Re: ABDC Response to Reforms to Deductions for Education Expenses Discussion Paper

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1 The Hon David Bradbury MP Assistant Treasurer PO Box 6022 House of Representatives Parliament House Canberra ACT July 2013 Dear Assistant Treasurer Re: ABDC Response to Reforms to Deductions for Education Expenses Discussion Paper The Australian Business Deans Council (ABDC) is the authoritative collective voice of Pro Vice Chancellors, Executive Deans, Deans and Heads of Business Faculties and Schools in Australian universities, from which 35 per cent of Australian university students graduate. 1 ABDC promotes and advances excellence in business education and research as well as engagement with industry, the government and the community. ABDC welcomes the opportunity to provide feedback on this Reform to Deductions for Education Expenses Discussion Paper. Our position ABDC supports Federal Government initiatives and policies that are of vital important to Australia s increased productivity, innovativeness and long term economic growth, including improving school education and increasing participation in undergraduate programs. We also understand that there are cases where tax deductibility of self education expenses may have significant personal benefits that do not improve the Australian economy. But the expenses associated with pursuing postgraduate university degrees, diplomas and certificates (tuition fees and other legitimate degree costs such as course materials) do not fall in this category of personal benefit. Instead, they materially enhance national well being. Supporting postgraduate business education is essential to increasing Australia s human capital and hence our competitiveness in the Asian century. Postgraduate students are likely to have among the highest annual self education expenses in all of Australia, well in excess of the proposed $2,000 cap and not captured by the medians reported in the Discussion Paper. Our students who work for large enterprises may be able to continue their postgraduate studies on the same financial basis as today by taking advantage of the FBT exemption available to big business for its investments in the human capital of its employees. However this effective tax sheltering of postgraduate study is not available to SMEs and the self employed. The 1 Calculated from Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education (DIICCSRTE), Completion Count by Field of Education, Higher Education Statistics Data Cube (ucube),

2 adverse effects of the government s proposed deduction cap would therefore most heavily fall on these SMEs and the self employed their pre dominance being particularly evident in rural and regional Australia. For the reasons outlined above, ABDC recommends that the government exempt university tuition fees and related legitimate course expenses from the proposed legislation. This exemption would not affect the government s goal of reducing the ability of working professionals to deduct from tax, expenses related to lavish conferences and the like. It would, however, preserve the ability of working Australians to make socially desirable educational investments to increase their own human capital from which the country will continue to benefit greatly. The impact on universities Introducing the proposed $2,000 cap would be a major impediment to sustaining let alone building participation in postgraduate education. Many professional Masters programs in subjects such as Business Administration, Commerce, Finance and Marketing rely heavily on self education tax deductions to attract full time employed and mature age students into study options that would otherwise be financially out of their reach. At a time when universities will have to absorb the negative impact of the government s efficiency dividend and the increasing competitive threat from overseas universities, massive open online courses (MOOCs) and other online providers of higher education, this capping will have a large additional adverse financial effect on universities. The negative impact on university budgets is likely to run into tens of millions annually on large campuses as students either, do not enrol in postgraduate education, withdraw from programs in which they have enrolled, or slow down study so that their annual education expenses do not exceed the $2,000 cap. The impact on individuals Capping deductions discourages business professionals, executives and managers (and those who aspire to these positions), especially individuals, who seek to upgrade their skills and knowledge by accessing postgraduate university qualifications. It will significantly disincentivise individuals 1) seeking to upgrade skills through a university education or 2) currently studying, but who will have to pay costs, unexpected from when they decided to undertake their program of study. We need to be up skilling all our managers and workers in the digital age, and the capping of tax deductibility will harm this ambition. The impact on the economy ABDC is very concerned not only about the impact on our postgraduate programs and students but also regarding the adverse impact of the proposed capping on the Government s own priorities for social inclusion and improving productivity. The flow on effect from the lack of development of advanced skills and knowledge in management, particularly in SMEs, where the productivity gains from better human capital are potentially largest, will be substantial. This proposal undermines the vital role of universities in ensuring an adequate talent pool of postgraduates, to enhance 2

3 management capability (particularly SME capability), to drive increased innovation and to improve productivity the most important and necessary factors in boosting Australia s long term economic growth, prosperity and competitive advantage in global markets and supply chains. Australia has a good record in starting new firms, but we do not perform so well in growing them into the mid sized firms that can succeed in export markets and drive prosperity in terms of jobs in Australia. Evidence shows that Australian SMEs are held back by limited access to finance, markets and management skills. 2 A 20 country comparison of medium to large manufacturing companies found that Australia s management practices in an overall management assessment ranked below those of other countries such as Canada, Germany, Japan, Sweden and the United States. 3 The impact on government By including university tuition fees and related legitimate course expenses in this proposed legislation, the government would negatively impact both 1) participation rates in postgraduate higher education a central pillar of a developed society and 2) faith that government encourages and supports education as a priority. Referring to the examples provided in the discussion paper we agree that the current system allows for unfair and inconsistent application by rewarding private benefits with tax breaks. It would however seem unfair and inaccurate to equate, as the Discussion Paper does, the following two examples and hence justifying the capping of self education expenses on both: Example two, where Sam, to maintain his professional licence, can claim the cost of a trip to a conference in Costa Rica, which includes a significant amount of sightseeing and Australian based speakers in the program. Example six, Ann, who is undertaking an MBA with annual fees of $25,000. (Assume Ann works for a recently established SME as a manager, where she has to pay her own education expenses to improve her management capability and knowledge). Let us explore Ann s case further. If we assume she was on a salary of $80,000, under the current scheme she will receive over $8,000 in tax deductions (see figure 1 below). However with the proposed capping at $2000, she will receive only $650. This capping would represent an effective annual increase in course costs to Ann of 44 per cent a powerful disincentive for Ann to continue further study. 2 DIICCSRTE, 2013, A Plan for Australian Jobs The Australian Government s Industry and Innovation Statement, page xxi. 3 Bloom N, Genakos C, Sadun R & van Reenen J 2012, Management practices across firms and countries, working paper no , National Bureau of Economic Research, Cambridge, Massachusetts, (as referenced in the Asian Century White Paper). 3

