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	Murdoch University Electronic Journal of Law

E LAW - MURDOCH UNIVERSITY ELECTRONIC JOURNAL OF LAW
VOLUME 1 NUMBER 4 (DECEMBER 1994)
Copyright E Law and/or authors

Review of Western Australian State Taxes 1994
Chapter 6 A BROAD-BASED STATE SERVICES TAX

Part 1 Introduction
Why Not A Goods and Services Tax?

Part 2 Equity
Equity - The Existing Taxes
Vertical Equity
Horizontal Equity
Tobacco
Alcohol
Petrol
Services Tax
Summary

Part 3 Efficiency
The economic rationale behind a services tax
The efficiency criterion
The effect on service providers
The effect on service recipients
Summary

Part 4 Simplicity
The Structure Of The Tax
Multiple Rates or a Single Rate?
Exemptions and Zero-Ratings
Methods Of Enforcement
Tax Evasion and Non-Registration
General Problem of Tax Evasion in Underreported Sales
Summary

Part 5 Conclusion

Bibliography

PART 1 INTRODUCTION

This chapter discusses the possibility of introducing a broad-based
services tax in Western Australia. The State may choose to introduce such a
tax for a number of reasons, such as, so that it can replace an existing
tax or decrease its reliance on Commonwealth grants. The latter course of
action would be fraught with political and economic difficulties and is
beyond the scope of this chapter.

There are already a number of collections by the State which are or
resemble services taxes. They are: (i) Financial Institutions Duty
(F.I.D.); (ii) Debits Tax; (iii) Tobacco Franchise Fees; (iv) Alcohol
Franchise Fees; (v) Petrol Franchise Fees; and (vi) Fees for Public
Utilities and Services.

The Franchise Fees rest precariously in this group in that their existence
is largely due to the High Court s reluctance to overrule past decisions
relating to section 90 of the Commonwealth Constitution.[1] However, it is
possible to construe them as services taxes if they are seen as applying to
the service of providing tobacco, alcohol and petrol products.

The 1993 Review of Western Australian State Taxes[2] discussed the first five
of these service taxes in terms of the criteria for optimal taxes and found
them to be relatively simple taxes, with equity problems. While attempts to
make F.I.D. and Debits Tax more equitable have not severely damaged the
simplicity of those taxes, they have failed to adequately address their
inherent equity problems.[3] The Franchise taxes are good revenue raisers
because the subjects of the tax exhibit a low price elasticity[4] but they
also have equity problems resulting from this same feature.[5] Franchise fees
are also quite simple to collect and the inelasticity of their subject
matter tends to prevent any adverse reaction in terms of the efficiency of
resource allocation in the market.The last category of existing services
taxes, fees for Public Utilities including water and electricity, was not
examined last year and the discussion below will focus only on equity.

Why Not A Goods and Services Tax?

The majority of critics advocating change recognise that a services tax is
best complemented by a goods tax but they also recognise the problems this
entails in the Australian federal system. Section 90 of the Commonwealth
Constitution prevents the States levying duties of excise .[6] This section
has been held to prevent the States from levying taxes on the manufacture
or distribution of goods.The definition of excise presently favoured by the
High Court is very broad with the courts looking beyond the form of the
legislation to its substance.[7] Tobacco, alcohol and petrol taxes have been
spared because of political and economic factors, in particular the fact
that the States have organised their affairs in reliance on the validity of
earlier decisions.[8] However, the High Court has been reticent to allow the
States to levy taxes on goods beyond this limited group of
products.[9]Therefore, the first hurdle for any tax on services is its
constitutional boundary. There are substantial difficulties in
distinguishing services from goods . For example, a lawyer clearly provides
a service, a mechanic will provide both parts and services which can be
easily distinguished, but does a coffee shop provide a service or does it
manufacture a finished product? It is arguable that the finished product is
the roast coffee bean and the making of the cappuccino from it is a
service. However, the argument that the finished product is the cappuccino
appears equally valid and, if so, a tax on the coffee shop providing the
coffee to the customer contravenes section 90. Any attempt to formally
distinguish the manufacture of the finished product from the services
provided by the coffee shop would entail difficulties which would severely
compromise the simplicity of the tax.

Other problems exist beyond the constitutional minefield. The following
sections of this chapter will examine these in the light of overseas
experience. The discussion will take place under the umbrella of equity,
efficiency and simplicity.

