Mr. Eddie Downey:

I thank the Chairman and Members of the Oireachtas for giving the IFA the opportunity to make this presentation. The announcement by the Minister for Finance, Deputy Noonan, of a comprehensive review of farm taxation in last October’s budget presents an opportunity, for the first time in a generation, for all stakeholders to step back and assess how well or otherwise the tax system is working to support the farming sector in Ireland today. While fully integrated into the general taxation system, the structure and operating environment of farming remains unique to any other business sector. In developing its submission, the IFA emphasised that a comprehensive review of the taxation system for farming requires an understanding of the market environment facing Irish agriculture and the key characteristics of that sector. The key objectives for the IFA in the independent review of taxation are to ensure valuable tax reliefs, which are critical to the development and growth of the agrisector, are maintained; to secure new tax incentives that are necessary to drive structural improvements by incentivising land transfer, mobility and investment, to examine how the taxation system can better accommodate the extreme volatility in farm incomes and to examine how tax returns can be simplified to drive down compliance costs.

Farming is continuing to contribute to the economic recovery that now is clearly evident, through continued growth in agrifood exports and employment. Agrifood exports reached a record high of almost €10 billion in 2013 and the value of our exports has increased by a further 11% in the first four months of this year. However, despite the contribution of the farming sector to national economic recovery, continued low levels of farm income, coupled with increasing income volatility, provide a threat to the viability of the Irish family farm and the sector’s growth prospects. Against this backdrop, the burden of taxation on farm families has, in common with other sectors, increased significantly in recent years. Marginal rates of tax are now at a very high level, which is removing resources required for investment in the farm enterprise. Increases in the rates of capital taxes and reductions in tax-free thresholds have added to the costs of investment and asset transfer.

Key characteristics which differentiate agriculture from other business sectors and which are critical in developing an appropriate taxation system are that farming is a capital-intensive industry with significant, recurring, investment requirements. Moreover, with a high level of owner-occupancy of farms, the minimisation of costs to facilitate lifetime intergenerational transfer is critical. In addition, the main business structure of family farms continues to be that of sole trader, with the result that farm incomes are subject to high tax rates, even at low profit levels and increasing exposure to international markets and competition is driving necessary structural reform, increasing scale and improved efficiency.

IFA's submission focused on the existing main tax reliefs relevant to farming, and whether they could be adapted to work more effectively, whilst also proposing a number of new measures to address particular issues.

IFA proposes two new and innovative taxation measures that, if implemented, would tackle two of the major challenges facing agriculture. These are the growing income volatility and the barriers to lifetime farm transfers.

We can clearly see the impact of volatility in the tillage sector, for example, which, in 2013, experienced a fall in incomes of 20% to less than €30,000 due to price collapse, and despite increased yields. Prices in this sector continue to fall through 2014.

The first of two proposals to manage income volatility and encourage lifetime transfer is an income-smoothing mechanism that would operate within the income tax system, in addition to income averaging. This would allow a farmer place on deposit a portion of his or her pre-tax income, in a designated commercial farming account - tax deposit account. This could then be drawn down by the farmer and used for the running of his business when required, and would be taxable in the year it was drawn down.

The second proposal is a phased transfer partnership, PTP. This is a progression model in which there would a defined, phased transfer of the family farm over a set time period. It would require an agreed transfer contract where both parent and child would work together in partnership over the period of the phased and progressive transfer of assets. As an incentive to the farm holder to enter into the contract, he or she would receive tax relief on a portion of their farm income, up to an agreed ceiling.

In addition to these incentive measures, IFA has submitted a comprehensive set of proposals covering all aspects of farming business. In respect of income tax, the IFA has proposed the introduction of an optional system of increased capital allowances which would provide capital allowances of up to 50% for the first two years; extending the 100% trained farmers' stock relief to all farmers for a period of four years, up to 2020; the extension of income averaging to farm profits where the farmer or spouse has an additional source of self-employed income; and the introduction of an earned income tax credit to remove the discrimination in the income tax system between employees and the self-employed.

In the areas of farm transfer, succession and mobility, the IFA has proposed the retention and index-linking of the capital acquisitions tax tax-free exemption thresholds, and retention of 90% agricultural relief; improvement in the uptake of the land leasing tax exemption scheme through recognition of incorporated farm businesses as qualifying lessees, and removal of the 40 year age limit for qualifying lessors; reintroduction of indexation for capital gains tax, CGT, and retention of CGT retirement relief; and retention of young trained farmers stamp duty exemption and consanguinity reliefs for transfers between family members - it should be noted that consanguinity relief is due to be cease from 31 December 2014.

To encourage greater numbers of farm partnerships, there must be an extension of existing tax reliefs for milk production partnerships to all registered farm partnerships and reintroduction of CGT relief in the event of a farm partnership dissolution.

IFA has identified a number of sector-specific issues that require changes in the taxation system, and other general taxation issues of relevance to farm enterprises. These include compulsory purchase of supply licences - co-operative shares - must be treated as a qualifying business expenditure, and offset against income tax; introduction of a tax-relieved loan scheme open to farmers and non-farmers who wish to invest in the development of the dairy sector; exclusion of forestry-felling income from the high income earners restriction; retention of the existing pay-and-file deadline for self-assessed tax returns; and extension of a simplified system of farm income assessment for farmers with a non-complex farming system.

I wish to conclude with some comments on budget 2015, to which the outcomes of the agri-taxation review will be closely linked. On the expenditure side, funding for farm schemes underpins farm incomes and output. Under the new rural development programme, RDP, there is an overall allocation of €2.1 billion of EU funding and €1.9 billion of national funding for the period 2014-2020.

I wish to take this opportunity to acknowledge the Government's funding commitment earlier this year to the rural development programme for the next six years. Over €500 million of funding for RDP farm schemes must be provided in October's budget. This funding will deliver programmes of support for low-income farmers, the provision of environmental services, encourage young farmers, promote on-farm investment and support farming in marginal areas.

IFA's priorities for expenditure in October's budget are: commencement of contracts for the new green low-carbon agri-environment, GLAS, scheme in early 2015, with places for 30,000 farmers in the scheme in its first year and payments disbursed in 2015; allocation of €30 million for the targeted agricultural modernisation scheme, TAMS, in 2015 to fund on-farm investment programmes across all sectors; funding of €52 million for the beef data and genomic scheme to support the vulnerable suckler sector; and increased capital funding allocations for the horticulture, forestry and aquaculture sectors to achieve output targets and employment growth.

Farming is facing significant challenges at present, but the opportunities for continued growth are many. The achievement of Food Harvest 2020 growth targets will result in a significant return to the Exchequer through an increased tax take from additional economic activity, earnings and employment at farm, processing and industry services level. As an immediate priority, full funding of farm schemes that provide income support for vulnerable sectors and investment support across all sectors is critical in Budget 2015. On the taxation side, the agri-taxation review must result in a set of proposals supporting the long-term growth of the sector. These must be implemented, starting with this October's budget.