Corporation Tax in the Q2 2022 Institutional Sector Accounts

Ireland’s surging revenues from Corporation Tax are evident in the Institutional Sector Accounts which are now available for the second quarter of 2022.  Here is the four-quarter sum of Taxes on Income or Wealth (D.5.) paid by the non-financial corporate sector since 2004.

Obviously, we are interested in what has been happening in recent years and, in particular, the near-vertical increase seen in recent quarters.  Looking at the series there are three level changes that can be identified over the past decade: 2015, 2018 and 2022.

This is more evident if we look at the annual change of the four-quarter sum.  The three peaks correspond to the years listed above and are instances when the annual increase was 40 per cent of higher.

Of course, what is striking about the latest increase is that it is a 50 per cent increase on what was already an elevated level.  We could go back through some of the factors behind the 2015 and 2018 jumps but here will we focus on the most recent increase – though as the most recent it is the one we know least about.  It will be the first half of 2024 before the Revenue Commissioners report aggregate data for the CT returns filed with them for financial years ending during 2022.

One thing we can look at from the Institutional Sector Accounts is the indicative effective tax rate using Net Operating Surplus (NOS).  Some differences aside, NOS in the national accounting equivalent of Earnings Before Interest and Taxation (EBIT) from financial accounting.  There may also be some timing differences that distort things from time-to-time but these should wash out.

Here is the ETR on the Net Operative Surplus of Non-Financial Corporates since the start of 2014.  To help with some of those timing issues both the numerator and denominator are taken as a four-quarter moving sum.

What we see is that, bar the odd fluctuation, the ETR on NOS has been generally fairly stable over the past decade or so.  And this is a period when there have been some tumultuous changes in Ireland’s national accounts (2015 and all that).

There a small step-up evident in late 2018.  It is possible this is due to rule changes related to the claiming of capital allowances for intangible assets introduced in Budget 2018. But that is something for another day.

It can also be seen in the chart that the ETR is below the 12.5 per cent headline rate for Ireland’s Corporation Tax.  A key reason for this is likely to be differences in the treatment of the depreciation of aircraft. 

For tax purposes in Ireland, aircraft can be amortised over an eight-year period while in the national accounts a wide-body aircraft is depreciated over 25 years, which better reflects the actual lifespan of the asset.  In both cases the gross, or pre-depreciation, profits will be the same.  Due to the longer depreciation period, the net profit in the national accounts will be higher and this reduces the effective rate.  Tax accounts for aircraft leasing will have more depreciation (or at least will have more depreciation quicker) which will reduce net profits and lead to a higher ETR, probably close to the 12.5 per cent rate.  Again, this is something for another day and is not really our interest here. 

Our interest is in the ETR in the chart for the past two or three quarters which is the highest for the period shown.  At 9.6 per cent, the ETR for Q2 2022 is around two percentage points higher than the average from 2014 to 2021 (7.3 per cent).  The average in 2019 and 2020 (post the 2018 step-up) was 8.0 per cent.

Is there something that could be pointed to that could have caused this recent rise in the ETR?  There is nothing that particularly stands out.  There doesn’t appear to have been any rule or rate changes that could be pointed as contenders as explanations.

One issue could be the preliminary nature of the 2022 figures for NFCs in the latest institutional sector accounts.  The CSO will have a fair handle on gross profits - from trade data and other sources.  They can obviously see how much Corporation Tax is being paid from the monthly Exchequer statements – but the detail behind those payments may not yet be available to them.

As alluded to above, companies are currently paying Corporation Tax linked to profits made in 2022.  Companies make preliminary Corporation Tax payments in months six and eleven of their financial year – by which time it is expected that they will have 90 per cent of their expected Corporation Tax liability paid.  Companies then file their full Corporation Tax return in month nine following the end of their financial year and accompany that filing with any outstanding amount due.

So a large company with a year-end of December 31st will make its first preliminary Corporation Tax payment in June (45 per cent), make its second preliminary payment in November (90 per cent) and file its full Corporation Tax return the following September.

A similar schedule has been set out for alternative year-ends. For example, if a company has a year end of September 30th, its first preliminary payment will be due in March, its second in August with its full return to be filed by the following June.  This could be significant has 2022 has seen unusually large CT revenues reported for March and August.

