Greening the tax system

How tax policy could support net-zero

March 2021
Tax and Regulation
2 Tax and Regulation: Greening the tax system
 Tax and Regulation: Greening the tax system 3

Contents
Chapters

1. ‘Greening’ the tax system – why now? 4

2. Tax policy fit for net-zero: guiding principles 6

3. Short-term actions: net-zero quick wins 12

4. Long-term vision: more certainty and  18

a holistic approach needed

References
24

About the CBI 26

4 Tax and Regulation: Greening the tax system

‘Greening’ the tax system -

why now

With the commitment to a net-zero emissions target by 2050, the hosting of

the COP26 climate conference later this year, and a commitment to ‘build
back better’ after the Covid-19 crisis, the government faces a challenge to
clarify how policy will get the UK on track to reach net-zero.

Business plays a crucial role in meeting the net-zero objectives and a significant
number are already setting themselves highly ambitious climate targets, which
in many cases are decades ahead of those set by the government. Yet it should
not be underestimated that the transition to net-zero will require business to incur
significant new costs as they invest in new low-carbon technologies and services.
The Climate Change Committee (CCC) in 2019 put the annual investment cost at
£50 billion between 2030 and 2050 to achieve the net-zero target1, with most of the
investment being delivered by the private sector.

In the current tough economic climate, it is crucial that business is provided with the
right policy framework to support the delivery of net-zero. The scale of the climate
challenge and delivery of the government’s plans for a green industrial revolution
call for innovative ways to use the tax system, along with regulatory signals, to
scale up market opportunities in a carrot and stick fashion. All this must be done
consistently with targeting opportunities for green growth in the UK. The build-up to
COP26 and beyond offers a crucial moment for business and government to come
together and get these plans in place. This is a once in a generation platform to
boost climate progressive industries, associated skills, and innovation to show the
UK can lead the world in the technologies of the future and accelerate our response
to climate change2.
 Tax and Regulation: Greening the tax system 5

Devising suitable regulatory frameworks will be key given the pressures on

public finances. But fiscal measures, including environmental taxes and tax
incentives, will also be an important lever in driving change. They can work
to discourage damaging environmental behaviours (e.g., emissions taxation);
incentivise investment in both the acquisition of, and research and development
into environmentally friendly products (e.g., Vehicle Excise Duty, Research &
Development (R&D) tax credit) and energy efficiency (e.g., capital allowances and
reduced VAT rates).

This paper sets out some guiding principles which the CBI believes the government
should consider to shape environmental tax policies for business over the coming
decades. It then recommends a number of short-term actions government can take
over the course of this Parliament to accelerate the business progress towards net-
zero and some long-term priorities to support the government’s 2050 strategy.

All parts of the economy need to transition to net-zero, and the tax system will
play an important role in making this happen. This paper focuses on some of the
largest emitting sectors: transport, buildings, the power generation, and industrial
emissions, but the government should continue to shape tax and fiscal policy that
supports decarbonisation in all sectors of the economy.
6 Tax and Regulation: Greening the tax system

Tax policy fit for net-zero:

guiding principles

‘Greening’ the tax system must go beyond simply looking at different environmental
taxes, i.e., transport, pollution, and energy taxes, independently. It is crucial that the
tax and regulatory systems are considered holistically and how each element drives
the delivery of net-zero. In assessing how the UK tax system could be harnessed to
improve its effectiveness in working towards net-zero, set out below are a number of
guiding principles to be used in tax policy design and when reviewing the existing
policies. These principles are:

• Polluter pays

• Certainty

• International co-operation

• Carrot and stick

• Greenhouse gas hierarchy

• Green technologies

• Transparency

• Circular economy

• Just transition

The above principles are explained below.

1. Polluter pays

Tax is a useful instrument to assist with the internalisation of externalities, i.e.,

the incorporation of the costs of environmental services and damages (and their
repairs) into the prices of goods, services or activities which cause them. This
directly contributes to the implementation of the ‘polluter pays’ principle and to the
integration of economic and environmental policies.