PART 2 EQUITY

Overseas services taxes have experienced problems with equity and this is
reflected in the complex nature of those taxes.[10] This section of the
chapter will examine current services taxes with regard to equity and
consider the implications for a broad-based services tax.

Equity - The Existing Taxes

Financial institutions duty and debits tax have received analysis elsewhere
in this publication[11] and the issues will not be re-canvassed here. It will
be sufficient to endorse the proposal of substituting a composite Financial
Transactions Tax with its concomitant improvement in equity.

Vertical Equity

The general theory is that taxes which are not proportionally linked to the
ability of the payer to pay are vertically inequitable.[12] Therefore, a
broad-based services tax will only achieve vertical equity where, assuming
the tax is passed on to the consumer, the consumption of a service is
proportional to the economic capacity of the individual. Although this will
vary depending on the service, the likelihood of the tax being vertically
inequitable is high. The fact that Business Franchise Fees are
fundamentally excises masquerading as service taxes does not alter this
conclusion: the amount of tax paid is proportional to consumption.[13]
Service taxes are the functional economic equivalent of excises and
vertical inequity cannot be addressed by altering the tax rate according to
consumption in the same way that income tax rates are increased.

Horizontal Equity

The high rates of tax imposed on tobacco, alcohol and petrol necessitate a
consideration of the incidence of the tax in more detail. Given that
tobacco and alcohol are both inelastic consumer goods, the incidence of the
tax falls primarily upon the purchaser. Petrol, on the other hand, is
commonly consumed in the course of commerce with the result that the
incidence of the tax is far broader. A tax on fuel sold for non-productive
consumer use is borne by the consumer and is widely spread throughout the
community. This wide incidence of the petrol tax makes it horizontally
equitable. Tobacco and alcohol taxes, in contrast, are only horizontally
equitable within the particular consumption sector.[14]

Tobacco

High taxation rates on tobacco are often supported by the claim that
tobacco consumption imposes economic costs for health care which the
general community should not bear. This argument has force because the
consumption of tobacco is statistically related to resultant health costs.
A group of smokers will incur health costs proportional to consumption.[15] A
tax rate which produces aggregate revenue below that total cost results in
horizontal inequity in favour of the smokers. Similarly, a tax rate which
produces aggregate revenue that is higher than the predicted health costs
results in a similar inequity in favour of non-smokers.

Alcohol

These arguments do not apply to alcohol. The community costs of alcohol
consumption result from the behavioural decisions of those who consume it.
It is not equitable to impose costs on consumers who do not drive after
drinking, or those who beat their spouses, merely because there are other
individuals who do. The salient difference between tobacco and alcohol is
that community costs associated with tobacco consumption by any individual
are statistically predictable, whereas this cannot be said in relation to
alcohol.[16]

Petrol

The arguments relating to the equity of fuel tax are different again. Tax
paid on fuel in the course of commerce is likely to be diffused throughout
the community by increased costs of goods and services. While transport
costs affect the price of some goods and services more than others, the
disparity will be minimal and a reasonable degree of horizontal equity
exists.

Services Tax

It is difficult to assess the equity of a broad-based services tax without
a working model. Due to constitutional and equitable problems,[17] it is
suggested that a practical way to impose a broad-based services tax would
be to list the services to be taxed. Law, architecture, medicine and
accountancy would be good candidates, as machinery currently exists to
regulate these professions. The existence of practicing certificates or
licences provides easy identification of potential taxation points and it
would simply be a matter of establishing the value of the services
provided.

Political opposition to a services tax with respect to medicine would
probably be insurmountable because it would be seen as a tax on the sick.
Similarly, a tax on legal services could further reduce their already
limited availability to middle and lower- income Australians when the
services are not covered by Legal Aid. This might be averted by applying a
sufficient tax threshold, subject to concerns in relation to simplicity.

This is not to say that a broad-based services tax has no future, but a
limited list of services to be taxed may be the best option. Those services
which can be identified as substantially supplied for commercial purposes
would be able to bear a higher rate consistent with considerations of
equity. However, the tax rate which could be set would be limited by the
possibility of services being provided interstate.[18]There is also the issue
of whether or not a distinction should be made between public and private
institutions in the application of a services tax. If public services are
excluded, private services could legitimately claim inter-sector inequity.
On the other hand, inclusion of government services may be inappropriate
since government services are often provided for welfare purposes or
because of their beneficial externalities.