Of course, the Exchequer Returns also give no reason for an increase in the ETR.  One possible explanation is that the CSO have underestimated profits and that these will be revised up in subsequent releases which will, in turn, reduce the ETR.  It’s certainly possible but the CSO have been keeping an ever-closer eye on some of the key MNCs operating in Ireland via its Large Cases Unit (LCU).

An alternative explanation is that the gross profit figure is fine but that the net profit, i.e. post depreciation, will be revised.  Companies pay Corporation Tax on their net profit.  In recent years, there have been huge claims for capital allowances for intangible assets.  However, these allowances, at least as related to the original acquisition of the intangible asset, will be exhausted.

This means a company could face a much higher tax bill even if its gross profit is unchanged.  This is because it has run out of capital allowances to use as an offset against the gross profit.  If this was to happen, the companies net profit would increase and it would have to pay more tax.

It is possible that this is the reason for some of the 2022 increase in Corporation Tax.  Of course, absent the full returns of the companies it is just supposition.  It is not clear how the tax treatment of capital allowances for intangible assets aligns with the consumption of fixed capital for those assets in the national accounts.  Both are versions of depreciation and, as set out above for aircraft, they do not have to coincide.

The Institutional Sector Accounts show no decline in the consumption of fixed capital for NFCs.  Here are the quarterly CFC figures for the NFC sector since 2012. 

The step changes linked to the onshoring of intangible assets (Q1 2015, Q1 2020 and others) are clearly visible.  The increases over the past two and a half years are more gradual and more like those that would be linked to the ongoing, and regular, increase in the stock of tangible assets (buildings, plant and machinery) owned by the sector.

Could some of the 2022 increase in CT be linked to the exhaustion of capital allowances? It could be. It certainly is something that could happen over the coming years.  But it will a while before we have evidence of that. 

How it will be treated in the national accounts will also be worth keeping an eye on.  As noted, the exhaustion of the capital allowances will not impact gross profits – so GDP won’t be directly impacted. It is net profits that will change – so the impact may be on GNP.  Higher net profits accruing to foreign-owned companies would push down on GNP.  This would reduce the gap between GNP and GNI*.

Another possibility is that the intangible assets are relocated when the capital allowances run out.  This would have a direct impact on GDP – pretty much the reverse of what we have seen with the onshoring in recent years, most notably the event in 2015.

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The Household Sector in 2022: Continued Savings

The CSO have published the Q2 2022 update of the institutional sector accounts.  They continue to show a strong performance for the household sector – at least in aggregate terms.  A previous discussion of estimates for distributional sector accounts is here.

It should also be noted that the figures are presented in nominal terms, i.e., not inflation adjusted. Here is the current account showing income, consumption and savings for the first half of the past five years.  Percentage changes relative to 2019 (pre-COVID) are also shown.

The bottom line is that the household savings rate remains elevated.  The savings rate was 13 per cent for the first half of 2019; it was 24 per cent for the equivalent period of 2022.  This is the result of strong income growth (aggregate compensation of employees is up over 20 per cent since 2019) and modest consumption expenditure growth (up five per cent over the same period).

In the first six months of 2019, households received €50.0 billion of employee compensation.  This increased to €60.6 billion in the first half of 2022.  There was an increase in pay from all sectors but the largest, and fastest increase was from non-financial corporates.  Companies to the first half of 2019, businesses paid out €7.4 billion more on their employees, an increase of 23.1 per cent.

The increase in income has resulted in an increase in income taxes paid.  These are up 36 per cent compared to 2019.  Social insurance contributions are also up with contributions to private pension schemes up nearly 40 per cent (from €3.5 billion in the first half of 2019 to €4.8 billion this year).

The last few years has seen significant changes in social benefits received from the government sector.  These were €11.8 billion in the first half of 2019 and rose to €15.1 billion in 2020 (due the lockdowns and the Pandemic Unemployment Payment).  They rose to €15.9 billion in 2021 before falling back to €13.3 billion in the first half of this year.

All told, there was a near 20 per cent rise in the gross disposable income of the household sector in the first half of 2022 compared to the same period of 2019.  As noted, the increase in consumption expenditure has been more muted with only a five per cent rise over the same period.

