AFTER years of pleading for lower taxes, corporate chiefs may soon have a dilemma on their hands.
In the next few months, an expert panel hand-picked by Treasurer Wayne Swan will take a hard look at the case for lowering corporate taxes further, as recommended by Ken Henry.
There's only one catch: for any tax cut, business must give up benefits worth just as much in return. Takes the fun out of a tax cut, doesn't it?
This sticky situation facing business may sound far removed from the world of personal taxes most people are concerned about. But in these tough fiscal times, it highlights a grim new reality that affects us all.
Despite all the wealth being created in mining, it has become clear that any goodies from the government such as lower taxes will now be funded by cuts elsewhere. We can no longer rely on government coffers bulging due to bumper resource prices.
The business tax working group, appointed by Swan last year, is grappling with this challenge. It will soon start assessing the case for company tax cuts and how to pay for them, after this month publishing a rough list of areas where Swan might trim some fat to pay for tax relief for loss-making small businesses.
Yet even for a fairly small measure, such as the proposal to make small business losses deductible, the need to find offsetting savings has raised some tough questions.
For example, high on the list of potential cuts was support for research and development. Up to $500 million could be saved over four years by tightening up the tax breaks for research and development by large companies, the report said.
But hang on, isn't research and development the kind of thing we should encourage to help lift the economy?
Heather Ridout, the chief executive of Australian Industry Group and now a Reserve Bank board member, quickly pointed this out.
"At a time when so much attention is on the need to raise productivity to offset the pressures of the high dollar, high energy prices and growing labour market inflexibilities, it does not make sense to encourage a wind-back of business R&D," she said.
Ridout is representing her members' interests, of course. But she also has a point. At a time when many manufacturers are in dire straits, cutting incentives for innovation does seem short-sighted.
Tax breaks for resources companies could also be in the firing line, such as rules that allow oil companies to write down their costs more quickly.
The government could save $1.2 billion over the four-year forward estimates by removing this perk, the report said. But after the political damage sustained by its mining tax battle of 2010, another battle with deep-pocketed resources companies may hold little appeal in Canberra.
Less controversially, a further $300 million a year could also be saved by limiting interest deductions for local subsidiaries of foreign multinationals.
Putting aside the merits of making these cuts, the report highlights the revenue challenge facing Canberra.
Making all three of the working group's potential cuts would produce about $3.9 billion in savings over the forward estimates.
It's hardly a paltry sum, and more than enough to fund the fairly narrow task of giving small businesses tax relief on losses. But it's nowhere near enough to pay for sweeping cuts in the company tax rate, which typically cost $1.5 billion a year for each percentage point.
Finding further savings that may pay for a company tax cut is the group's next, bigger, challenge. But as much as business wants lower taxes, it's hard to see companies agreeing to give up the $6 billion a year that would be needed to cut the rate to 25 per cent, as recommended by the Henry review.
Whether you support lower company taxes or not, the dilemma reflects deeper problems in our tax base. The Treasury secretary, Martin Parkinson, said in February that compared with before the global financial crisis, federal tax revenue's share of gross domestic product had slumped by about 4 percentage points. This is equal to about $60 billion.
With sharemarkets in a funk and house prices falling, capital gains tax receipts today are worth about 0.5 per cent of GDP, compared with 1.5 per cent a few years ago.
Eight years in a row of tax cuts have left the income tax base weakened. This weakness in tax receipts is why businesses won't be getting a tax cut soon without losing major benefits.
And it's a similar story for areas that are closer to home for most of us such as taxes affecting personal income, or superannuation.
Lower-income earners are effectively getting a one-off tax cut this year with the carbon price, because compensation is likely to outweigh increased living costs. But beyond that, don't hold your breath for lower taxes soon.
With both parties viewing budget surpluses as the holy grail, tough decisions such as these are likely to remain the norm for a while to come.
Yet Joe Hockey insists an Abbott government would deliver personal tax cuts and a "modest" company tax cut. How Hockey will achieve this without the revenue from the carbon price or the mining tax is hard to fathom.