4 Figure 1: The impact of current and proposed tax deductions No Self Education Part time MBA Pre tax income of $80,000 Expenses Study $2000 Cap Self Education Expenses Tax Deductions 25,000 2,000 Taxable Income 80,000 55,000 78,000 Tax payable 17,547 9,422 16,897 Tax deductions 8, Corresponding increase in course cost to individual 44% Note: Tax payable calculated at ATO rates income tax/ and excluding Medicare levy Over one fifth of all students studying postgraduate coursework part time are in business disciplines. 4 Most postgraduate business students are pursuing qualifications other than the MBA (e.g. Master of Commerce), but their annual degree costs are very similar to those of MBAs. Anything close to a 44 per cent increase in fees would discourage many of these 33,000 business students from continuing their studies none of our business schools would contemplate raising their own tuition fees by anything near this amount. But if it is enacted, the decrease in enrolments, the policy would inevitably cause, would not only significantly shrink the planned cost savings anticipated by the Federal Government, but would have an adverse multiplier effect. Not only would we see a multi million dollar decrease on an already diminishing higher education revenue stream but also a decreasing talent pool of postgraduates needed to increase our SME capability and productivity. We would also expect a negative impact on future tax earnings from a higher salaried workforce. The Productivity Commission 5 has shown that higher levels of education increase incomes. Compared to a person with a year 11 education or less, on average a university education adds around 40 per cent to an individual s average earnings. Based on median salaries for recent graduates, this figure increases by $10,000 for graduate certificate/diploma graduates and by $15,000 for Masters graduates. 6 So while on the one hand an individual should expect an increase in their salary, the Federal Government should also expect an increase in tax revenue not to mention the increase in national productivity. The underlying principle of this proposed legislation supports improving the human capital of a firm, but improving the human capital of individuals in a firm is seen as a private benefit. The biggest flow on effect might be that larger more prosperous companies are encouraged to cover education expenses of their employees, while smaller, emerging companies, such as the one for which Ann works, would be disadvantaged. Although long term it is anticipated that an individual like Ann would see an increased personal salary as a result of her investment in her education, based 4 Calculated from DIICCSRTE, Completion Count by Field of Education, Higher Education Statistics Data Cube (ucube), Productivity Commission, March 2010, The Effects of Education and Health on Wages and Productivity, page xii. 6 Data from Graduate Careers Australia, all fields of education masters by coursework and graduate certificate diploma, Australian Graduate Survey,

5 on the research mentioned earlier, the return on investment or private benefit may take several years to realise. The benefits we believe should be measured on the long term impact on the Australian economy. Recommendations from ABDC ABDC urges the Federal Government to ensure any future legislation provides: 1. A level playing field between big business and self employed individuals or SMEs, who represent 99.7 per cent of Australian businesses 7 and are the engine room for new ideas, new business activity and employment growth of Australia s post mining future A long term aim to maximise national productivity and wealth by increasing human capital, skills and knowledge, irrespective of whether it happens in firms or as individuals. To pursue capping of tax deductions on self funded postgraduate education would see individuals faced with such a significant disincentive to study further, that student enrolments would dramatically fall, SMEs would be disadvantaged by a smaller higher skilled postgraduate talent pool, our economy would lose productivity, and the government would not realise the tax revenue savings it envisages. ABDC recommends an alternative excluding formal education (tuition fees and legitimate course costs) from the proposed legislation so as not to disadvantage SMEs or individuals making serious investments in their human capital. In a world where increasingly a Bachelors degree is not enough, we need to encourage human capital investment an investment required to transform Australia from a high cost post mining boom economy to a thriving socially inclusive and knowledge based economy, with strong productivity growth and increased international competitiveness In summary, ABDC recommends that the government exempt university tuition fees and legitimate course expenses from the proposed legislation, so as not to discourage those seeking to pursue further university education education that would greatly improve Australia s productivity, innovativeness and long term economic growth. Yours sincerely Professor Michael Powell President (and Pro Vice Chancellor (Business) Griffith University) Professor Geoffrey Garrett Vice President (and Dean, Australian School of Business The University of New South Wales) 7 Australian Bureau of Statistics, 21 May 2013, Count of Australian Businesses including Entries and Exits, Factsheet DIICCSRTE, 2012, Enterprise Connect Booklet, page 5. 5

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