New Zealand Winegrowers has made two public statements regarding excise in recent times. In the first it advocated shifting the accounting for excise to the retail end of the chain. In the second it advocated that the Government give the annual excise increase due on 1 July next year a miss owing to the significant impact it would have on the wine industry.
There is an unfortunate irony in that I suspect New Zealand Winegrowers is hamstrung by the technicalities (in particular that the true cost is not simply excise) in respect of its public pronouncements.
The fact is that excise on alcoholic beverages is a multi-layered beast. Demonstrating this may go some way to show why shifting excise to the retail end of the chain is both economically and ethically more desirable, and yet unlikely to happen.
Moreover, in pulling its punches New Zealand Winegrowers has refrained from pointing out the double up in the excise increase attributable to this year’s increase in the rate of GST. In short, the 5% forecast level of CPI inflation by next year includes the 2.2% annual effect of the increase in the rate of GST from 12.5% to 15%, which increase has already been factored into the excise impost (if not in theory, very much so in practice).
Allow me to illustrate this. The following table shows the impact on either the winery or the consumer (or, as often than not, both) in the event of a 5% excise hike next year.
|GST on Excise||3.51||0.29|
|Total Excise Impost||26.93||2.24|
|Add retail margin (e.g. 35%)|
|Excise portion of markup||8.20||0.68|
|GST on markup||1.23||0.10|
|Total Excise Impost incl margin||36.36||3.03|
|Adding a 5% excise increase|
|GST on Excise||3.69||0.31|
|Total Excise Impost||28.28||2.36|
|Add retail margin (e.g. 35%)|
|Exise portion of markup||8.61||0.72|
|GST on markup||1.29||0.11|
|Total Excise Impost incl margin||38.18||3.18|
|Consumer excise (ex winery)||1.35||0.11|
|Consumer excise (retail all inclusive)||1.82||0.15|
While the 35% retail markup is an approximation (as some distribution and retail combined mark ups will be less, and others more, depending on the channels supplied), the true impact at the consumer level will be greater when restaurant margins and other costs are added in.
Note also that the Government collects income taxes on the proportion of the margin on excise that may be retained as profits by the retailer.
Of course this is not the whole story. The 2010 GST increase had the following impact on the ex winery (GST inclusive) excise impost:
|Current Excise (ex winery)||23.42||1.95|
|2010 GST increase on Excise (ex winery)||0.59||0.05|
|Pre increase Total Ex-Winery||26.35||2.20|
What this means is that when you add the double slab of 2010 GST and 2011 increase, including GST on the increase, you get:
|Total GST (ex winery)||4.27||0.36|
|Total Excise Impost (2010 & 2011)||28.86||2.41|
|Total Increase from 1 Jul 2010||1.93||0.16|
|% Increase on 1 Jul 2010||7.3||7.3|
So how might excise have risen over 7.3% in 12 months? It is the proverbial anomaly when you have a tax on a tax.
Of course, it is one thing to have a double up – where the increase in a tax causes the increase in excise and, therefore, in the tax on that excise. The other question is the extent to which that reaches the consumer. If the retailer refuses to pay a higher price or compromise on its margins, the economic cost to the winery for continuing to supply that retailer is not the level of excise it must absorb, but the level of excise including the GST on the cost that is not able to be passed on.
Based on the assumption that at present a little under 40% of New Zealand wine is drunk domestically (and therefore subject to excise), and that about two thirds of this is tied to “immoveable” price point structures, accordingly about 66% of the total increase in excise, plus GST, is worn by the industry, and a mere 1/3 (representing about 13% of total NZ wine production) will be passed on to consumers or borne in some proportion by retailers.
It is curious then that the Law Commission and other advocates for higher levels of excise as a consumer behaviour influencer have not wholeheartedly supported NZ Winegrowers on its stance regarding shifting excise payment to the retail end of the chain. The fact that excise may be paid, by the winery, months or years before a bottle is sold is conveniently overlooked. More importantly, the whole situation goes to show how impotent and irrelevant the present system is from the perspective of using excise as a tool to fight alcohol abuse.
Two reasons, both morally questionable and conveniently overlooked from a revenue perspective, why an excise shift won’t happen:
- The tax on tax factor – Government would lose both the GST and income tax on the profit margin earned by downstream distributors and retailers on the excise charged as part of the price to them.
- The breakages and losses factor – a certain amount of wine will always be damaged or stolen after it has left the winery. The Government still collects excise on these losses. There is no provision for reversal, since the people who handle wine after it has left bonded warehouses (usually the winery or storage facility) are not accountable to NZ Customs.
On closer inspection, however, are either of these actually material or true?
The breakages and losses factor is difficult to quantify without adequate data. Assuming 2% as a breakages and losses factor (and I do not know if that is low or high) would mean a revenue loss of approximately $13 million on current excise estimates (including beer, spirits and other beverages also).
As regards the “tax on a tax” factor, if retail prices do not change from present levels, this need not be the case at all. There will be a range of costs and savings shifted between the upstream and downstream sectors. Retailers would be able to justify higher margins on the basis of taking on administrative costs (although in the age of GST compliance these should be not be onerous).
Let me illustrate. Under the present system, using a 35% indicative mark up rate, the general pricing economics look as follows:
|Total ex-winery price||123.42||10.28||874.56|
|Add retail margin (35%)||166.62||13.88||1180.66|
|Retail Price incl GST||191.61||15.97||1357.75|
|Effective total excise (incl GST)||26.93||2.24||190.84|
|Total value of GST||24.99||2.08||177.10|
However, if the excise collection is shifted downstream, the same formulae would produce a different result:
The level of total GST revenue lost is just $8.7 million under this scenario.
If, instead, prices are maintained at the same levels as originally, and we then work back to obtain the retailer margin:
|If price unchanged:||191.61||15.97||1357.75|
|Price excl GST||166.62||13.88||1180.66|
|Less ex-Winery price||100.00||8.33||708.61|
|Retail Margin (%)||43.20||43.20||43.20|
While the percentage margin is expanded, the actual value remains the same so that, aside from shifts in compliance and funding costs, the net taxpayer position remains the same.
The biggest single added cost would be the transitional cost of establishing bonded storage areas and the downstream compliance regime – although this is no different to what a winery with a cellar door or restaurant operation already has to manage, and would continue to have to do so.
Overall, however, from a wine industry perspective the small reduction in compliance costs (since all would need to continue as bonded areas) is less important than the balance sheet impact. Based on the (occasionally substantial but usually a matter of months) gap between incurring excise liabilities and receiving payment for most wine sales, the estimated working capital requirement incurred by the industry averages approximately $40 million and may well peak at closer to $50 million, not only incurring debt costs but also tying up valuable working capital that is not able to be utilised elsewhere.
At the present time, that release of overdraft working capital could mean the difference between survival and failure of many businesses under pressure from their banks.