In simple terms, green taxes should be targeted to a pollutant or a polluting behaviour

(with clear definitions being provided as to what constitutes the pollution or polluting
behaviour). They should be designed to introduce a price signal into the supply chain
to promote alternative, less environmentally damaging behaviour by making alternative
options more economically viable. The tax system should seek to penalise the polluting
activities – both production and consumption – while using effective reliefs and
subsidies to encourage activities that support the transition to a net-zero economy.
 Tax and Regulation: Greening the tax system 7

Furthermore, if there are viable low-carbon alternatives available, there is a case

that taxes should be higher for the most polluting products and services as
these are the priority to remove from the circulation. As green taxes will in many
cases increase the price of environmentally damaging goods and services, this
should translate into impacts on demand as well as supply and shift consumers
towards greener alternatives. For example, large retailers have been required by
law to charge for single-use plastic bags since 2015. The seven largest retailers in
England issued around 86% (6.6 billion) fewer single-use plastic bags in the year
April 2017 to April 2018 (1.0 billion) than they did in 2014 (7.6 billion). Though not
a tax, with retailers instead expected but not required to donate proceeds to good
causes, this policy measure has had a clear impact on consumer behaviour across
the UK.

However, in implementing the ‘polluter pays’ principle it is crucial that the tax
mechanisms are targeted at those points in the value chain where they will
influence the decision makers who have the ability to make investment decisions
which will result in lower carbon emissions. For example, tax breaks for zero
emission vehicles work because consumers have the option to buy them. In
contrast, tax breaks for hydrogen fuel cell trucks may not be as effective in the
short-term because hydrogen is not currently routinely available. In this case tax
incentives would be more appropriate further up the value chain with potential
hydrogen producers. Given these sector and technology-specific implications, it
is vital that decisions on the use of tax measures are based on the latest data and
evidence to ensure that desired impacts are being delivered.

2. Certainty

The CBI report ‘Goal 13 Impact Platform: emerging findings’ found that the most
frequently cited external barrier which is stopping or slowing down business to
progress their climate objectives is an uncertain policy and regulatory environment.
To address this, the government must provide long-term certainty to underpin
the investment decisions by consumers and businesses. Long-term certainty
of taxation allows businesses to commit to long term investment if budgets
underpinning this strategy have a reduced risk of surprise costs. For example, for
manufacturers it takes time to ramp up their production, so they need certainty
that there will be a strong UK market at the point when their products are released
into the market. For tax policy, any tax incentives must be broad and available for
the whole duration of the project life cycle. Like regulation, tax charges and tax
incentives need to have a long term outlook that accounts for product life-cycles
and technology developments.
8 Tax and Regulation: Greening the tax system

Planning for any tax incentives should also take into consideration the current
proposals by the OECD around the Tax Challenges Arising from Digitalisation, Pillar
2. Based on these proposals, tax incentives can lead to a lower effective tax rates for
corporates. The tax consequently would need to be topped up in the country of the
ultimate parent (IIR). This is an important consideration when designing any green
tax incentives, as there is a risk that they may be rendered ineffective.

3. International co-operation

Climate change is a global threat that will irreversibly affect all regions of
the world. However, the reality is that taken collectively, current nationally
determined contributions are not enough to avert the looming effects of climate
change3. Fragmented domestic policies will not achieve a sound transition towards
a global resource-efficient, net-zero carbon and circular economy. Businesses
involved in multiple markets, such as global value chains, cannot afford to
be exposed to widely differing tax and regulatory systems. Strengthening
international co-operation across environmental policies, including green taxation,
is therefore necessary.

In the run up to COP26, the CBI urges government to not only accelerate progress
towards its own net-zero objectives but also fully utilise its leadership role in
imploring other countries to bring forward their plans to cut emissions and set
net-zero targets. For example, collaboration on carbon pricing, such as through
linking emissions trading systems (and their tax treatment) and shared approaches
to carbon pricing should be sought (both in terms of the base to be taxed and the
rate of taxation). More international co-operation is also urgently required across
sectors such as aviation, shipping, and finance.

