Yes, it will be pretty short.
First of all, thanks very much for having us on this important issue. It's a pleasure to be here.
I think you've hit a lot of these issues already in a general way. We see ourselves as here to assist the committee in your review of this bill, and we thought it would be useful to explain the general framework or lens through which we in the tax policy branch evaluate tax credits like this one when they're presented to us.
As a general starting point, it's important to consider whether any proposal, any tax measure, is consistent with the general functions of the tax system. The primary function is to raise revenue, the revenues that finance the program initiatives that benefit Canadians.
The tax system does have secondary functions, and one of these functions—and this was touched on during your discussion—is incentives within the tax system to support economic and social objectives. They can be things like increasing savings and investment and promoting charitable giving. There are also disincentives in some cases, such as excise taxes on tobacco. There are a few activities we want less of, but there are many activities we want more of, and that's what we're talking about today.
A tax measure of the variety proposed in Bill C-240 serves one of these objectives-encouraging socially beneficial behaviours-at the expense of another-raising revenue.
In assessing such a trade-off it is important to consider whether the tax measure in question can be expected to be effective in meeting its stated goal, and whether it is efficient. That is to say, does it achieve its objective at relatively low cost compared to available alternatives? After all, the revenue forgone as a result of a tax measure could go towards government spending serving a similar end, or that supports other important government objectives.
One factor we take into account is the potential effect of the measure on the desired activity. Put simply, if the purpose of a tax measure is to encourage people to perform a particular activity, its effectiveness should be analyzed by looking at both its cost and the extent to which it causes more people to perform that activity than would have undertaken the activity in any event.
You touched on this as well. Tax measures also impose compliance costs for taxpayers and administrative costs for government, and there we're talking about the Canada Revenue Agency. These costs can contribute to reducing the overall efficiency of a measure, but it's important to consider how high the costs are and how the costs might compare to a similar measure if it were delivered as a spending program.
In addition to efficiency, equity is another criterion integral to policy analysis. Non-refundable credits provide taxable individuals with tax recognition at the same credit rate, irrespective of income level, versus a deduction, where the rate of relief increases with an individual's marginal tax rate.
There is often a strong case for making a credit non-refundable, to the extent that the measure is trying to properly account for the individual's ability to pay tax. However, non-refundable credits reduce an individual's tax payable and are therefore not useful for individuals who are non-taxable. Ultimately, the impacts of any tax measure on taxpayers at all income levels must be considered in the context of the overall progressivity of the tax system.
One final point, also of key importance when you're designing an efficient and equitable tax system and considering how the proposed measure might fit into that, is ensuring tax legislation is drafted in a manner that protects individual tax measures from being accessed in ways counter to the original policy intent.
During the course of our work on the tax policy development process at Finance Canada, legislative review and drafting of tax measures is a very integral part—Trevor is our expert—and ensures that technical issues don't arise that can inadvertently undermine the operation of the measure or of other provisions of the act.
Thank you, Mr. Chair.
Thanks to all the members of the committee.
We would be happy to elaborate further on any of these points or to answer any questions that committee members may have.