Requirement to provide a statement about short-term charge facilities

Submissions

(BusinessNZ, Deloitte, Simpson Grierson, Corporate Taxpayers Group, New Zealand Institute of Chartered Accountants, Westpac, KPMG)

Employers should not be required to provide a statement to employees – this requirement would create an excessive amount of paperwork that would serve little to no purpose and would impose significant compliance costs on employers. (BusinessNZ, Deloitte, Simpson Grierson)

The requirement to provide this statement should be limited to employers in the charitable sector. (Corporate Taxpayers Group, BusinessNZ, New Zealand Institute of Chartered Accountants)

We do not believe that employers would typically enter salary trade-off arrangements involving short-term charge facilities outside of the charitable sector. (BusinessNZ)

The requirement to provide a statement should be limited to employers that provide vouchers as salary substitutes. (Westpac)

This requirement will impose significant compliance costs on employers who will need to track every single voucher provided during the year. This will not be practical. There should be a minimum amount, under which statements do not need to be provided. This could be $100 per voucher. (KPMG)

Employers should only need to provide a statement to employees who receive a significant amount of remuneration through short-term charge facilities. This amount could be $1,200, or the lesser of $1,200 or 5 percent of income. (Corporate Taxpayers Group, Deloitte, New Zealand Institute of Chartered Accountants)

The $300 per quarter FBT threshold should apply to the requirement to disclose information on short-term charge facilities. (Wilson Parking)

Comment

Clause 67B proposes that all employers who have provided short-term charge facilities, such as vouchers, will be required to provide a statement to each employee who received the short-term charge facility setting out the total value of facilities they received during the income year. The reason for this requirement is to assist employees in calculating their income for social assistance purposes.

Employees are unlikely to keep a record of all short-term charge facilities they receive from their employer. When an employee receives short-term charge facilities from multiple employers, it will be difficult for them to calculate their income for social assistance purposes if they do not have information about the benefits they received during the year from all their employers. The amount a person receives from each employer may be below the threshold, but when combined may exceed the threshold for including this amount in their social assistance calculations.

Officials accept that this disclosure requirement would increase compliance costs for businesses which provide benefits to employees by way of short-term charge facilities. Officials also accept that many businesses which provide these types of benefits to employees do not provide substantial sums under these short-term charge facilities. Accordingly, on balance, officials recommend the removal of this requirement from the bill. Businesses which provide short-term charge facility benefits could still provide information about these benefits to employees if employees request this information. However, this is contingent on their keeping sufficiently detailed records.

Recommendation

That the submissions to remove from the bill the requirement for an employer statement be accepted.