanced approach.  The  solutions are not always simple.  Very often simplicity is the enemy of  equity."
> [broken link removed]
> ...



Speaking as someone trying to get to grips with a tax qualification at the moment, I have to laugh. The current monstrous structure is plainly result of continual tinkering by sectional interest with almost no attempts at reform. 

Equity appear never to have been a consideration at all, or if so it was a long way behind getting nice things into the budget headlines and giving the government more levers to pull.


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## Jim2007 (4 Jan 2014)

RainyDay said:


> Surely allowances are simpler, and should be part of the reform. If you have a sales rep on the road 5 days a week, surely it is easier to have a fixed lunch allowance of €10 per day, rather than to be collecting receipts and taking away the pint of beer that he bought with his own money but is on the same receipt etc.



Well that is how it is here and in many of the other EU countries as well.


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## Jim2007 (4 Jan 2014)

RainyDay said:


> Yes, I'm aware of that. Jim's suggestion seemed to be a retrograde step to me, which is why I queried it.



That was not a suggestion!  I was responding to Breadan's question as to why it took so much effort to do a tax return over here.


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## Sophrosyne (4 Jan 2014)

Are you looking at reform of all taxes or just income tax?
Might it be better to focus on one or two key areas where you think change could be effected?


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## Orga (4 Jan 2014)

RainyDay said:


> I suspect (though I have no direct knowledge) that in the example you give about cutting dole for younger people, there would be policy papers prepared and reviewed in Dept Social Protection around a policy change like this. It would be great if these papers were published by default. If not, you could probably get your hands on them via FOI if you were so minded.




Rainyday, I understand where you're coming from - it makes perfect sense. Yes, I can access the policy papers under FOI, subject to the usual restrictions, and yes, it would be great if they were published by default. However, what would give us faith is that we know the decision has been well researched. While papers relating to deliberative process MAY be exempt from release under FOI, the practice is that they are not released because those involved do not want to see their thinking (or absence thereof) made public. But, the key issue is that the policy paper very often follows the political decision rather than engendering an open discussion which leads to policy formation. This is often the case because political parties form governments on the basis of a negotiated programme for government. In instances where there has been a change of government, the incoming government has no access to the ACTUAL figures other than rudimentary confirmation of figures by the Dept of Finance in advance of taking office. This, in addition to the negotiated nature of the policy programme means that policy decisions are not well-informed in very many cases.

In general, policy papers should set out the case for and against particular options. In practice policy papers only argue one option. See here for the policy paper on the changes to junior cycle education as one example: [broken link removed]

(I'm not engaging on whether the changes are a good idea or not - am just pointing out that policy tends to show just one option)

Where legislative changes are needed these are obliged to be accompanied by a document called a regulatory impact analysis. This analysis should set out the impacts of making the change, and of not making the change. In a significant number of instances the RIA is not done, and in almost all instances it contains a dreadfully poor level of analysis. This analysis is almost always centred on cost, as if no other principle matters, regardless of the actual nature of the legislation. 

When one examines RIAs in detail, you can see that they provide two options exclusively:
1. Do nothing
2. Implement the change which is proposed

My argument is that if you were to put your investment in the hands of a broker who gave you just two options i.e. do not invest, or put it in just one specific fund, then it wouldn't be long before you started to get worried about your investment. But, here, the issues are more nebulous, things like quality of life, access to services and so on. There are no robust systems in place nationally to report widely on such issues. So, unlike the investment adviser example where you can see your money dwindle away in a very clear way, can you see how well or badly the social structures funded by the taxes you pay are improving or disimproving? Unfortunately, I think not.

For anyone interested in what an RIA is like here is a link to an RIA on the Harbour Act (2008): 
[broken link removed]

In my view, this is a poor RIA and you will see that when you turn to the analysis of options on page 3 of 11. Most RIAs look like this. Note the wording that is used throughout: "view of" and terms which show that the opinion is already formed and set.

