MEMORANDUM SUBMITTED BY LEONARD BEIGHTON
AND DON DRAPER (ICC 03)
SUMMARY
1. The Working Families Tax Credit (WFTC)
has failed to treat couples and their children in a way comparable
with lone parents and their children. Figures given below show
the extent to which children in families headed by couples in
work remain in poverty. By contrast, the WFTC lifts well clear
of poverty children in families headed by a lone parent with the
same gross income. We believe that, because couples and their
children have health and educational advantages, and because of
the economic and social cost of the breakdown of marriage, it
would be sensible if the Integrated Child Credit (ICC) provided
couples with a fiscal advantage. But, even if this view is not
accepted, it cannot make sense to discriminate against them.
2. This discrimination against couples arises
because the WFTC confuses aggregation and independent taxation.
It aggregates the incomes and savings of a couple, but then ignores
the second adult when looking at their needs.
3. It might be possible to remove this discrimination
against couples by adjusting the Employment Tax Credit (ETC),
but as the ETC is due to be phased out as incomes rise before
the ICC is tapered, that could not be a comprehensive solution.
Instead, our answer is to introduce an Integrated Family Credit
(IFC) which would look at the family as a whole consistently throughout
the tax credit system in the same way as is done with the income
related benefits. Unlike the present proposals, this approach
would provide the seamless system of support for children for
which the Government is looking. It would also remove the anomaly
within the Children's Tax Credit (CTC) under which the taper discriminates
against single earner couples.
4. As it stands, the ICC will do little
to provide employment opportunities for all. This is because it
has been devised without regard to Housing Benefit (HB) or Council
Tax Benefit (CTB). The recommendation for a housing credit made
by the Social Security Committee in its recent Report on HB now
needs to be pursued; and its recommendations on the length of
time an award should last and on the savings disregard should
apply to the ICC also. Progress towards making work pay and providing
employment opportunities for all will be made only if the income
related benefits and tax credits are looked at in the round.
INTRODUCTION: THE
WORKING FAMILIES
TAX CREDIT
(WFTC)
5. The aim of the Government in introducing
the Integrated Child Credit (ICC) is to provide a seamless web
for supporting families with children whether or not they are
in work, so as to move further towards the elimination of child
poverty. It is to be introduced in conjunction with the Employment
Tax Credit (ETC), which is to take further the policy of making
work pay and of providing employment opportunities for all. As
such these tax credits build on the WFTC, so that a good starting
point in considering the prospects for the ICC is to examine how
effective the WFTC has been in achieving these aims.
6. As we showed in our earlier written and
oral evidence to the Committee [eg First Report, Session 1997-98,
pp267-276 and 318-24], one feature of the WFTC has been its failure
to treat couples, and children in families headed by couples,
in a manner comparable with the treatment of lone parents and
their children. Couples with the same gross income as lone parents,
and in otherwise similar circumstances, will end up in the distribution
of incomes one, two or even possibly three deciles lower than
lone parents. As a result children in families headed by couples
are more likely to end up in poverty.
7. This is illustrated by the following
table which shows in which decile in the distribution of incomes
particular families would fall if the tax and benefit system planned
for April 2001 were in force now:
Table 1
| Household Income Distribution BHC at April 2000 prices
|
| Gross income per week (£) | 100
| 150 | 200 |
250 | 300 | 400
|
| Single personno children | 2
| 4 | 6 | 7 |
8 | 9 |
| Lone parentone child (2) | 5
| 6 | 6 | 6 |
7 | 8 |
| Lone parenttwo children (2, 4) | 4
| 5 | 6 | 6 |
6 | 7 |
| Lone parenttwo children (14, 16) |
3 | 4 | 4 | 4
| 5 | 6 |
| Single earner married coupleone child (2)
| 2 | 3 | 3 |
4 | 4 | 5 |
| Single earner married coupletwo children (2, 4)
| 2 | 3 | 3 |
4 | 4 | 5 |
| Single earner married couplethree children (2, 4, 6)
| 3 | 3 | 4 |
4 | 4 | 4 |
| Single earner married coupletwo children (14, 16)
| 2 | 2 | 3 |
3 | 3 | 4 |
| Two earner (80:20) married coupletwo children (4, 6)
| 2 | 3 | 4 |
4 | 4 | 5 |
8. The present position can also be illustrated by the
following chart which shows the position of these families when
their gross income is £100 a week. The chart shows that the
children of all three lone parent families have been pulled out
of povertyin the two families where the children are young
markedly sowhile the children in families headed by couples
remain in poverty.

Key
1 is a single person with no dependants.
2 is a lone parent with one child aged two.
3 is a lone parent with two children aged two and four.
4 is a lone parent with two children aged 14 and 16.
5 is a single earner married couple with one child aged two.
6 is a single earner married couple with two children aged
two and four.
7 is a single earner married couple with three children aged
two, four and six.
8 is a single earner married couple with two children aged
14 and 16.
9 is a two earner married couple, income split 80:20, with
two children aged four and six.
