Part six of a six-part series on GST
Health and education are priority areas for the government and are often exempted from tax in public interest. However, under Goods and Services Tax (GST), granting an exemption to health and education sectors could lead to a greater tax burden, than when including them. Moreover, in the Indian context, the incidence of tax under the exemption system would be regressive.
Let us take the case of health services, which could be provided by the government or non-profit sector at a lower, subsidised cost or by the private sector at comparatively higher prices. There would also be cases where health care costs are covered by insurance. Assume that the subsidised health services are available at Rs 50 and private services for Rs 200. Assume non-labour input costs, such as equipment, medicines, supplies, building maintenance, sanitation and administrative overheads, are Rs 80 for both public and private health centres.
If health services are within the tax net, the tax on services provided by public and private sectors would be Rs 6 and Rs 24, respectively, assuming a GST rate of 12 per cent. The health centres would also incur GST of Rs 9.60 on their inputs, but this tax would be fully recoverable/creditable as long as their revenues are fully taxable.
If the health services were to be exempted, there would be no tax on their revenues, and no credit would be allowed for the tax charged on their inputs. This blocked input tax would be embedded in the cost of the services provided. Thus, the exemption would lead to an increase in tax to Rs 9.60 from Rs 6 for public health services, and a decrease in tax to Rs 9.6 from Rs 24 for the private services, a regressive outcome, given the dependence of lower income families on public health care. An exemption under GST replaces the tax on outputs/revenues by the tax on inputs of the supplier. Where the outputs are subsidised, the tax on inputs could be far greater than the tax on outputs.
Now, consider the case where health care facilities are covered by insurance, for which an insurance premium of Rs 112 is charged, inclusive of GST of Rs 12. With insurance, GST on health services (Rs 6 or Rs 24 in our example) would not be a burden on the consumer, since the expenditure would be borne by the insurance company and could be claimed as input credit against the tax charged on the insurance premium. If health services are exempted, then Rs 9.60 of input tax would become a net additional burden on the health sector, with neither the insurer nor the health service provider eligible to claim a credit for it.
The above considerations would apply to education services as well, barring the insurance element. Administratively, exemption (or a lower tax rate) for health and education services would generate definitional issues and classification complexities, given the diverse nature of the services offered. For instance, health care could include medicines, hospital facilities, nursing care, diagnostic tests, therapeutic treatment, physiotherapy, yoga and physical fitness, to name only a few. Even within these, there would be different alternatives for treatment such as ayurveda, homeopathy, naturopathy and so on. Similarly, education facilities could range from child care to school and higher education, diploma courses, private tuitions and coaching, professional education and even imparting recreational education or training such as dance and drama.
Thus, both on grounds of public interest and administrative simplicity, services such as health and education should be kept within the ambit of GST.
The author is Partner, Ernst & Young. Views expressed are personal.