Lest I be accused of being overly negative, here is an RIA which is better. It's from the Department of the Environment and is about waste management:
http://www.environ.ie/en/Environment/RHLegislation/FileDownLoad,30784,en.pdf

When I say it is better, I mean that the quality of analysis is better than what you generally find. It doesn't mean that I believe the decisions reached are necessarily correct, wholly or in part. If I remember correctly this issue generated a lot of debate and the ESRI got involved as well (I may be "mis-membering")

Finally, here is a link to an EPA (US) RIA and you should notice that upfront it mentions social costs/effects as well as the economic costs. The issue the paper covers is that of reducing sulphur emissions. The quality of the analysis leaves our own analysis in the shade.
[broken link removed]


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## Purple (4 Jan 2014)

Superb post Orga.


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## Sophrosyne (5 Jan 2014)

Orga,

Your post is titled *“Reform the tax code – actually do it!”*

Therefore, you must think there is something wrong with the current tax code, regardless of how it was devised and of the transparency or otherwise of governmental analytics and decisions.

Can you set out, in points, what you think is wrong with the taxation system and specify which taxes you are looking to reform?


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## Orga (5 Jan 2014)

Sophrosyne said:


> Orga,
> 
> Your post is titled *“Reform the tax code – actually do it!”*
> 
> ...




You'll have read a number of such points already as part of this thread and I can provide a long list of points but this would defeat a lot of the purpose of reforming the tax system. That's because a piece-meal approach is not reform, a piece-meal approach is about refining, re-jigging, re-aligning. Changing individual points when the whole is sub-standard doesn't change the fundamental nature of the system. 

We pay taxes so the State can provide services and infrastructure. Let's start there and design from the point of view of current and future needs for services and infrastructure. You see, that way you start to look at taxation in a sustainable way with a long-term orientation. 

As a kid you may have had a piggy bank, though not many kids do these days. Yet, you often hear kids saying that they are saving for something by putting money away. The point is that by focusing on the purpose for the money there is a greater likelihood of its purpose being realised. 

This is not so much, at least initially, about changing the technical rules, instead it's about changing how we think, and that's a lot more challenging than changing rules. That's because how we think decides how we act, how we see the world and the values we hold underpin the decisions we make. See a piece by Stephen Kinsella who has an article in the Indo about the failure to reform: http://www.independent.ie/opinion/c...4-a-chance-to-stop-a-new-bubble-29876240.html

I understand that to not answer the question you asked Sophrosyne is going to be seen as dodging the issue and I don't want that. Equally, I don't want the larger issue to be overwhelmed by smaller details. So, as an attempt to answer your question, here are some specific issues which I've picked at random (which in a reform would need to be looked at in an integrated way):

1. Recalculate the value and purpose of the PAYE tax credit for workers - it was introduced to compensate for time value of money due to differences between how self-employed pay tax and PAYE pay tax
2. Explain the rationale for the miserly increase in the tax exemption limit for those aged 65+ where they still have a dependent child, such as a disabled adult child
3. Provide a rationale for why expenses which are allowable and are paid for from post-tax income are only allowable at the marginal rate regardless of whether the taxpayer pays at the higher rate
4. Simplify the calculation of PRSI and the range of classes - are there really different classes of citizen in the State?
5. USC, PRSI and various deductions...prize for anyone who can convincingly explain the real difference in purpose (not collection) of USC and PRSI


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## Sophrosyne (6 Jan 2014)

Don't forget interest payable on national debt. I read somewhere that this soaks up 20% (open to correction) of taxes raised.


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## RainyDay (6 Jan 2014)

Orga said:


> But, the key issue is that the policy paper very often follows the political decision rather than engendering an open discussion which leads to policy formation. This is often the case because political parties form governments on the basis of a negotiated programme for government. In instances where there has been a change of government, the incoming government has no access to the ACTUAL figures other than rudimentary confirmation of figures by the Dept of Finance in advance of taking office. This, in addition to the negotiated nature of the policy programme means that policy decisions are not well-informed in very many cases.


Yes, I can see the issue here, though I’m not sure about practical solutions. Political parties really don’t have access to the depth of resources needed to produce the depth of analysis you propose, unless or until they get into Government. Take Universal Health Insurance for example – both Labour and FG had UHI as their preferred health funding policy prior to getting into Govt. They have both had the policy for some time, in Labour’s case, back to before the 2007 general election or earlier. So it automatically came into the joint Programme for Government.
When the two parties came together in Government, they put together a dedicated unit in Dept Health to  progress it, and put together an implementation group of relevant experts; [broken link removed]. I understand that that group are working towards a ‘white paper’ to show how this policy could be implemented. I also understand that the emerging research from Netherlands and Germany suggests that the jury is very much still out on UHI. 
But there is just no realistic possibility that either individual party would have the resources to undertake this kind of detailed examination out of Government. And I don’t think it would be fair to lambaste either party for setting UHI as their target objective, based on the evidence that was available at that time.