For business, it is crucial that UK environmental tax policies are co-ordinated

or at the very least considered in the international context to avoid excessive
administrative burdens, unintended consequences, and damaging effects on
the UK’s competitiveness. For example, co-operation with the EU is important
to ensure the most efficient use of existing and future regional decarbonising
infrastructure. An unbalanced environmental tax policy risks production moving out
of the UK or overseas manufacturers having a competitive advantage.
 Tax and Regulation: Greening the tax system 9

4. Carrot and stick approach

In line with the ‘polluter pays’ principle above, the government should tax a
‘bad’ such as pollution but also reward a ‘good’ such as a reduction in pollution.
However, it is important to consider how these measures interact: if you tax a
‘bad’ too much, it potentially constrains the ability to do the ‘good’. The use of
carrots and sticks by the government should be balanced to encourage action
from consumers and businesses. For consumers, the focus should initially be on
incentives, given the need to grow demand during the post-pandemic recovery
period, with sticks more useful in the future. The judgement about when to apply
taxes to business should also recognise the need to accelerate investment in
the recovery period, but need not wait as long as for consumers, as arguably
businesses are better equipped to plan ahead.

The overall carrot and stick approach should be set out in a clear roadmap of how
these taxes will develop over time to provide business and consumers with certainty
and enable them to adapt. This should be achieved by developing and publishing
a strategic tax roadmap for the UK’s post-pandemic tax system with the net-zero
objectives placed at the core of the tax strategy.

5. Greenhouse gas hierarchy

The government’s policy frameworks, including taxation, must focus on incentivising

carbon reduction ahead of carbon offsetting. Offsetting allows business and
consumers to continue with a carbon producing behaviour in a way that will
potentially slow a step change in a sustainable reduction of the carbon emissions.
It is important that the rules for offsetting are clear and robust and the price signals
for carbon credits are set over the longer term.

Energy and carbon reduction tax policies should focus on the elimination of
carbon emissions and be designed with a greenhouse gas (GHG) management
hierarchy approach, developed by the Institute for Environmental Management and
Assessment (IEMA)4, in mind. The tax policies should encourage business to take
the following action in respect of GHG emissions:

Eliminate (by using green design, recycled materials, regenerating existing stock,
• 
e.g., retrofitting rather than demolishing and re-building in construction).

Reduce (through innovation/investments in efficiencies, e.g., reviewing energy

• 
usage, water consumption, waste production, reducing business travel etc.).

Substitute (moving from fossil fuels to renewables).

• 

Compensate (purchasing appropriate number of carbon credits, carbon capture

• 
and storage solutions, self-created forestry offsets etc.).
10 Tax and Regulation: Greening the tax system

6. Investment in green technologies

The investment levels required to reach net-zero means that taxation must be
used as a tool alongside the right policy and regulatory frameworks to support
investment and innovation in a range of low-carbon technologies. The 2020s and
2030s need to deliver significant scale-up and deployment of technologies like
carbon capture, electrification of transport and heating, hydrogen production and
its use across a range of sectors. Tax incentives need to support the investment into
deliverable green R&D.

Furthermore, as the UK accounts for less than 1% of annual global emissions5,

significant progress needs to be made internationally. The UK should play an
important role in helping other nations reduce their emissions in line with the
Paris Agreement. This leadership should be based on a strong investment in green
technologies, which in turn creates business opportunities for the UK to export
clean technology (‘cleantech’), skills, services, and products. Supported by the UK’s
leading role in the development of green and sustainable finance, shaping new
trade agreements and facilitations post-Brexit, and diplomatic leadership at events
like the G7 and COP26 the UK can help accelerate progress at home and abroad.

7. Transparency

Complete transparency around environmental taxes is needed. Business is

concerned that there has been a shift from green taxation that is tackling
climate change to it becoming just another revenue raising mechanism. Effective
environmental taxes should be designed to raise less revenue over time, i.e., if the
green taxes are designed with proper principles in mind, the ideal outcome is that
they raise nothing. Environmental taxation should promote the transition to net-zero
and as a transitional tax, its main objective should not be as a revenue raiser.