The household sector had €7.4 billion of gross savings in the first half of 2019.  Although 2022 saw a slightly lower level than both 2020 and 2021, at €16.1 billion it remains significantly higher than pre-COVID levels with the savings rate continuing to exceed 20 per cent.

The capital account (below) shows that these savings are not being used for capital formation (investment spending) though the household sector did have just over €1 billion of net capital formation in the first half of 2022.  This compares to negative net capital formation in the equivalent periods of the preceding three years (as depreciation – consumption of fixed capital – exceeded gross capital formation).

One notable item in the capital account is the €3 billion of investment grants received in 2022.  This is linked to the Mica Redress Scheme which was approved by Government earlier in the year.

The household sector remained a significant net lender in 2022.  Other figures suggest that most of this is going on increased deposits (though the €3 billion from the Mica Scheme will go on the financial balance sheet as an “other receivable”.  There will also have been a reduction in loans liabilities.  What is needed is an increase in capital formation – new houses.

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Downward Historical Revisions and a Large 2021 Increase in the Modified Current Account

The current account of the balance of payments is an important macro-economic indicator. For a variety of reasons Ireland’s headline current account outturns are pretty useless as an indicator of the underlying position of the economy. To that end, the CSO have been publishing a modified current account for a number of years.  The latest estimates were published last week.

Historical Revisions

The first thing we note is that the historical series has been revised down.  This is something that may have been expected given it was thought that something may be mucking up the current account and the impact of the statistical discrepancy.  Anyway, here are the revisions.

For 2022, the estimate of CA* has been revised down from €24 billion to €13 billion.  This is still a significant surplus and equivalent to around 6.5 per cent of GNI* in 2020.

Large Increase in 2021

The second thing we note from the latest estimates is the large increase for 2021.  The 2021 estimate of CA* is a surplus of €26 billion or 11.1 per cent of GNI*.  In a very timely manner, the CSO have published institutional sector accounts that are consistent with the recent National and International Accounts.  Using these we can get a sectoral breakdown of the modified current account.

The primary drivers of Ireland’s underlying position in the current account of the balance of payments are the household and government sectors.  This remains true to the large increase showing for 2021.

Household savings remained elevated in 2021 while the government deficit closed significantly - due mainly to surging revenues.  Typically taxes would not feature in a discussion of the current account.  They might impact sectoral positions but are generally internal transfers.

Corporation Tax and the Current Account 

Ireland is unusual in having a large share of Corporation Tax paid by foreign-owned companies.  Some of these have set up operations in Ireland to service the domestic market but the largest source of Corporation Tax are foreign-owned FDI companies with operations in Ireland to manufacture for or service markets abroad.

About three-fifths of Corporation Tax is based by US MNCs.  This tax is paid from the profits made on export sales and boosts Ireland’s current account.  The money is not counted as a factor outflow to foreign shareholders but goes to the government as corporate income tax payments.  Strong rises in other taxes such as Income Tax and VAT also helped improve the government’s position.  That the household sector maintained its savings at such an elevated level points to a strength in the position of that sector – albeit in aggregate terms.

The Corporate Sectors in 2021

At this stage we can’t delve too deep into developments in the corporate sectors.  That will come later in the year when a split by foreign and domestic ownership is made available.  For the moment we can see that this is where most of the revisions arise.  The “not sectorised” component of the current account for 2020 went from +€6.4 billion in the 2021 estimate to +€2.4 billion in the latest estimate. 

While the impact of the non-financial corporate sector in 2020 (though technically a residual to make the sectoral balances consistent with CA*) went from +€9.5 billion in last year’s estimates to €1.0 billion in the latest figures.  It is these two changes that led to the downward revision in CA* for 2020 shown in the opening chart.

The contribution of the NFC sector also seems to have played a role in the large 2021 increase in CA* – see the large red block in the column for 2021 in the second chart.  But, as noted above, probably best to wait until the foreign/domestic split of that is made available later in the year before drawing any conclusions on that. 

Who Should be Spending More?

Looking at the household and government sectors shows that the improvement in 2021 was more than just a measurement anomaly.  With the quarterly figures now available we can extend this to Q1 2022.  Here it is as a four-quarter moving sum.

