Comparative Tax Policy Approaches in New Zealand and Australia: Instructional Guidance for Hong Kong?

Abstract

Tax policy development in Australia and New Zealand has the hallmarks of consultation and input from various organizations outside of the government. Both countries operate as democracies, although Australia’s parliamentary system is more complex through the operation of both the Lower House and the Senate, and multiple layers of government that comes with a federal system. New Zealand has a unicameral House of Representatives, which facilitates the policy development process, notwithstanding operating under a Mixed Member Proportional system. In comparative terms, New Zealand’s tax policy process is more structured and transparent, highlighted by the Generic Tax Policy Process. Australia’s federal tax policy process operates with less cooperation between the Australian Treasury and the Australian Tax Office, compared to the New Zealand Treasury and Inland Revenue. In contrast, the Hong Kong Special Administrative Region (HKSAR) operates under the provisions of the Basic Law, with Articles 107 and 108 providing guidance with respect to tax policy development. This paper seeks to offer insights from Australia and New Zealand that could potentially inform the debate in the HKSAR over tax reform, especially with the HKSAR’s long term revenue planning, and recent proposals for more enhanced tax policy development.