The poverty line is estimated to be at an equivalised income
of £166 per week, ie the April 1999 figures published in
Households below Average Income 1994-95 to 1998-99 increased by
2.5 per cent. For technical reasons this is likely to be an underestimate.
Comparable charts illustrating the position at other income
levels can be provided if requested.
9. Moreover these figures understate the difference in
treatment. They assume that none of the lone parents is in receipt
of the lone parent premium. In addition, any maintenance payments
which a lone parent receives is ignored in calculating WFTC.
10. We would argue that the tax-benefit system should
favour families headed by couples and their children. All the
evidence shows that on average adults are healthier and happier,
and their children are healthier, do better at school, and have
fewer behavioural and criminal problems if they are married, or
at least cohabiting, than if they are lone parents. To provide
a fiscal advantage for people to come together and to be committed
to each other in marriage would therefore make considerable economic
and social sense.
11. Even if this argument is not accepted however, what
cannot make sense is to provide a fiscal advantage for those families
who on average are less likely to be successful in bringing up
their childrenfor that is what the evidence shows. Moreover,
given the very significant cost to the Exchequer of marriage breakdown,
it would seem only reasonable to ensure that couples who stay
together do not face a tax-benefit system which is less favourable
to them than if they split up.
12. The disadvantage which couples face has come about
in part because of the Government's concern that lone parents
should be helped back into work. But it does not follow from this
laudable objective that this help should put the children of couple
families at a comparative disadvantage, in particular within a
mechanism like the ICC which is designed to give support for all
children and to take all children out of poverty.
13. The other reason why couples and their children are
disadvantaged is that the WFTC does not consistently follow the
practice to be found with the income related benefits generally.
This is to look at the family and its needs as a whole. In assessing
how much WFTC is due the income of the spouses or partners is
aggregated, as are their savings. However the needs of the second
adult in a couple are then ignored and no tax credit is given
in respect of him or her. In this way the principle of aggregation
is followed when it may be to the disadvantage of the coupleand
then at that point the principle of independent taxation is applied,
also to the disadvantage of the couple. This is clearly inconsistent
as well as unfair.
14. In our view this issue needs to be tackled now within
the WFTC without awaiting its replacement by the ICC in 2003.
THE TREATMENT
OF THE
FAMILY WITHIN
THE ICC AND
THE ETC
15. At first sight the comparative treatment of couples
and their children seems unlikely to be improved within the ICC:
indeed it may well get worse. This is because, by focussing on
the children alone without regard for their family circumstances,
the credit will not easily be able to take account of the additional
costs which a couple necessarily incur in the way that the benefits
system does. Paradoxically, by focussing on children, the ICC
may do them a disservice by favouring those environments in which,
on average, they do less well.
16. It would of course be possible to provide for the
second adult elsewhere in the tax-benefit system. There could
be separate benefits and tax credits for adults which fully took
account of the needs of couples whether they had children or not.
Indeed within the tax credit system the ETC will do that to some
extent. But even if, when the ETC applies, it takes full account
of the needs of adults so that couples and their children were
treated comparably with lone parents and their children, as things
stand that would not fully meet the case.
17. This is because, under the Government's proposals,
the ETC is to be tapered out before there is any tapering of the
ICC [Tackling Poverty and Making Work Pay, paragraph 4.12]. In
other words, there will be significant numbers of families who
will be entitled to the ICC but not to the ETC in full, or even
to the ETC at all. A tax credit system which takes account only
of children cannot properly reflect the needs of their family
as a whole.
18. One way of meeting this would be to taper out the
ETC at the same time and over the same range of incomes as the
ICC. In this way all families would be treated equally according
to their family circumstances and the disadvantage suffered by
couples and their children would be removed. However in practice
this might be quite complex to arrange.
THE INTEGRATED
FAMILY CREDIT
(IFC)
19. The alternativewhich we favourwould
be to introduce an IFC in place of both the ICC and the ETC. This
would mesh in well with the benefits system and take over smoothly
from Income Support and Jobseeker's Allowance when the recipient
found work. The income of spouses and partners would be aggregated,
as would their savings, and the amount of tax credit would be
calculated taking full account of the circumstances of all the
family, as happens with the income related benefits. Childless
people would qualify for the credit at a lower level.
20. Under the Government's proposals, in the case of
couples the ICC will be paid to the carer of the children and
the ETC to whoever is in work. It would be possible to divide
the payment of the IFC in this way, but to do so would seem to
be unnecessarily complicated. Payment of the WFTC through the
employer has added very considerably to the compliance burden
on businesses without really doing much to establish the credit
as a reward for work. With its proposal to pay the ICC to the
carer along with child benefit, the Government has largely abandoned
this principle on which initially it put so much weight. There
would seem little case for trying to resurrect it with the IFC,
all of which should go to the carer (or possibly to either parent
as with benefits generally).
21. While we have a system of income related benefits
based on aggregation and a taxation system based on the individual,
it is inevitable that there will be some discontinuity somewhere.