One conclusion that could be drawn from this is that the government is (not yet) saving any of its corporate tax largesse – but the household sector is. Could we get households to spend more and the government to save a small bit?  And the increase in household spending can be greater than any saving done by the government.  We don’t need a +€20 billion outturn as currently shown in the above chart.

Events, Dear Boy, Events

If it’s extra spending we’re looking for then it may already be happening – but due to outside circumstances rather than a conscious decision to spend more. Here is national net monthly fuel imports. 

Pre-COVID these were running at around €400 million a month.  The latest figures go to May 2022 and show net imports of around €1 billion a month.  Import spending at that rate won’t be long in putting a dent in national net lending. But seems unlikely to be large enough to wipe it out.

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Continued Calm in the Aggregate Corporation Tax Calculation–apart from Capital Allowances Claimed.

This time last year we noted the relative calm across most of the items in the 2019 update of the Revenue Commissioner’s aggregate Corporation Tax calculation.  The recent release of the 2020 update has seen this largely continue. 

This may not be a surprise as, elevated though they are, Exchequer Corporation Tax receipts were relatively stable across 2018 (€10.4 billion), 2019 (€10.9 billion) and 2020 (€11.8 billion).  It is also hard to discern a clear impact of the COVID-19 pandemic in the figures.

Anyway here is the calculation of Taxable Income for the most recent five years that are available.

The bottom line is that Taxable Income for the financial years of companies that ended during 2020 aggregated to just over €110 billion, an increase of around €4 billion on 2020.  There is probably a bit more going on under the headline aggregate figures.

The starting point of Gross Trading Profits was actually lower in 2020 compared to 2019.  However, this was offset by lower figures for capital allowances used and trade losses carried forward used.  There may be a pandemic effect here via the impact on the aircraft leasing sector which would have seen a big drop in gross income in 2020.

There was a reduction in trade charges in 2020.  In this context these are typically certain royalty payments for the use of intellectual property.  The reduction may be due to the restructuring undertaken by US MNCs and the relocation of the IP either back to the US or onshored to Ireland.  We might have expected this to result in an increase in capital allowances but as noted above they actually fell.

There is however some tumult if we look at the figures for capital allowances claimed.  The figures in the above tables are for capital allowances used, that is actually offset against positive income in the year they are claimed.  In some cases firms may claim capital allowances but not have sufficient positive income to use them against.  Those unused capital losses are carried forward to subsequent periods where they may be offset against positive profits if they arise. [Technically, the unused capital allowances are carried forward as trade losses.] 

The first time we really got interested in these figures was when those for 2015 were published.  These gave insight into the 26 per cent GDP growth rate published by the CSO for that year.  In 2015, the amount of capital allowances claimed jumped from €24 billion the previous year to €51.5 billion.  There was an associated increase in the figures for capital allowances used which is also reflected in the increase in Gross Trading Profits (which are included in GDP).

The following years saw increases but nothing that really stood out – until 2020.  As can be seen, claims for capital allowances went from €86 billion in 2019 to €145 billion in 2020.  The annual increase in 2020 is bigger than the annual total for 2015.  But what is unusual now is that it is not associated with increases in the other related items.

As discussed above there was actually a slight drop in the amount of capital allowances used in 2020, as there was for Gross Trading Profits.  So we have a huge increase in capital allowances claimed but no evidence of an associated increase in profits.  It is hard to know what is behind the rise in claims for capital allowances.

The panel on the right of the table gives the figures for the consumption of fixed capital for non-financial corporates in the national accounts.  We can see that by and large the national account version of depreciation tracks the tax treatment of it.  Consumption of fixed capital jumped in 2015 and typically has been around 85 per cent of the figure for capital allowances claimed.

The figures can differ in how depreciation is treated.  Most notable the capital allowances for aircraft for leasing can be claimed over eight years whereas such aircraft will be depreciated over 25 years in the national accounts.

The difference between the figures exploded in 2020 with consumption of fixed capital in the national accounts being a little over 60 per cent of the figure for capital allowances claimed in the Corporation Tax statistics.  There may be some insight in the forthcoming annual national accounts set to be published by the CSO.

