Sunday, 1 January 2012

AQP v Comptroller of Income Tax [2011] SGHC 229

The following is a summary of the judgment by Tay Yong Kwang J. It deals with conflicting interpretations of Commonwealth cases as well as legal and policy arguments on the scope of deductibility.

The question before the court is whether losses caused to a company by a fraudulent director ("the Ex-MD") are deductible for income tax purposes under s14(1) of the Income Tax Act ("the Act"). The Ex-MD had misappropriated company funds causing the appellant to incur losses ("the Loss"). The appellant is seeking relief for the Loss under s93A of the Act, which concerns relief in respect of error or mistake.

Previously, the Income Tax Board of Review applied Curtis (HM Inspector of Taxes) v J & G Oldfield, Limited (1925) 9 TC 319 (“the Curtis test”) and concluded that the loss sustained by the appellant was not deductible under s14(1). It held that the Ex-MD was 'in the same position as the managing director in the Curtis case".

The Board also considered whether the appellant’s omission to set off the Loss in YA 2000 could qualify as an “error or mistake” under section 93A(1) of the Act, if the Loss were deductible. The Board held that the omission by the appellant was not “due to oversight” as “it was a decision made after due consideration that the Loss was not an allowable deduction under section 14 of the Act” but agreed with the appellant’s argument that “[i]f the decision was a mistake it was one of law and still a mistake falling within section 93A of the Act”.

Hence, two issues arose on appeal:

Issue A: Did the Board err in holding that the Loss incurred by the appellant was not wholly and exclusively incurred by the appellant in its production of income under s14(1)?

The appellant argued that in Curtis, the “real reason” why the loss was not deductible was because the defalcations took place outside the company’s trading or income-earning activities, since the money had already been earned and was simply passed through the company’s books into the pocket of the director. The respondent, however, understood the Curtis test as prohibiting the deduction of losses incurred by a director who was “in a position to do exactly what he likes”.

Tay J agreed with the respondent and held that the correct understanding of the Curtis test, is as follows: Did the defalcator possess an “overriding power or control” in the company (i.e. in a position to do exactly what he likes) and was the defalcation committed in the exercise of such “power or control”? If so, the losses which result from such defalcations are not deductible for income tax purposes. This reasoning was derived from a review of cases from different jurisdictions that considered the Curtis test, with Tay J eventually concluding that the Commonwealth cases are on the whole, in greater support of the "overriding power or control" test.

Tay J also rejected the appellant's argument that such an approach was undesirable both legally and on policy grounds. The Curtis test should be understood as a common law exception developed by the courts to render certain defalcation losses as having sufficient “nexus” with the production of income such that they could be deductible for income tax purposes. The Curtis test seeks to alleviate the hardship of the taxpayer by granting tax-deductibility to certain defalcation losses but it cannot and should not provide a warped incentive for firms to allow certain employees to do as they please and then claim that they had “expected” the losses which result from the employees’ defalcations to be tax deductible.

The distinction between losses resulting from the defalcations of lower echelon employees and those who possess an “overriding power or control” in the firm are justified on two policy grounds. First, the distinction drawn by the Curtis test as understood by the Board is as an extension of sympathy to large firms in view of their inability to keep all their employees, especially those of the lower echelon, in check. Second, and more importantly, it functions as a form of deterrence to firms that do not provide adequate checks on employees who possess such “overriding power or control” that they are able to incur great financial and social damage. As a deterrent tool, the Curtis test only makes sense if it is not only descriptive but also prescriptive of commercial practice.

In addition, it was considered that the appellant’s test may have undesirable consequences. The effect of such a test may be to encourage firms to turn a blind eye towards the power or control wielded by their employees. This is because so long as their employees, especially the high-level ones, “dress up” their defalcations as if they were part of the company’s activities, the losses which they incur would be tax-deductible.

Issue B: Did the Board err in holding that an erroneous opinion or a grossly negligent error, such as a mistake of law, can constitute an "error or mistake" under s93A of the Act?

The Board held that it did not find favour with the respondent’s argument that “error or mistake under section 93A of the Act does not include an erroneous opinion or grossly negligent error, but ‘must be genuinely due to ignorance or inadvertence”.

Tay J held that he agreed with the judge in the Hong Kong case of Extramoney Ltd v Commissioner of Inland Revenue [1997] 2 HKC 38 that errors with regards to the commercial advantage of attributing the said profits to itself are clearly outside the ambit of section 93A(1), which provides only for an “error or mistake in the return or statement made by [the taxpayer]”. It must follow then that genuine mistakes or errors made by the taxpayer in the filling up of the return or statement falls within section 93A(1) and this could have been caused by a genuine mistake of law instead of fact.

On this issue, Tay J agreed with the Board that a genuine mistake of law is still a mistake falling within section 93A of the Act.