Summary

While it is true that a services tax lends itself to the liberal equitable
footprint ,[19] it does not necessarily meet the standard model of equity.
The discussion on franchise fees concluded that the broadest tax, the tax
on petrol, was more equitable than the narrower tobacco tax. It may be
anticipated, therefore, that a sufficiently broad services tax might be
better than a tax with a narrow base.

PART 3 EFFICIENCY

The economic rationale behind a services tax

The tax system is an instrument of social reform and economic
intervention.[20] As an instrument of economic intervention, it can be used
to discriminate arbitrarily in favour of certain economic activities and
organisations perceived to be desirable by legislators to the detriment of
others perceived as undesirable.[21] Thus, a tax may operate to discourage
the activity on which it has been imposed. This consequence, however, may
not always be the intention of the legislators. Taxes which are intended to
generate revenue, as opposed to ones designed to regulate certain
activities, may have unforseen or unintended effects on the marketplace.
Taxes which typically fall into this category are those with narrow revenue
bases and high rates.[22] Inequitable and inefficient taxes such as stamp
duties,[23] with their multiple rates and large number of exemptions, become
arbitrary in their impact and complex to administer.[24] In addition, the
narrowness of their revenue base and wide range of tax rates affect
relative prices, thereby distorting consumption decisions.[25] Therefore, it
follows that broad-based taxes with flat rates and few exemptions have less
distortional effects on the marketplace. With this idea in mind, a services
tax with a flat rate and few exemptions could be considered as a substitute
for stamp duties.

The efficiency criterion

Efficiency analysis, from a taxation policy perspective, is based on the
economic assumption that the interaction of unrestricted market forces
always results in the optimal allocation of resources.[26] Flowing from this
assumption, an ideal tax should be neutral with respect to the economic
behaviour of producers and consumers. Taxes should not unintentionally
distort the behaviour of these parties. In relation to a services tax, the
relevant parties are the service provider (producer) and the service
recipient (consumer).An efficient tax is one that does not induce service
providers to change the forms and methods by which they provide the
service, nor does it induce the service recipients to change the services
they use.

The effect on service providers

The service provider is likely to be the person who would be liable to
collect and pay the tax to the State Taxation Office. However, the ultimate
incidence of the tax is unlikely to be borne by the service provider due to
the reason that a tax which increases the cost of supplying a service is
likely to be passed on to the service recipient. This one-off price
increase in the cost of services to accommodate the tax is unlikely to have
a continual effect on inflation.

For political, economic, moral or equity reasons, the tax is likely to be
implemented with exemptions. Essential services associated with education,
health and social welfare will undoubtedly fall within this category.
Financial services are also likely to be exempt[27] (a tax levied at a rate
of 15% on financial services will very quickly terminate the State s
economy). Although justifiable, exemptions may create problems associated
with the categorisation of services. This type of problem has been a
feature of many stamp duty disputes where liability is dependent on the way
in which the transaction is categorised.[28] The existence of exempt
categories may encourage service providers to characterise their services,
where possible, as one that falls within those categories.

The effect on service recipients

An obvious method to avoid a services tax is to minimise the use of taxable
services. A more serious problem arises when service consumers seek to
avoid the tax by using equivalent services offered interstate or overseas
where it is possible and practical to do so. However, this problem is
addressed in jurisdictions where a services tax is in operation[29] by
provisions which typically read as follows:If the supplier is not resident
in the State, the service is deemed to be supplied in the State if
either:(i) the service is received in the State; or(ii) the service is
performed in the State.However, such provisions may in practice prove
difficult to enforce as the flow of interstate services needs to be
continuously monitored.[30] Tax liability also depends on the circumstances
under which services are rendered. For example, health services rendered by
a public medical facility may be zero-rated (hence escaping the tax) while
the same service rendered by a private medical facility may be liable.
Under these circumstances, the differential treatment of health services
may result in an undesirable distortion of the health care market. Service
consumers with private health insurance may place excessive demands on the
public health care system. Although differential treatment of services may
be desirable for equity reasons, its potential distortional effects need to
be anticipated and taken into account.

Summary

A broad-based services tax will not necessarily be efficient unless it is
complemented by a strictly flat rate and minimal exemptions. Differential
rates and exemptions are major causes of efficiency problems. The
introduction of the tax by a single State can also lead to distortions due
to service shopping which is difficult to police. However, if introduced in
the manner described, it is likely to be easy to administer and provide a
broad platform for raising State revenue.

