The two articles listed below address one of the most controversial aspects of 
Budget,2005. The Fringe Benefit Tax has attracted widespread criticism from 
India Inc. Is this criticism justified? 

o o o o o o
 
 
Taxing FBT 
 
The Hindu Business Line
Editorial | Mar 30, 2005 
http://www.blonnet.com/2005/03/30/stories/2005033000300800.htm


THE FINANCE MINISTER, Mr P. Chidambaram, has promised a stable tax and policy 
environment through a new Income Tax Bill by the year-end or January 2006. He 
has also admitted to far too much clutter in the income-tax law, though this 
was obvious to every one. He has even promised a quick clean-up of a number of 
non-revenue provisions in the tax law through an amendment Bill. So far so 
good. But some of the direct tax provisions in Budget 2005-06, such as the 
Fringe Benefit Tax (FBT), seem to suggest an impuissant approach by the 
Government to directly confront the serious problem of a declining tax to GDP 
ratio. 
Successive committees set up to suggest tax reforms, headed variously by Messrs 
Raja Chellaiah, Vijay Kelkar or Parthasarathy Shome, have suggested 
unambiguously that exemptions should go and tax rates for both corporates and 
individuals should come down. But introduction of such items as the FBT in an 
already complicated Income-Tax Act indicates a clear deviation from the avowed 
policy of reducing the IT rates to East-Asian levels and de-mystifying the 
complex tax laws. While exemptions have not gone away (except the axe on the 
standard deduction for TDS returnees), the tax rates (in terms of what one has 
to bear) have actually become stiffer, making not only compliance cumbersome, 
but also costly, especially for business houses. Interestingly, none of the 
committees had suggested such a tax, for they all thought, rightly, that the 
immediate priority of all-round tax reform has to be tax administration and 
simplification of procedures. The FBT, incidentally, will call for separate 
assessment, returns, appeals, etc., all enough to give nightmares to the 
assessee. It would also in a sense amount to two kinds of tax payments from the 
same profit and loss account of Indian corporates. A new Section 271FB is 
proposed to be inserted in the I-T Act to provide for levy of penalty on the 
employer for failure to furnish a return of fringe benefits. The moot point 
here is that instead of moving to an assessee-friendly regime, are we not being 
pushed towards a more complicated one, which may also have the potential to 
emerge as a drain on our precious national resources. Where are the real steps 
to boost revenue? 

The FBT burden, if passed on to the hapless employee, it is uniformly felt, 
will surely lead to a shrinkage in spending by the average individual. Call it 
a cautious approach, or saving for a rainy day, but spending by most salaried 
people will reduce once the indirect impact of the FBT is felt across Corporate 
India. According to one school of thought, more spending of unaccounted money 
may happen, while the Government tries to plug other holes. And for the 
employer, the 30 per cent rate by way of FBT coupled with a 10 per cent 
surcharge and the 2 per cent education cess will mean a much higher tax burden. 
For the I-T Department, this will open up a whole new mechanism of parallel 
proceedings, including litigations, which may turn out to be a colossal 
national waste.


o o o o o

Fringe at the core 

The Hindu Business Line
Editorial | Mar 30, 2005 
http://www.blonnet.com/2005/03/05/stories/2005030500070800.htm


IN A SPEECH that ran to 184 paragraphs, the discussion of the Fringe Benefit 
Tax (FBT) lay at the fringes. But the issue of FBT has been at the centre of 
most analyses since, compelling Mr P. Chidambaram to the defensive stance of 
promising to correct unintended anomalies. It is true that there are employee 
benefits enjoyed collectively rather than individually. Also indisputable is 
the fact that many such benefits are deductible from the employer's income as 
legitimate business expenditure, even as these are not accounted for as the 
income of any employee for the purpose of taxability. The Minister's worry that 
employers disguise perquisites as fringe benefits and escape tax seems to have 
weighed in favour of introducing a whole new Chapter XII-H into the Income-Tax 
Act and making the employer liable for the tax at 30 per cent. 

Worse, the definition of fringe benefits in Section 115WB is open-ended. 
Barring canteen and transport, it covers any privilege, service, facility or 
amenity, reimbursement, contribution to superannuation fund and so on, and 
extends to a host of expense heads by slapping a `deeming' provision on them. 
Thus, any expense towards entertainment, festival celebrations, gifts, 
hospitality, use of club facilities, conference, sales promotion, use of 
telephone and so forth are all going to form the tax base for applying the 
percentages prescribed by the FBT regime. For instance, 50 per cent of expenses 
towards employee welfare, and 20 per cent of conveyance, tour and travel, will 
get taxed as fringe benefit. It is criticised that the FBT provisions 
constitute an Act within an Act because the Finance Bill proposes a whole set 
of provisions on FBT, governing the filing of a separate return, advance tax, 
notice, best judgment assessment, tax payment, interest for delay, refund and 
so on.

Employers cringe not only at the new fringe cost that has to be added to their 
employee expenditure, but also at the cost of compliance the Bill seeks to 
burden them with. To illustrate, an Assessing Officer will have the power to 
serve a notice on the employer to go over in person and produce evidence. 
Companies may have to think of adding `Fringe Sections' in their accounts 
departments, and also hiring legal officers to fight the fringe disputes to 
finish. And companies that were not liable to tax hitherto � such as foreign or 
loss-making corporates � will have to fork out FBT. 

Not all businesses are alike, and, therefore, expediencies governing 
expenditure differ from one employer to other. It is not unusual for a 
research-based firm to spend more on travel than a manufacturer using local 
inputs. Now, the FBT turns the focus of tax provisions to a micro level � that 
of the account heads � to engage in hair-splitting of outlays to determine the 
proportion liable for tax. Rubbing salt into the sore, the Bill hastens to deny 
any benefit of deduction for the FBT paid when computing the employer's income. 
Protests shout that the tax is not on income but on expenditure, thus violating 
the basic tenet of income taxation. If the FBT were to stay, a simple way out 
for employers will be to increase the pay and cut on facilities. An alternative 
for the employer will be to make the perquisites identifiable with the 
employees so that they would pay tax on the same. 




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