We return to the aggregate Corporation Tax calculation and look at how Gross Tax Due as derive from Taxable Income becomes Tax Due.

Again, there is really nothing of note that stands out in the 2020 figures.  The biggest impact on Tax Due comes from Double Taxation Relief and the Additional Foreign Tax Credit which reflects the tax paid in foreign jurisdictions on the worldwide income of Irish resident companies included in their Irish tax return.  A move to a territorial system would see such foreign income removed from the Irish tax base.

Elsewhere there were only small changes.  The amount of the R&D tax credit remained relative stable compared to 2019.  And the end point of Tax Due gives figures that closely match the receipts collected by the Exchequer.

There may be a bit more going on in the next releases.  In 2020, Corporation Tax jumped to €15.3 billion and is on track to be even higher in 2022.  And maybe additional data releases will give some insight into that unusual jump in capital allowances claimed in 2020.

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Distributional National Accounts for the Household Sector

Eurostat have published distributional national accounts for the household sector.  There is a small number of countries with national estimates with centralised estimates using a common methodology applied by Eurostat are available for all Member States.

Ireland is one of the countries with national estimates and these are available for 2015 and 2016.  The aggregates come from the national accounts with the distribution based on the relevant SILC and the 2015 Household Budget Survey. 

The following table presents the 2016 estimates showing the distribution by income quintiles (fifths of the distribution, bottom 20 per cent, next 20 per cent and so on).  The ratio of the share of the top 20 per cent to the share of the bottom 20 per cent is shown in the final column (S80/S20) to give some insight into the inequality of the distribution.

The accounts follow the typical layout of the sector accounts going from output to income to disposable income to consumption and concluding with savings.  In this instances, social transfers-in-kind (goods and services used by households but paid for by another sector, usually the government) are accounted for.  This gives Adjusted Gross Disposable Income on the income side and Actual Individual Consumption on the consumption side.

The starting point is Gross Operating Surplus which for the household sector is the value added from the provision of housing services.  Some of this will be actual rents charged by household landlords to other landlords but most of it will be the imputed rents of owner-occupier households.  This “income” nets out as consumption under CP04: Housing.  Adding the first two items gives the value added, or GDP, of the household sector.

Next is by far the most significant item on the income side: compensation of employees received.  This is wages and salaries and also any social insurance contributions made by employers for their employees.  Like self-employed income this has an unequal distribution but is not skewed to the same extent.  In 2016, the top quintile received almost ten times more employee compensation than the bottom quintile.

The next item, Gross Mixed Income, is primarily the gains (or losses) from self employment.  This has a highly unequal distribution with almost 25 times such income going to the top 20 per cent (of the income distribution) compared to the bottom 20 per cent - €31.5 billion versus €3.3 billion.

This distribution does not stand out if we look at the equivalent quintile share ratios for the other countries which have provided national estimates to Eurostat.  As these are experimental statistics some caution is probably warranted.

Ireland’s quintile share ratio for employee compensation is lower than those for the Netherlands and Sweden.

Property income received (mainly interest and dividends) is also heavily skewed with the top quintile in Ireland receiving over 25 times more than the bottom quintile.  Net property income for the bottom quintile is essentially zero while it was around €2 billion for the top quintile in 2016.  As noted above, building rents, most notably for dwellings, are not included in property income as they are counted as the provision of services and come under operating surplus.

The output and income figures resulted in a Gross National Income for the household sector in Ireland of around €110 billion in 2016.  Of that, around ten times more was attributed to the top quintile relative to the bottom quintile.

To get to Gross Disposable Income taxes and social transfers must be accounted for.  In 2016, the household sector paid €21.5 billion in taxes on income and wealth (in practice this is almost all income taxes).  Of this, almost half was paid by the top 20 per cent.  There were almost €18 billion of social contributions paid.  This includes PRSI (both the employee contributions and the employer contributions in respect of employees) and contributions to occupational and private pension schemes.  Around €6 billion of the social contributions paid went to such schemes.  Social contributions are also skewed towards the top of the distribution but the difference between the fourth and top quintiles is noticeably smaller.