PART 4 SIMPLICITY

In terms of simplicity, a services tax appears undesirable. Several
overseas jurisdictions have introduced a services tax as part of their
Value Added Tax (aka Goods and Services Tax) regime but have experienced
substantial difficulties in this area, especially in relation to
administration and collection.

The simplicity of a tax is largely dependent upon costs of administration.
The simpler a tax is, the lower this will be. However, there are several
factors which work to increase costs and, therefore, erode the simplicity
of the tax. These factors are grouped into two broad areas;

i) the structure of the tax, and

ii) methods of control and enforcement.

The Structure Of The Tax

The most important factors are the number of rates to be imposed and the
question of exemptions.

Multiple Rates or a Single Rate?

Multiple rates are one method of addressing equity problems but this will
affect the simplicity of the tax. Tax administrators prefer a single rate,
whereas politicians perceive electoral advantage in imposing lower rates of
tax on services which are considered to be used most frequently by lower
income earners.[31] However, although such intentions may arise from a
genuine concern for people s welfare, as well as being politically
advantageous, they inevitably increase the complexity of the tax, while not
necessarily achieving the purposes for which they were intended.

Multiple tax rates will result in tax forms becoming more complex.[32]
Therefore, there will be a corresponding increase in the possibility of
error (both by taxpayers and administrators), as well as tax evasion. Even
if there are lower rates for those services which are considered to be the
province of lower income earners, these individuals will not necessarily
receive the benefit intended by the lower rate: the wealthy often use
services generally associated with lower income earners. Conversely,
services normally associated with wealth, such as electricity and
telecommunications, are not used exclusively by the wealthy.

Thus, a single rate is preferable in terms of simplicity.

Exemptions and Zero-Ratings

These raise further complications. Ideally, for a tax to be simple, there
would be no exemptions at all, however, there are many practical
difficulties with this.

There are three main reasons for exemptions and zero-rating. The first is
identical to the policy behind multiple tax rates, and is fraught with the
same problems.

The second relates to merit services such as health care and education
which many consider should not be taxed.[33] This is particularly so on the
grounds of equity, especially if one believes that everyone has a right to
these services so that they should be subsidised if not free.[34]The final
reason for creating exemptions is that some services, such as financial
services, are simply too difficult to tax.[35] Taxation of these services
would be impracticable as the taxes would cost more to collect than they
would to impose.The situations highlighted above demonstrate the need for
exemptions despite the effect they have simplicity.The New Zealand Goods
and Services Tax introduced in 1986 demonstrates many of the problems of
this tax.[36] Initially it was introduced as a single rate of tax, the only
exemption being in relation to exports. However, the Government was forced
to grant exemptions in areas where tax collection was becoming too
difficult, including financial services, life insurance, some residential
accommodation payments and central and local government services. Although
a no-exemption tax model is ideal, obtaining the broadest base possible and
maintaining simplicity requires accommodation in certain areas.

Methods Of Enforcement

In Canada all businesses must register unless they are earning below a
specified amount.[37] Those not required to register pay no tax under the
exemption for small traders.[38] This can have two possible effects: the tax
may become easier to collect, or it may become more difficult to collect.
Granting exemptions to small businesses with a low turnover may keep the
tax simple[39] because there will be fewer collection points. However, this
may make only a marginal difference, depending on the level of commercial
development in the jurisdiction in which the tax is introduced. It may have
a smaller impact on developing countries, in which fewer people use
services such as hairdressers and restaurants, than in developed countries
such as the United States or Britain.

Imposing a threshold is more likely to increase the complexity of the tax.

Tax Evasion and Non-Registration

The registration threshold may encourage tax evasion. For example, a large
business may be divided into two or more smaller businesses, each with a
turnover below the threshold, in an attempt to avoid tax.[40] This would
necessitate more money for monitoring and safeguards. However, this may be
easily avoided by providing that the liability for tax will be measured on
the aggregate sales of all the separate branches.

Non-registration is a definite concern, and should be viewed as a serious
offence, attracting a suitably heavy penalty. However, this again results
in increased administrative costs.

General problem of tax evasion in underreported sales

The underreporting of sales is the major problem which has arisen in
jurisdictions which already have a services tax and is the most usual way
to evade the tax. In Europe tax administrators have discovered that it is
especially common in small trades such as carpentry and plumbing.[41]
Constant checks can be run, but this may involve substantial administrative
costs, and it may be more expensive to collect the tax than to impose it.
Other jurisdictions have attempted to surmount this difficulty by requiring
traders to use numbered receipts stating their name, address and
registration number.[42] However, this practice has not been successful.
Traders can fill out reduced amounts on their receipts (although customers
may still be required to pay the full price) or else receipts may not be
filled out at all.[43] Monitoring this kind of activity again necessitates
considerable financial outlay, which diminishes the simplicity of the tax.