Orga said:


> In general, policy papers should set out the case for and against particular options. In practice policy papers only argue one option. See here for the policy paper on the changes to junior cycle education as one example: [broken link removed]
> 
> (I'm not engaging on whether the changes are a good idea or not - am just pointing out that policy tends to show just one option)
> 
> ...


Yes, I can see the importance of taking a broader view, rather than just the two options. However, this is also not trivial to solve. In almost every policy scenario, there are an almost unlimited set of policy options available. And for each of those policy options, there are an almost unlimited set of policy options for inter-related policies, each of which will have impacts of the outcomes of this policy. So where does the analysis start and end?
And by the way, as soon as the Minister mentions that this analysis is taking place, you’ll have VinB or Hooky or Pat Kenny or Ivan Yates taking deep sighs and telling the Minister that the dogs on the streets (or on AAM) know what the solution is so why doesn’t he just rush ahead and do something?


Orga said:


> For anyone interested in what an RIA is like here is a link to an RIA on the Harbour Act (2008):
> [broken link removed]
> 
> In my view, this is a poor RIA and you will see that when you turn to the analysis of options on page 3 of 11. Most RIAs look like this. Note the wording that is used throughout: "view of" and terms which show that the opinion is already formed and set.
> ...


Interesting examples there, and it does seem like the Harbours one was particularly skimpy. There may be questions about what stage in policy development the RIA occurs. If it is done as a tick-boxing exercise before the final legislation is passed by Cabinet, it is probably not a valuable support to the policy development process. 
You might be a bit unfair to the Irish guys about the lack of social costs/effects, as I know some of this analysis is done outside of the RIA. This is definitely the case for papers going to Cabinet.


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## Purple (7 Jan 2014)

RainyDay said:


> You might be a bit unfair to the Irish guys about the lack of social costs/effects, as I know some of this analysis is done outside of the RIA. This is definitely the case for papers going to Cabinet.



Are these papers available on-line or without a FOI request?


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## Orga (9 Jan 2014)

You have a good point RainyDay about the capacity to undertake analysis. What your point shows, I believe, is two things:

1. the analysis existing in the system i.e. the civil service analysis needs to be made available
2.  the analysis which outside agents undertake needs to be leveraged, and  yes, many of them have a lobbying bias, but still this analysis has  utility

I wish that I could find the piece to link to it, but I  recall an interview with an economist who commented that when in  opposition, politicians were beating a path to his door for his views  and analysis. But, once they got into government they didn't want to  hear anything he had to say and they ignored him and others in the same  situation. That's not an unusual situation. There's a very small circle  and very strong sense of groupthink.

You're also right that I'm  hard on our own, as you call them, "Irish guys". Yes, things are better  than they were 10, 15 years ago - if you want to be appalled just look  for various papers that went to Cabinet in that period (or even worse,  things you would expect would have gone to Cabinet and didn't). You  might be interested to read the analysis which was undertaken for a  range of policies which were announced in those times - maybe you  already have an insight in this areas, your posts would suggest it. The  most interesting part would be the date on the advisory memo, which was,  in many instances after the policy announcement. It's probably the  lateness and the length of day which may be affecting my memory, but  didn't a (Labour?) minister make a policy announcement on radio/tv  (Morning Ireland?) I think earlier this year where he said that he was  announcing something that he didn't intend to announce....I'm just  confused by that...

Yes, Purple, the papers are available under  FOI. However, the issue is that they are usually not released because  the Departments consider them to be part of deliberative process, which  is, in my view, not in keeping with how the Acts should be interpreted,  and which constitutes grounds for refusal of access.


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## RainyDay (10 Jan 2014)

Orga said:


> You have a good point RainyDay about the capacity to undertake analysis. What your point shows, I believe, is two things:
> 
> 1. the analysis existing in the system i.e. the civil service analysis needs to be made available
> 2.  the analysis which outside agents undertake needs to be leveraged, and  yes, many of them have a lobbying bias, but still this analysis has  utility


Fully agree with this.


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