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Environmental taxes

Outcome paper:English
Cover note:English
Comment template:English
Global consultation status:Open
Deadline for comments:25/11/2010
Number of comments:31
Comments from the global consultation
Posted onProvided byComments
23/12/2010Central Bureau of Statistics Israel1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
No, there may be some relation to environment in these payments.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
There could be a category of other for some unforeseen phenomenon related to environment
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes
17/12/2010Statistics Norway1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
See comments to question 2.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes, but the other environmentally related payments should be mentioned and included, in line with what is done with environmentally related subsidies and other transactions. Suggestion: Include one chapter containing all environmental related transfers/transactions, which further can be divided between environmentally related transfers from the general government (environmentally related subsidies and other transfers) and environmentally related payments to the general government (environmentally related taxes and other payments). One should also consider another main group including environmental related transfers that did not include the general government as an actor (some emission permits, charges etc). (One example is environmental related charges paid to industries for specific services done, i.e. like the mandatory charge in Norway put on some household appliances for having the shop/vendor to receive used household appliances and remove it in an environmentally friendly way).
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
The pros and cons of alternative definitions of governmental (environmental related) taxes and other payments should be discussed – setting the current recommendation into context. Why the current recommendation was chosen have to be better explained. The Eurostat/OECD definition of Environmental related taxes is a practical definition and disregard theoretical considerations of what should be called an Environmental tax – cf a Pigou tax.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
We think these categories are too general in order to use for comparisons between countries or for other analytical purposes.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
It is unclear what is meant by the relevant proportion – cf also the discussions about purpose in the subsidy issue and the physical tax base on tax issue
  7. Any other comments?
No comment
06/12/2010Statistics Finland1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes
  7. Any other comments?
When defining environmental taxes, could it be possible to also take into account the possible effect of taxes to innovations and structural changes in the economy? Environmental tax can play an important role promoting e.g. new technologies.
01/12/2010Turkey / Turkish Statistical Institute1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes. The scope of environmentally related taxes should include transactions defined as taxes on production and imports, taxes on income. But I have no comment on other current taxes and capital taxes.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes. The payments to general government of rent, fees, penalties, fines and other payments should be excluded from the scope of environmentally related taxes in the revised SEEA, since they are payments for services or current transfers.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes. Four categories are enough for grouping. But when the term transport used, first of all, people may think that taxes on energy used for transport should be covered under transport taxes. May be another term should be used, like vehicle or mean taxes, just to give an example.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes. If the aim of sulphur taxes is only to reduce SO2 emissions in all countries, taxes on sulphur should be categorised as pollution taxes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
I am not sure whether VAT should be related with environmental taxes. Because as indicated in the document, VAT are deductible for many producers.
29/11/2010New Zealand / Statistics New Zealand1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Statistics New Zealand agrees that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Statistics New Zealand agrees that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Statistics New Zealand agrees that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Statistics New Zealand agrees that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Statistics New Zealand agrees that taxes on sulphur should be categorised as pollution taxes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Statistics New Zealand agrees as this shows clear alignment with 2008 SNA.
29/11/2010Botswana Central Statistics Office1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
No comment
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
No comment
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
The definition of environmental taxes is too broad. It is noted that for subsidies the purpose is an important factor. See recommendation 7.2 here items are only included if they are directly intended to support environmental protection or resource management. This contrasts with 6.3 for taxes where the purpose is not mentioned. Since subsidies are, effectively, negative taxes, the treatment should be consistent. In addition, main purposes are important in other areas such as the classification of natural resource use and management activities.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
No comment
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
No comment
29/11/2010Australian Bureau of Statistics1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Agree.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Agree, but recognise that fines (for contravening environmental regulations, illegal logging etc) may be important in some countries and could be included where significant. SEEA should provide guidance on the boundary between taxes and natural resource rents. Of particular interest are resource rent taxes based on income (or super profits) which have the characteristics of both tax and a resource rent.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
ABS has reservations about the definition. As far as possible there needs to be consistency in the criteria used to decide what is ‘environmental’ across all the accounts of SEEA. It should be the default position. The proposal is inconsistent with the definition of environmental subsidies and environmental protection expenditure where ‘main purpose’ is the essential criterion. Intent would seem important when assessing government and private response to environmental issues whether it by imposing taxes, paying subsidies or undertaking environment protection and resource management expenditures. It is also the case that subsidies are often thought of as negative taxes in the SNA environment (taxes are often presented net of subsidies in the SNA production account) However, as noted in the Outcome Paper, tax regimes may also have the affect of increasing the relative prices of products or activities that impact on the environment, even though the primary purpose may be to raise revenue. While this is so, different tax regimes between countries for raising general revenues will make it difficult to make international comparisons. If the proposal goes forward, the ABS has a preference for deleting the words ‘is a physical unit (or proxy of it) of ’. Important environmental taxes such as resource rent taxes can be based on a base denominated in monetary units.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Following on from the previous comments, the ABS has a preference for CEPA, consistent with environmental protection activities. It is also consistent with the recommendation that environmental subsidies be classified as far as possible using classifications of environmental activities.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Agree
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Do not agree. VAT is designed to be non-distortionary and therefore does not alter relative prices in favour of the environment.