Sunday, 18 December 2011

Singapore tops Asia-Pacific's 'Good Governance' Index?

According to this report it does. The emphasis under the taxation category appears to be about whether there is transparency and efficiency in tax collection, and whether tax rates encourage international businesses to invest. Given Singapore's reputation as an uber MNC friendly country, this is no surprise. We really do roll out the red carpet for businesses to invest in Singapore - I imagine this starts from EDB and IE's combined efforts in attracting investment, and then followed through by coupling that with various incentives especially those that are tax-related. Equally important is the enforcement of tax collection and how user-friendly the system is. On both counts it appears from the rankings that Singapore is doing a comparatively fantastic job.

However, Singapore's system has its detractors. According to this other blog post, we are a tax haven. Their issue is not that Singapore has low taxes, but that it does not cooperate in exchanging information with other countries and is thus a 'secrecy jurisdiction'. One view on this would be that we are merely modelling ourselves after Switzerland in terms of developing the private wealth industry, and our secrecy is a reflection of our understanding that people wish to keep the state of their finances private and confidential, and thus by allowing that to happen, we are able to attract more funds than other more transparent jurisdictions. On the other hand, there is the view that our status as a tax haven is damaging to our public image and international standing, and will deter investors in the long-term if countries start to turn away from us and implement measures to discourage their companies to invest in Singapore i.e. politically there might be a loss of goodwill.

This juxtaposition clearly serves as an interesting perspective on the many different directions that a country's tax policy can take, and how those policies are being compared against those of other countries. In the end, whether they work seems to me to always be a matter of whose point of view we want to take, and what criteria we want to base our judgment on.

Wednesday, 7 December 2011

New stamp duty taxes to cool Singapore's property market

Just read online that the government is imposing new stamp duty taxes. Check out the following articles:

http://www.businessweek.com/news/2011-12-07/singapore-imposes-new-stamp-duty-taxes-to-cool-property-market.html

http://www.channelnewsasia.com/stories/singaporebusinessnews/view/1170002/1/.html

In terms of the broader economic policy considerations, as always, there is a balancing approach that the government is trying to take here. If we free up the markets too much, we risk huge and sudden inflows and outflows of funds. This is destabilising because if all the investors of the world are trying to cash in on the booming property market in Singapore and invest all at once, property prices will sky-rocket i.e. inflation occurs. On the other hand, if we tax too heavily, businesses and individuals alike will be deterred from investing in Singapore property, which would lead to lower economic growth. Already I'm sure the various property investment companies aren't too pleased with this new tax.

Politically, I imagine that it would also not be popular for the government to allow a situation where foreigners own the vast majority of private residential property. That may well be the case in a totally free market especially with stories of the uber rich mainland Chinese buying up Sentosa Cove bungalows. This new tax is broadly in line with the efforts of the government to make housing affordable to Singaporeans, which was one of the main complaints made during the recent General Elections. However it is worth noting that this tax is only for private residential property and does not affect HDB flats which is the concern of Singaporean families with an average income. That said, the tax increase also affects PRs and Singaporeans, but to a lesser degree than foreigners. As an aside, I like that the government thought about what would happen if a citizen bought property with a foreigner and covered off that loophole.

In land-scarce Singapore, it seems that property prices have been on an upward trajectory and will as a general trend continue to just keep on rising unless the government takes increasingly drastic action such as higher taxes or massively increasing the supply of property. Singapore is becoming like Hong Kong in this regard. Whether the government introduces more or higher stamp duty taxes will depend on how successful these measures are at cooling the property market.

Monday, 5 December 2011

Hiya

So here we go. I'm hoping to use this blog as a process of discovery into the bewildering, complex but interesting world of tax. Tax may be one of the two certainties in life, but little else about tax seems certain. The laws change more frequently than most other laws (hello Budget Day), and they vary so much from country to country (HK versus Belgium for instance)! I like how tax is such a practical and important part of our lives - it affects just about every single thing you can think of and I also find it fascinating how it's actively being used by governments as a tool for social engineering. Our reactions to it also reveal plenty about who we are and what we stand for. Aside from policy issues, there are so many opportunities to be creative and imaginative with the practice of tax law itself. Law, being drafted by humans, is not infallible, and some digging around is likely to reveal unexpected inconsistencies and ambiguities - loopholes that easily get exploited, which then turns into an intellectual cat and mouse game with the authorities. In court, this manifests itself in all sorts of interesting situations e.g. whether Jaffa Cakes are cakes or biscuits, and whether Pringles are crisps or something else altogether! Tax seems connected to so many areas: economics, social policy, philosophy, accounting, politics...and so anyway hopefully I'll get to cover as many areas as I can in my quest to gain a deeper understanding of what this tax thingy is all about!