Summary

If a government had sufficient political will it could implement a services
tax which, in terms of simplicity, would outperform taxes such as stamp
duty. The fact that stamp duty consists of so many taxes, is perforated by
so many exemptions and is punctured by variance in rates, creates a very
complicated structure for the tax. The rationale behind the varying rates
is confusing and could be causing distortion in the market and complicating
otherwise routine transactions.[44]A broad-based services tax could also make
inroads into areas which are generally cash areas such as hair dressers,
prostitution and other personal services and thus avoid close scrutiny.
This is a common argument in favour of services taxes but it is still
possible and perhaps likely, that the provider of the service may be able
to avoid the tax by falsifying returns. However, this is a problem faced by
any tax.

PART 5 CONCLUSION

Current State services taxes have problems with equity but are not alone in
this failing.[45] However, in terms of simplicity and efficiency they are on
equal footing if not higher ground. However, overseas experience has
displayed problems with broadly based services taxes as they rapidly become
complex and often lead to inefficiency. This is particularly so where the
tax is modified to rectify problems of equity.

The lack of certainty surrounding efficiency and constitutional problems
brings an element of risk into any proposal to introduce a services tax,
despite some possible advantages in terms of simplicity. To avoid the
constitutional problems, it has been suggested that section 90 of the
constitution be amended to allow States to charge excises and hence
legitimise a State goods and services tax.[46] However, referenda have a poor
success rate in Australia.Despite problems with existing taxes, the
uncertainty involved in the introduction of a State tax that is
substantially different from its neighbours presents a real and difficult
obstacle to the imposition of a broad-based services tax. However, its
advantages may provide impetus for the States to promote collective reform.

BIBLIOGRAPHY

Cases

Bambro (No. 2) [1964] NSWLR 183

Capital Duplicators (No. 1) (1992) 177 CLR 248

Capital Duplicators (No. 2) (1993) 118 ALR 1

Dennis Hotels Pty Ltd v Victoria (1960) 104 CLR 529

Gosford Meats Pty Ltd v New South Wales (1985) 155 CLR 368

Kenworthy Homes v Commissioner of Stamp Duties [1975] ATR 311

Philip Morris v Commissioner of Business Franchises (1989) 167 CLR 399

Western Australia v Chamberlain Industries Pty Ltd (1970) 121 CLR 1.

Statutes

Commonwealth of Australia Constitution Act 1900 (Imp), 63 & 64 Vict.

Stamp Act 1921 (WA).

Texts and Monographs

AUSTRALIAN RESEARCH FOUNDATION, Consumption Tax: Everyone s Guide to the
Pros and Cons (Sydney: Australian Tax Research Foundation, 1989).

BOLLARD, A. "New Zealand s Experience With Consumption Tax" 9(3) Australian
Tax Reform (1992) 473.

COMMITTEE OF INQUIRY INTO THE AUSTRALIAN FINANCIAL SYSTEM, Australian
Financial System Final Report (Canberra: Australian Government Printing
Service, 1981).

COMMONWEALTH TREASURY, Taxation and the Fiscal Imbalance Between Levels of
Australian Government: Responsibility, Accountability and Efficiency
(Report of the Working Party on Tax Powers, 4 October 1991).

CROSSEN, S., "The Technical Superiority of VAT over RST", 4 Australian Tax
Forum (1987) 419.

GREENBAUM, ABE, "The Canadian Goods and Services Tax: A Sign of Things to
come for Australia?" 20(2) Australian Business Law Review (1992) 186.

HOCKLEY, J, "An Australian Goods and Services Tax" 1991 Australian Tax
Review 217.

LANE, P.H., A Manual of Australian Constitutional Law (Sydney: Law Book
Company, 1991).

McGIFFIN, B., "The Canadian Goods and Services Tax" (GST) CCH Journal of
Australian Taxation (December 1991/January 1992) 53.

McKENZIE, A., "Introduction to GST: A Practical Guide" (New Zealand: CCH,
1988).

McLEOD, N. (ed.), 1993 Review of Western Australian State Taxes (Perth:
Murdoch University School of Law, 1993).

MATTHEWS, R., Distributional Equity, Tax Neutrality and Tax Effectiveness:
Issues in Tax Reform (ACT: The Australian National University, 1985).