  7. Any other comments?
SEEA should contain a discussion of carbon taxes and particularly the treatment of emissions permits, including carbon trading.
26/11/2010Jordan/ Department of Statistics1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
We disagree because environmentally related taxes should be incentives to complain to environmental regulations and legislations rather than regular taxes system. Therefore, environmentally related taxes could play a major and vital role in encouragement of environmental friendly industries by reducing taxes on production and imports in such industries and at the same time increasing taxes on production and imports on polluters industries.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
We disagree to exclude the environmental taxes and fees from government sector, because in this process we encourage the government to overexploit the natural resources and omitting the natural resources potentially environmentally damaging and degradation cost from the payments relating to the use of assets, which cause underestimation of our natural resources assets.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
We agree to define environmental tax on a physical base units on something has proven negative impact on environment.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
We agree for this classification of environmental taxes. In addition to transboundary related taxes. For example, the riparian countries and taxes related to waste mobilization.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
We agree based on the end purpose of use of the sulphur.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
We agree to include environmental related taxes in tax base of a VAT particularly in developing countries which have not an effectively enough environmentally related tax system.
26/11/2010Peru/ INEI1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
The revised SEEA must include all transactions defined as taxes in the SNA 2008, since it will have a consistency between both systems.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Agree. Payments should be excluded from the scope of taxes, but must be treated as a rent since the government has the property of natural resources.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Agree. Taxing the physical unit or something that has a negative impact. Since this will help to care for the environment, as well as using the income for not having a negative impact.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Agree. But there should be an opening for a tax group related to assets.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Agree.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Agree. It has an impact on the environment.
26/11/2010Mexico/ INEGI1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes. Considering that the productive processes make use of the environment and natural resources, it is necessary to record the taxes related to the environment, similarly as the way which are identified in the 2008 SNA.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes. However, must be taken care in differentiating among rent, fees, penalties, fines and other payments and taxes at the time to register. In addition, should be consider that the fate of these taxes it is not necessarily intended to compensate the damage caused to the environment.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes. In fact it is a direct and homogeneous way to determine the taxes. Thus, while the depletion of the natural resources and environmental degradation are increasing, the paid should be higher. Additionally, the SEEA considers in a more accurate way the treatment in physical units of natural resources due to the complexity presented by the valuation in monetary units.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Being the SEEA the conceptual and methodological framework of reference for the current environmental accounting, we agree with the proposed classification of environmental taxes, in addition, this proposal allows us to identify issues of great importance as climate change by burning fossil fuels. However, in practice only some countries have available information in the detail necessary for this classification.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes. It is noteworthy that the tax can be calculated in based on the sulfur content in the fuel, which is different to the treatment which is given to carbon dioxide, that is a result of burning fossil fuels. In addition, CO2 is a gas that goes directly to the atmosphere, while it is not possible to identify the final destination of sulphur.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes. This will make possible to be consistent with the method of valuation considered in the 2008 SNA, in case that the administrative records lets to identify the environmental tax related to the natural resource depletion and environmental degradation.
26/11/2010Slovak Republic/ Statistical Office1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes, we agree.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes, we agree.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes, we agree.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes, we agree.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes, we agree.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
