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An International Comparison of Capital Gains Tax Rates
American Council for Capital Formation
August 1998
Most industrial and developing countries tax individual and corporate
capital gains more lightly than does the United States, according to a
survey of twenty-four industrialized and developing countries that the
ACCF Center for Policy Research commissioned from Arthur Andersen LLP.
The Center's analysis shows that the United States taxes both short- and
long-term capital gains more harshly than most other countries. High capital
gains tax rates increase the bias against saving and investment, raise
the cost of capital for new investment, and slow U.S. economic growth.
Individual Capital Gains Tax Rates
Both short- and long-term capital gains on equities are taxed at higher
rates in the United States than in most of the other twenty-three countries
surveyed. Short-term gains are taxed at 39.6 percent in the United States
compared to an average of 19.4 for the sample as a whole (see comparison
table, parts I & II,
and accompanying notes [marked with asterisk]).
Long-term gains face a tax rate of 20 percent in the United States versus
an average of 15.9 for all the countries in the survey. Thus, U.S. individual
taxpayers face tax rates on long-term gains that are 26 percent higher
than those paid by the average investor in other countries. In addition,
the United States is one of only five countries surveyed with a holding
period requirement in order for the investment to qualify as a capital
asset.
The reduction in individual capital gains tax rates in the Taxpayer Relief
Act of 1997 lowered the cost of capital for new investment and thus will
enhance U.S. productivity and economic growth. The 1997 reductions almost
certainly contributed to the current budget surpluses. In addition, shortening
the holding period for long-term capital gains from eighteen to twelve
months, which was included in the IRS Restructuring and Reform Act of
1998, signed into law by President Clinton July 22, 1998, will be a further
boost to investment.
Corporate Capital Gains Tax Rates
Similarly, short- and long-term corporate capital gains tax rates are
higher in the United States than in most other industrial and developing
countries surveyed. Both short- and long-term gains are taxed at a rate
of 35 percent in the United States, compared to an average of 22.8 percent
for short-term gains and 19.6 percent for long-term gains in the sample
as a whole. In other words, U.S. corporations face long-term capital gains
tax rates almost 80 percent higher than those of their competitors in
other countries. The U.S. tax rate on long-term corporate capital gains
is higher than that of all but two of the other countries surveyed (Germany
[45 percent] and Australia [36 percent], and Australia provides for indexing
the cost of an asset). In addition, only four of the twenty-four countries
surveyed impose a holding period in order to be eligible for preferential
corporate capital gains tax rates.
Conclusion
Sound tax policy and economic considerations, as well as revenue consequences,
argue for further reductions in U.S. individual capital gains taxes. In
addition, the U.S. corporate capital gains tax rate of 35 percent should
be reduced, thereby creating a meaningful differential between the tax
rate on ordinary corporate income and on capital gains. This would reinstate
the historical U.S. treatment of corporate capital gains: an alternative
corporate capital gains tax was part of the Internal Revenue Code from
1942 until its repeal by the Tax Reform Act of 1986.
PART I: COMPARISON
OF CAPITAL GAINS TAX RATES FOR INDIVIDUALS
(*indicates
note) |
| Country |
Gross
Domestic Saving as a Percent of GDP |
Maximum
Individual Tax Rate |
Individual
Capital Gains: Max. Tax Rate on Equities |
Individual
Holding Period |
| Short-term |
Long-term |
| Argentina |
18.0 |
33.0 |
Exempt |
Exempt |
No |
| Australia |
21.0 |
48.5 |
48.5 |
48.5; asset cost is indexed |
No |
| Belgium |
23.0 |
56.7 |
Exempt |
Exempt |
No |
| Brazil |
18.0 |
27.5 |
15.0 |
15.0 |
No |
| Canada |
21.0 |
31.3 |
23.5 |
23.5 |
No |
| Chile |
26.0 |
45.0 |
45.0; annual exclusion of $6,600 |
45.0; annual exclusion of $6,600 |
No |
| China |
44.0 |
45.0 |
20.0; shares traded on major exchange
exempt |
20.0; shares traded on major exchange
exempt |
No |
| Denmark |
21.0 |
61.7 |
40.0 |
40.0; shares valued at less than $16,000
exempt if held 3+ years |
Yes, 3 years* |
| France |
21.0 |
58.1 |
26.0; annual exclusion of $8,315 |
26.0; annual exclusion of $8,315 |
No |
| Germany |
23.0 |
55.9 |
55.9 |
Exempt |
Yes, 6 months |
| Hong Kong |