TAIT, A.A., Value Added Tax: International Practice and Problems
(Washington DC: International Monetary Fund, 1988.

Notes:

[1] Philip Morris v. Commissioner of Business Franchises (1989) 167 C.L.R.
399 at 427.

[2] N. McLeod, ed., (Perth: Murdoch University School of Law, 1993).

[3] 1993 Review of Western Australian State Taxes, N. McLeod, ed., (Perth:
Murdoch University School of Law, 1993), 60 and 65.

[4] Commonwealth Treasury, Taxation and the Fiscal Imbalance Between Levels
of Australian Government: Responsibility, Accountability and Efficiency,
Report of the Working Party on Tax Powers, 4 October 1991.

[5] 1993 Review of Western Australian State Taxes, N. McLeod, ed., (Perth:
Murdoch University School of Law, 1993), 95.

[6] P.H. Lane, A Manual of Australian Constitutional Law (1991) (Sydney: Law
Book Company, Sydney, 1991), pp. 352 - 353.

[7] Capital Duplicators (No 2) (1993) 118 ALR 1 per Mason CJ, Brennan, Deane
and McHugh JJ at 9.

[8] Ibid, 14-15.

[9] Capital Duplicators (No 2), Gosford Meat Pty Ltd v. New South Wales
(1985) 155 CLR 368, Western Australian v. Chamberlain Industries Pty Ltd
(1970) 121 CLR 1.

[10] See Part 4: Simplicity.

[11] See Chapter 10.

[12] See Chapter 10.

[13] A Liberal Theory footprint - see Chapter 10.

[14] See Chapter 10, Liberal Theory.

[15] Statistically.

[16] See the discussion above.

[17] See Part 1.

[18] See Part 3.

[19] Chapter 10.

[20] As argued in: R. Mathews, Distributional Equity, Tax Neutrality and Tax
Effectiveness: Issues in Tax Reform (ACT: The Australian National
University, 1985).

[21] Ibid.

[22] Ibid.

[23] 1993 Review of Western Australian State Taxes, N. McLeod, ed., (Perth:
Murdoch University School of Law, 1993), 95.

[24] R. Mathews, Some Reflections on the 1985 Tax Reforms (ACT: The
Australian National University, 1985).

[25] Commonwealth of Australia, Reform of the Australian Tax System: Draft
White Paper (Canberra: Australian Government Printing Service, 1985).

[26] S. Cnossen, The Technical Superiority of VAT over RST (1987), 4
Australian Tax Forum 419.

[27] J. Hockley, An Australian Goods and Services Tax (1991), Australian Tax
Review 217.

[28] Bambro (No 2) v Comm of Stamp Duties [1964] NSWLR 183.

[29] A. McKenzie, Introduction to GST: A Practical Guide (New Zealand: CCH,
1988).

[30] Section 92 of the Australian Constitution and the Extra-Territorial
powers of the States impact on the States ability to enact such provisions.
Supra, note 6, pp. 371-386.

[31] Alan A. Tait, Value Added Tax: International Practice and Problems
(Washington DC: International Monetary Fund, 1988).

[32] Ibid.

[33] Ibid, at 56; See also Part 2.

[34] Consider the reforms of the Whitlam Labour Government 1972-1975 on
Education and the Hawke Labour Government on Medicare.

[35] See Note 31.

[36] Alan Bollard, New Zealand s Experience With Consumption Tax 9(3)
Australian Tax Forum (1992) 473 at 479-80.

[37] Canada - C$30 000 (Barbara McGiffin, The Canadian Goods and Services Tax
(GST) CCH Journal of Australian Taxation (December 1991/January 1992) 53 at
58); New Zealand - NZ$24 000.

[38] Abe Greenbaum, The Canadian Goods and Services Tax: A Sign of Things to
Come for Australia? 20(2) Australian Business Law Review (April 1992) 186
at 191.

[39] Supra, note 31, at 271.

[40] Supra, note 31, at 273.

[41] Supra, note 31, at 311.

[42] Ibid.

[43] Ibid.

[44] See Bambro (No 2) [1964] NSWLR 183 for example.

[45] See, generally 1993 Review of Western Australian State Taxes, N. McLeod,
ed., (Perth: Murdoch University School of Law, 1993).

[46] Committee of Inquiry into the Australian Financial System, Australian
Financial System Final Report (Canberra: Australian Government Printing
Service, 1981).