No comment
  7. Any other comments?
No comment
26/11/2010Estonia/ Statistics Estonia1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
I agree that environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
I agree that environmentally related taxes should include only taxes according to the 2008 SNA definition and exclude payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government. However there is a need for statistics for environmentally related taxes, charges and levies in order to monitor the application of polluter pays principle and the effectiveness of ecological tax reform. The key principle of an environmental tax reform is a partial re-orientation of taxes from taxation of income to taxation the use of natural resources and pollution of nature. According to ecological tax reform countries should increase the use and weight of environmental economic instruments and reduce the burden on employment related taxes (income or social taxes). Providing statistics on environmentally related taxes, charges and levies is important for monitoring effectiveness of implementation of ecological tax reform. According to elaboration of monitoring of ecological tax reform it is important to track how have the revenues and tax rates of environmentally related taxes, charges and levies changed. For that purpose there is a national interest to compile statistics on environmentally related taxes, charges and levies, which is wider scope than just environmental taxes. For example mineral resources extraction charge is not considered as a tax according to national accounts´ definitions but as a rent (D45). However in the context of ecological tax reform this charge is treated as environmental related taxation of mineral resource use. Data on environmental taxes, charges, levies and penalties can be a base for a calculation of fair tax rates. So we propose to use two different terms: “environmental taxes” (data consist only taxes defined in 2008 SNA) and “environmentally related taxes, charges, levies” as a wider definition
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
We agree in general, but maybe there has to be made a clear remark in the definition of environmental taxes that environmental tax is a tax according to the national accounts´ definitions, as we find important to use only one term while determine the environmental taxes – either “environmental tax” or “environmentally related tax”. It is confusing, when both terms are used in methodological manuals.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes, the environmental tax categories are reasonable.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Taxes of sulphur should be categorised under pollution taxes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
We do not agree with this point. As the principle, it would be nice to include the relevant proportion of the VAT to the environmentally related taxes to get really all taxes related to environment, but the question is, how to do this in practice? We see many difficulties in calculation of such proportions - where usually estimations are used – and we do not believe it is worth the effort.
26/11/2010Germany/ Federal Statistical Office 1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes, in order to keep the definition in line with the 2008 SNA
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes
  7. Any other comments?
The CO2 emission permits should be added to the environmental tax base list, since they are treated as taxes in the 2008 SNA.
26/11/2010Hungary/ Central Statistical Office1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
YES
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
NO COMMENT
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
YES
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
YES
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
YES
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
NO COMMENT
  7. Any other comments?
NO
26/11/2010European Commission - Eurostat1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
YES, but we recommend that the categories should be the same as in SNA-2008: - Taxes on production and imports (D2) - Current taxes on income, wealth, etc. (D5) - Capital taxes (D91p) ''Other current taxes'' are a subcategory of ''Current taxes on income, wealth, etc'' and should not be made into a separate category.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
YES, payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope and definition of environmentally related taxes. However, environmentally related property income (rents), fees, penalties, etc are important environmentally related transactions and should not be excluded from the conceptual description of SEEA transactions in the revised SEEA.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
YES The definition is correct and has been applied in data compilation exercises by countries for a number of years. We would like to point out that income may be employed as a proxy for a physical tax base. Otherwise it would not be logical to label an income tax (D5) as environmental tax.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
YES
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
YES
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
YES This was agreed within the London Group discussions and is also supported by Eurostat/DG TAXUD Task Force on Environmentally related transfers.
  7. Any other comments?
The revised SEEA should describe in a clear way all the issues that were discussed during the LG meetings. These issues refer in general to: difference between taxes and fees, a clear description of resource taxes and the difference between resource taxes and resource rent. In particular, an important aspect refers to Resource taxes and the inclusion of taxes on oil and gas extraction. Discussions in the London Group showed that most of the oil and gas extraction taxes fall under category D5 - Current taxes on income, wealth, etc. These are taxes levied on the profit of the extracting units and the tax base is not a physical unit, but rather a "proxy" of it (please see point 3).
26/11/2010Latvia/ Central Statistical Bureau1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
For consistency reasons we agree it should be according SNA.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
In principal we agree, but it is very difficult to distinguish what is tax and what is fee. In our opinion it should be explained more detailed with criteria and definitions of fees.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Agree.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes
  7. Any other comments?
No
26/11/2010Switzerland/ Federal Statistical Office1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes. However, as taxes on carbon dioxide are included under energy taxes, the term “pollution taxes” is not completely consistent with the term “Taxes on pollution” (see SNA 2008 7.97f) used in the SNA 2008 and the users of the statistics must be made aware of that. As an alternative, we would suggest using another term.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes
  7. Any other comments?
No
26/11/2010France/ Ministry of Ecology1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Agree
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Agree
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Agree However for some environmental taxes the actual tax base is not a physical unit as they are calculated ad valorem as a specified % of the product unit price. We consider that this situation falls under the flexible "or a proxy of it". The outcome text could give examples in order to leave out any ambiguity.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Agree
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Agree
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Agree
  7. Any other comments?
There may be some difficulties to understand the position taken about the resource rent. All resource rents are not necessarily bases of rent payments to the general government as the owner of the ressource. If rent payments are well specified (i.e royalties, licences, fees) as rents to the general government as the owner of the ressource, then there is no ambiguity and SNA treatment has to be followed: not a tax. On the contrary, if the natural resource (oil deposit for instance) is not owned by the general government but by the private sector (oil company), how would be considered a charge instituted by the general government which applies to the resource extracted? In our opinion this charge in such a context should be classified as an environmental tax since there is no service - putting the natural resource at the disposal of the extracting corporation – offered by the general government.