31.0 |
20.0* |
Exempt |
Exempt |
No |
| India |
24.0 |
30.0 |
30.0 |
20.0 |
Yes, 1 year |
| Indonesia |
33.0 |
30.0 |
0.1 |
0.1 |
No |
| Italy |
22.0 |
46.0 |
12.5 |
12.5 |
No |
| Japan |
30.0 |
50.0 |
1.25% of sales price or 20% of net gain |
1.25% of sales price or 20% of net gain |
No |
| Korea |
34.0 |
40.0 |
20.0; shares traded on major exchange
exempt |
20.0; shares traded on major exchange
exempt |
No |
| Mexico |
23.0 |
35.0 |
Exempt |
Exempt |
No |
| Netherlands |
26.0 |
60.0 |
Exempt |
Exempt |
No |
| Poland |
18.0 |
40.0 |
Exempt |
Exempt |
No |
| Singapore |
50.0 |
28.0 |
Exempt |
Exempt |
No |
| Sweden |
22.0 |
57.0 |
30.0 |
30.0 |
No |
| Taiwan |
N/A |
40.0 |
Exempt (local company shares) |
Exempt (local company shares) |
No |
| United Kingdom |
15.0 |
40.0 |
40.0; shares valued at less than $11,225
exempt |
40.0; shares valued at less than $11,225
exempt |
Yes, 1 to 10 years* |
| United States |
16.0 |
39.6 |
39.6 |
20.0 |
Yes, 1 year* |
| Average |
25.2 |
42.4 |
19.4 |
15.9 |
79.2% have no holding period |
PART
II: COMPARISON OF CAPITAL GAINS TAX RATES FOR CORPORATIONS
(*indicates
note) |
| Country |
Maximum Corporate
Income Tax Rate |
Corporate Capital
Gains: Maximum Tax Rate on Equities |
Corporate
Holding Period |
| Short-term |
Long-term |
| Argentina |
33.0 |
33.0 |
33.0 |
No |
| Australia |
36.0 |
36.0 |
36.0; asset cost is indexed |
No |
| Belgium |
40.2 |
Exempt |
Exempt |
No |
| Brazil |
33.0 |
33.0 |
33.0 |
No |
| Canada |
29.1 |
21.8 |
21.8 |
No |
| Chile |
15.0 |
15.0 |
15.0; asset cost is indexed |
No |
| China |
33.0 |
33.0; shares traded on major
exchange exempt |
33.0; shares traded on major
exchange exempt |
No |
| Denmark |
34.0 |
34.0 |
Exempt* |
Yes, 3 years* |
| France |
41.7 |
41.7 |
23.8 |
Yes, 2 years |
| Germany |
45.0 |
45.0 |
45.0 |
No |
| Hong Kong |
16.0* |
Exempt |
Exempt |
No |
| India |
35.0 |
35.0 |
20.0* |
Yes, 1 year |
| Indonesia |
30.0 |
0.1* |
0.1* |
No |
| Italy |
37.0 |
37.0 |
27.0* |
Yes, 3 years |
| Japan |
34.5 |
34.5 |
34.5 |
No |
| Korea |
28.0 |
20.0; shares traded on major
exchange exempt |
20.0; shares traded on major
exchange exempt |
No |
| Mexico |
34.0 |
34.0 |
34.0 |
No |
| Netherlands |
35.0 |
Exempt |
Exempt |
No |
| Poland |
36.0* |
Exempt |
Exempt |
No |
| Singapore |
26.0 |
Exempt |
Exempt |
No |
| Sweden |
28.0 |
28.0 |
28.0 |
No |
| Taiwan |
25.0 |
Exempt (local company shares) |
Exempt (local company shares) |
No |
| United Kingdom |
31.0* |
31.0* |
31.0*; asset cost is indexed |
No |
| United States |
35.0 |
35.0 |
35.0 |
No |
| Average |
32.1 |
22.8; United States is 54% higher than average |
19.6; United States is 79% higher than average |
83% have no holding period |
| *Notes
on Table/Parts I and II |
| Maximum Individual Tax Rate |
| Hong Kong |
Maximum marginal tax rate is 20 percent for the assessment year
1997/1998 and 17 percent for 1998/1999. |
| Individual Capital Gains |
| Denmark |
Gains on shares held three or more years are tax exempt if taxpayer
owns less than US $16,000 of the company's shares. |
| U. Kingdom |
Sliding scale of rates applies to 1 to 10 years of ownership through
an exclusion that rises gradually to 75 percent for assets held 10
or more years. Thus, assets held 10 or more years face a top marginal
rate of 10 percent. |
| United States |
Shares held 12 months or more are taxed at a rate lower than that
on ordinary income under the IRS Restructuring and Reform Act of 1998. |
| Maximum Corporate Income Tax Rates |
| Hong Kong |
Maximum corporate rate is 16 percent for the assessment year 1998/99
and 16.5 percent for 1997/98. |
| Poland |
The corporate rate will be reduced to 34 percent in 1999 and to
32 percent for 2000 and beyond. |
| U. Kingdom |
The corporate rate will be reduced to 30 percent effective from
April 1999. |
| Corporate Capital Gains |
| Denmark |
For corporations, capital gains are tax exempt if the holding period
is longer than three years. |
| India |
Capital gains from sale of equity investments and securities listed
on stock exchange and held for more than one year are taxed at 20
percent. |
| Indonesia |
An additional tax of 0.5 percent applies to the disposition of founder
shares (effective as of May 29, 1997). In this case, if the taxpayer
does not want to use the facility of 0.5 percent, the normal progressive
tax rate of 30 percent is applied. |
| Italy |
For corporations, a substitute tax of 27 percent applies on capital
gains arising from the transfer of shares held and accounted for as
financial assets for at least three years. |
| U. Kingdom |
The corporate rate will be reduced to 30 percent effective from
April 1999. |
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