At present, as explained in paragraph 13 above, that discontinuity
arises in the middle of the WFTC. Under the system now proposed
by the Government, the discontinuity would arise in the middle
of both the ETC and the ICC. This runs counter to the aim of providing
a seamless basis of support for children. By contrast, with the
IFC aggregation would apply consistently to both income related
benefits and tax credits, leaving the tax system on an individual
basis. In this way the discontinuity would be least damaging.
22. But it leaves open the question whether aggregation
should apply throughout the tax-benefit system. To pursue this
in full might go beyond the compass of the Committee's present
inquiry. But one aspect of it is in point here. The Children's
Tax Credit (CTC), which is due to be introduced in April 2001,
is also based on a mixture of aggregation and individual taxation.
In awarding the CTC a couple is looked at together, and there
are provisions under which a cohabiting couple are treated as
man and wife. However the rules of independent taxation are then
applied, and the Credit is tapered where either one of them is
a higher rate taxpayer. In the case of a single earner couple,
the tapering will begin when their income is a little over £32,000,
and by the time their income reaches £38,000 no CTC will
be paid. By contrast, a couple where both partners earn will receive
the CTC in full if their joint income is £64,000 earned by
them equally. This is a good example of the sort of anomalies
which arise when the principles of the tax system are applied
to benefits without any adaptation for the circumstances.
MAKING WORK
PAY
23. Given the complexity of the income related benefits
and the interaction between them, any significant increase in
the incentive to work will be difficult to achieve except at very
considerable cost. Certainly the proposed ICC will have little
impact on the will to worknor, it is fair to say, would
the IFC except in the case of childless people. But it would put
all families on an equal footing in an area where any move towards
clarity and simplicity must be welcome. It would also mean that
parents would have a real choice whether or not to stay at home
to look after their children.
24. However the Committee itself in its recent Report
on Housing Benefit (HB) [Sixth Report, Session 1999-2000] referred
to the need in reviewing the relationship between HB and the new
tax credits to address the high marginal deduction rates [paragraph
79]. With respect, we wholly concur. We have long drawn attention
to the fact that the consideration of the WFTC and of HB has gone
on in separate compartments with little regard to their interaction.
25. Treasury Ministers have claimed significant reductions
in the number of people suffering the very highest marginal deduction
rates on a basis which takes no account whatsoever of HB or of
Council Tax Benefit (CTB)see for example the Budget 2000
Red Book, Prudent for a Purpose: Working for a Stronger and Fairer
Britain, paragraphs 4.66 and 4.67. Likewise the only reference
to HB or CTB in the Treasury publication Tackling Poverty and
Making Work Pay outlining the tax credits is in a footnote to
one figure. And even now, there is no mention at all of HB or
CTB in the very recent publication, Opportunity for all. One year
on: making a difference, or recognition of the impact of those
benefits on the incentive to take paid work.
26. At the same time, although the Housing Green Paper,
Quality and Choice: A decent home for all, made some reference
to WFTC, it hardly explored the interactions. This failure to
look across tax credits and the income related benefits as a whole
has now to be corrected if work is to be made to pay. As the Committee
recommended, the introduction into the new tax credits of a housing
credit might well radically simplify the structure of these benefits
and do more than anything else to strengthen the message that
work pays [paragraph 94 of its Report].
27. Our own recommendation for taking this forward was
to pass responsibility for oversight of HB to the Inland Revenue
(which we believe would also be likely to lead to significant
simplification and a reduction in fraud). We recognise however
that this proposal runs counter to the Committee's own recommendation
against administration by a central Government agency (although
in terms it did not consider the Inland Revenue) [paragraph 145].
So we do not press the point. We suspect however that other means
will have to be found for ensuring that these issues are considered
in the round together, and that the present compartmentalisation
is broken down.
28. The particular issue of the length of time for which
an award should last, on which the Committee made recommendations
in its report on HB [paragraph 29] and on which it is seeking
evidence here, is a good example of the need for a consistent
approach. There might be a case for having a different rule for
HB than for the tax credits, but the need for simplification so
far as possible suggests that it would probably be preferable
to have the same period for all purposes. But on this issue the
proposals on tax credits in Tackling Poverty and Making Work Pay
point in a direction which was argued against in the Housing Green
Paper. Until this sort of inconsistency is ironed out, the required
overall consideration of the whole tax-benefit system is unlikely
to be given effectively.
29. Similarly, in its report on HB the Committee recommended
that the value of the savings disregard should be increased to
its 1988 real value [paragraph 82]. However, while the disregard
in the case of the Disabled Person's Tax Credit is the same as
that for HB, WFTC is not paid once savings have reached £8,000,
half the level for HB. We see no good case for the difference
in treatment, and believe that the Committee's recommendations
for HB should also apply to the new tax credits.
CONCLUSION
30. The aim of reducing child poverty will not be properly
secured by the ICC as it stands. The family must be looked at
as a whole, whether through the IFC as we suggest or by some other
means. Similarly, the aim of making work pay, which is an important
component of the drive to reduce child poverty, will be achieved
only if the issue is looked at in the round and a common approach
is taken across departments and across all the tax credits and
income related benefits.
Leonard Beighton and Don Draper
Consultants on tax and benefits for Christian Action Research
and Education (CARE)
September 2000
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