24/11/2010UNSD1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes. However, to fully articulate in the SEEA the role of government in the environment it is necessary to present an analysis where these sorts of payments to government are also taken into account.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes. However, for the sake of comparability these taxes should also be classified according to CEA resource use and management activities in addition to the standard ISIC and SNA institutional classifications.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes in the case of non-deductible Vat
  7. Any other comments?
None
24/11/2010Republic of Mauritius/ CSO1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Another open category could be added.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes
  7. Any other comments?
None
24/11/2010United Kingdom/ Office for National Statistics1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes. However, it is unclear how payments made as part of emissions trading schemes should be considered. We recognise that there will be a separate outcome paper on emissions permits but it would be helpful if any conclusions are then reflected in the final text on environmentally related taxes, particularly if they diverge from the principle of including all SNA transactions. Further comments will be provided when the outcome paper on emissions permits is issued.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes, this is the most practical approach. Agree that environmental taxes should not be determined by either intention or purpose of expenditure of revenues.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes, such a classification system is helpful for international comparison. However, the presentation of metadata which explains which taxes fall in which categories should be encouraged. This returns to the point that the tax base is the physical unit of something that has a proven, specific negative impact on the environment rather than the justification for the tax. For example, the justification of a fuel tax may be congestion externalities and so the immediate assumption of the user would be that the tax is transport related but the physical base is energy.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes, for the specific case as illustrated by the UK example, where VAT is charged against the environmental tax. With this exception, we continue to support the general principle that VAT is excluded.
  7. Any other comments?
Regarding the tax bases listed in annex 1, the Eurostat Task Force on Environmentally Related Transactions has been reviewing the list, for example, to consider including flights/ticket bookings under transport. This would apply for Air Passenger Duty in the UK. It may be helpful to liaise with Eurostat on this before finalising the text.
24/11/2010Austria/ Statistics Austria1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes, we agree.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
We agree that these payments should be excluded from the scope of environmentally related taxes. But we insistently propose to consider a category “other environmentally relevant payments” to complement environmentally related taxes. These payments are of increasing importance. E.g. in Austria they amounted to 50% of environmentally related taxes in 2008. In the Austrian case this category consists of levies for parking of motor vehicles, waste charges, wastewater charges, water charges, toll sticker revenues, road section toll revenues, distance related toll revenues (heavy duty vehicles), toll evasion and security charge (aviation).
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes, we agree.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes, we agree.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes, we agree.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes, we agree.
23/11/2010Ecuador/INEC1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes, we do agree that the SEEA should be involved in the environment-related taxes as it is looking to identify the economic transactions in the SNA the previous identification for taxes that are related to the environment. That''s why we agree the way is set: • Taxes on production and imports, including taxes on products and other taxes on production. • Income taxes • Other current taxes • Capital taxes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
No, we don´t agree that payments to general government of rent, fees, penalties, fines and other payments made by companies for use or removal from any good from the state (mineral or energy resources) is outside the scope of implementing environment-related taxes for rental payments of property of the state are usually determined on the basis income from the sale of the extracted resources, while the concept of income taxes are calculated for both sales revenue and costs of extraction.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes, we do that the tax an environmental is a tax whose base is a physical unit of something that has a proven, specific negative impact on the environment. We agree with this approach because in this way is based on the technical use to measurement the damage and costs that they would sue and repair the damage caused to the environment.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes, we do that there are four major categories in which the taxes for the environment are together
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes, we do that taxes on sulfur should be categorized as a tax on pollution and should not be separated the taxes on sulfur from the dioxide carbon taxes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes we do, that the tax base of a VAT includes a charge related to the environment but, this tax must be classified according.
  7. Any other comments?
None
23/11/2010Netherlands/ Statistics Netherlands1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
yes
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
yes
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
yes
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
yes
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
yes
  7. Any other comments?
Tax bases: The Eurostat list of tax bases may not be complete. What is missing is that kilometres driven may also be used as an tax base. In the Netherlands it has been proposed to introduce a tax based an the actual kilometres driven by cars. This tax would supplement the tax on car ownership. This clearly would be an environmental tax, but the tax base is not in the list.
22/11/2010Poland/ Central Statistical Office1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes. This division, according to SNA, is also taken into account in the Proposal for a Regulation of the European Parliament and of the Council on European Environmental Economic Accounts.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes, they should be excluded from the scope of environmentally related taxes in the new SEEA.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes. The definition is consistent with SNA and Eurostat manual of 2001 “Environmental taxes – A statistical guide”.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes. See point 1.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes, but it can be the problem to identify SO2-taxes separately in tax statistics.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
It should be but in the situation of our country impossible for separation from the tax statistics.