Social benefits received are mainly transfer payments from the government but will also include pension income from occupational and private pension schemes.  Around €4 billion of the social benefits paid to households in 2016 came from such schemes.

After these we get to the national accounts measure of Gross Disposable Income (gross in this context means that it is before the consumption of fixed capital, i.e. depreciation, is accounted for).  Ireland had a quintile share ratio of 4.0 for gross disposable income in 2016.  Of the other countries with national estimates only Czechia had a lower estimate.

As noted above, these figures also factor in social transfers-in-kind.  These are goods and services provided to households but paid for by non-profit entities or the government.  The government provision can be purchases from market producers (such as medicines) or via non-market production of the government sector itself (such as health services).

Many of the quintile share ratios for this item are less than one as the bottom quintile receives more than the top quintile.  For Ireland, in 2016, it is estimated that the bottom decile received €6.1 billion of social transfers-in-kind with €3.7 billion going to the top quintile.  This gives a quintile share ratio of 0.6 which is the lowest for the countries shows.

Adding social transfer-in-kind to Gross Disposable Income gives Adjusted Gross Disposable Income.  As a result of the distribution of social transfers-in-kind, Ireland moves below Czechia and has the lowest quintile share ratio for Adjusted Gross Disposable Income in the set of countries shown.  This is illustrated by the graphic published by Eurostat with the results.

In the left-hand panel, Ireland has the highest share of Adjusted Gross Disposable Income going to the bottom quintile (but this is only for the seven countries with national estimates).

Finally, we can look at consumption and savings.  At this point an adjustment is made for the change in pension entitlements and this is the difference between the contributions to occupational and private pension schemes and the benefits received by households from such schemes.  As set out above, the difference between these was around €2 billion in 2016.  This is considered part of the savings of the household sector so is added back in here.

The consumption figure used in the presentation is Actual Final Consumption (which is equivalent to Actual Individual Consumption).  It excludes collective consumption such as policing and street lighting etc. 

In 2016, Irish households had €113.5 billion of Actual Individual Consumption with the top quintile have 2.3 times the amount of the bottom quintile.  Although Ireland had the lowest quintile share ratio for Adjusted Gross Disposable Income it has the highest quintile share ratio for Actual Individual Consumption.  Using the quintile share ratio indicates that Ireland had the most unequal distribution of consumption for the countries shown.  This can be seen in the right-hand panel of the graphic with Ireland having the smallest share of AIC going to the bottom quintile.

As it is not income that is is driving this result we must look elsewhere for an explanation.  Savings may provide it.  Italy hasn’t produced distributional estimates for consumption so is excluded.

There certainly is a bit going on here, especially for the bottom and top quintiles.  For all the countries shown there are very large differences between the savings rates of the bottom and top income quintiles.  All bar Ireland that is.  Indeed for most countries the bottom quintile is shown to be dissaving (by having a negative savings rate).  This excess of consumption over income in the bottom decile is particularly true for the Netherlands, Slovenia and Sweden. 

Ireland has a positive savings rate for the bottom quintile and the highest among the countries shown.  And at the other end, Ireland has the lowest savings rate for the top quintile.  This means that the change in the quintile share ratio when going from income to consumption is relatively modest in Ireland, going from 2.6 to 2.3 whereas for other countries the difference is much larger.  In The Netherlands, for example, the quintile share ratio goes from 3.6 for income to 1.8 for consumption.

The only quintile in Ireland that has a negative savings rate is the second quintile.  This could be due to a higher concentration of retirees in this quintile who may have savings to draw on to fund their consumption.  But it does see Ireland going from having the highest savings rate for the bottom quintile to the lowest one for the second quintile.

Such minor anomalies aside, at a broad level, the Irish estimates seem reasonably sound.  There may be differences in definitions or exclusions from the data that are behind some of the very large variations in the savings rates shown for other countries. In relative terms, Ireland may not be as good for the distribution of income, or as bad for the distribution of consumption, as these figures suggest.

Over time it is likely that more emphasis will be put on the publication of distributional national accounts estimates like these and any such wrinkles may be ironed out.  For now, it seems the case that the opening table gives a fairly good account of what is happening across the income quintiles of the household sector in Ireland’s national accounts.  And that’s a pretty good start.

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