19/11/2010Canada/ Statistics Canada1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
No comments.
  7. Any other comments?
No comments.
18/11/2010USA/ Bureau of Economic Analysis1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes. The terminology “proven, specific impact” is open to interpretation. This will likely invalidate international comparisons, as different agencies interpret “proven, specific impact” differently. See our comments to issue 4.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
It is unclear if we are being asked to agree to these categories as a classification system, or to the more specific listing given in annex 1. (For example, paragraph 32 states that these are the classifications used by the European Union, whereas annex 1 is entitled “Tax bases to be included in the environmental tax statistics framework”.) We agree to the categories listed above as a classification system, but not to the specific categories listed in annex 1. For example, we cannot see how the purchase of a vehicle in itself has a proven negative impact on the environment, and thus we would not classify car sales taxes as environmental taxes. (We do not dispute that consumption of transport – i.e. driving the car – would result in pollution. This would be captured however under the energy taxes listed in annex 1.)
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes.
18/11/2010Denmark/ Statistics Denmark1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Yes.
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Yes. However: - Rent, fees, and other payments are also of interest and could/should be accounted for as well in SEEA. - Restricting the accounting of environmentally related payments to the government to the SNA taxes only, but including other types of transfers/payments when it comes to the “subsidies” introduces an asymmetry in the SEEA accounting structure.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Yes.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
Yes.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
Yes.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Yes, but only the non-deductible VAT.
  7. Any other comments?
There is a need to consider the tax base carefully, e.g. inclusion of taxes on extraction of oil and gas, and he treatment of payments of CO2 permits (which are treated as taxes in SNA 2008.). It seems inconsistent to exclude taxes on extraction of oil and gas from resource taxes, but include taxes on abstraction of water. We suggest to include all those payments which are categorised as taxes in the SNA 2008, if they are environmnetally/resource related.
18/11/2010Azerbaijan/ State Statistical Committee1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Agree
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Agree
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Agree
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
No comments
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
No comments
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
No comments
  7. Any other comments?
No comments
18/11/2010Malaysia/ Department of Statistics7. Any other comments?
1. The Department of Statistics Malaysia (DOSM) has no experience in developing any environmental account using the SEEA framework. However, DOSM is currently trying to develop one of the SEEA account (eg Water account) with the experience and knowledge gain while visiting Australia Bureau Statistics (ABS), and also with the guide of the SEEA 2003. However DOSM, experience constrains in developing this account with lack of expertise in this field, human resources and budget. 2. DOSM also wants to learn in detail how to develop the SEEA account. Please inform and include us if there is any training/workshop to be conducted in future. 3. Therefore DOSM is unable to contribute fruitful comments for the revision of the SEEA. However, DOSM would like to be involved in further development of this matter.
18/11/2010Philippines/ National Statistical Coordination Board 1. Do you agree that within the revised SEEA the scope of environmentally related taxes should include all transactions defined as taxes according to the 2008 SNA – i.e Taxes on production and imports, Taxes on income, Other current taxes and Capital taxes?
Agree, for consistency purposes; SEEA being a satellite account of the SNA
  2. Do you agree that payments to general government of rent, fees, penalties, fines and other payments relating to the use of assets owned by general government should be excluded from the scope of environmentally related taxes in the revised SEEA?
Operationally, it is difficult to distinguish between fees…. and taxes since these terms may be used loosely by countries. Hence, it is should be left to the compiler in dealing with these items provided there are sufficient definitions and criteria for this purpose.
  3. Do you agree that an environmental tax be defined as a tax whose tax base is a physical unit (or a proxy of it) of something that has a proven, specific negative impact on the environment?
Agree, as it is specific for the environment.
  4. Do you agree that environmentally related taxes should be classified according to the four categories: energy taxes, transport taxes, pollution taxes and resource taxes?
These categories are useful however, there may be other tax items on environment that may be difficult to classify into these four categories. Hence, an item that can catch this difficult to classify tax items may be useful/helpful.
  5. Do you agree that taxes on sulphur should be categorised as pollution taxes?
We suggest to work on revisiting the four categories early suggested before dealing with this item.
  6. Do you agree that, where the tax base of a VAT includes an environmentally related tax, the relevant proportion of the VAT should be included as part of environmentally related taxes?
Agree, but operationally some countries might find it difficult to implement such. Hence, there should be a recommendation along this line.
  7. Any other comments?
None
 

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