It is important that any tax system changes are carefully considered against the
government’s net-zero objectives. The policy objectives should be transparent and
clear; any proposals for new environmental taxes should follow an established
policy making process with stakeholders properly consulted in a timely and
transparent way. In addition, common approaches should be taken (e.g., with
Financial Reporting Council and other Environmental, Social, and Governance
transparency reforms) to ensure consumers have relevant information to enable
them to make appropriate and consistent decisions (e.g., common indices).

Like transparency, good communication is essential for a successful environmental

tax policy. Well-communicated tax policy choices that look at long-run benefits in
terms of people’s well-being, environmental protection, and resilience to climate
and future shocks can increase public acceptance6. This applies similarly to green
tax policies designed for business.
 Tax and Regulation: Greening the tax system 11

8. Circular economy

As set out in a World Economic Forum report7, over the past 200 years, economic
and population growth migrated from previous circular practices for a move
towards the current take-make-waste model, with 45% of emissions coming from
how we make and use products and how we produce food.

It is important that when designing its environmental policies, the government

considers the carbon produced over the lifecycle of a product – from extraction,
through to manufacturing, use and then disposal (recycling). The aim is to reduce
any built-in obsolescence in how some products are made. It is crucial that the
government uses tax as a policy lever to support a transition to a circular economy,
which in turn will help achieve the UK’s net-zero objectives. The tax and regulatory
environment must incentivise products that can be used for longer, especially
where carbon inputs at the manufacturing stage/recycling are relatively high. Most
importantly, the government’s policies should encourage for the products to be
repaired rather than replaced.

9. Just transition

The just transition must feature strongly in the government’s climate strategies,
including tax policy. The principle is rapidly gaining momentum in businesses’ net-
zero strategies. For example, energy companies across Europe are signing up to a
just transition pledge and investors too are starting to integrate the just transition
into their climate activities. Development finance institutions such as the European
Bank for Reconstruction and Development and CDC are also coming forward with
new initiatives.

It is important that tax policies are designed in a way that the costs of the
net-zero transition do not fall unfairly on those least able to pay for them. This is
vital not only for fairness but also to maintain public acceptance of the actions
needed to achieve net-zero. Financing this investment will be a key challenge in
achieving net-zero.
12 Tax and Regulation: Greening the tax system

Short-term actions: net-zero

quick wins

As a priority, the government should focus on three key areas that the CBI
believes would have the most significant impact on acceleration towards
the decarbonised economy: transport, buildings and industry.

1. Encourage a quicker uptake of zero emission vehicles

Transport continues to be the UK’s largest carbon emitting sector. The emissions
from passenger cars and light goods vehicles make up over two thirds of all
transport emissions, so decarbonising those forms of transport is a priority. Whilst
the government has expressed high ambition levels for phasing out diesel and
petrol vehicles from 2030, this must be matched with support for consumers and
business to adopt new vehicle technologies and for the delivery of infrastructure
needed to make them viable alternatives. Below are some tax policy solutions that
could help achieve a faster transition towards zero emission vehicles.

• Company car tax (BiK):

The 0% company car tax (BiK) rate for zero emission vehicles rises to 1% from April
2021 (BiK rate was down to 0% for 2020-21).

As stated above, one of the key principles the government must follow in
developing tax policies is a long-term certainty of taxation. Although it is
disappointing to see that the 0% BiK rate was not extended in Budget 2021, to
lengthen the application of 1% company car tax (BiK) rate for zero emission vehicles
could increase car fleets’ changes as businesses gradually recover from Covid-19
and begin to make investment decisions again. This policy should be extended to
cover employee loans for such vehicles. Furthermore, given the long-term nature of
vehicle purchasing decisions, providing clarity on long term BiK rates would help
with zero emission vehicles’ uptake.
 Tax and Regulation: Greening the tax system 13

• Capital allowances:

Business welcomes the government’s announcement in Budget 2021 that a 130%

super-deduction tax incentives for two years will be introduced. However, more targeted,
‘green’ investment-focused capital allowances mechanisms for both incorporated and
unincorporated businesses should also be maximised to drive the right behaviour. For
businesses purchasing zero emission vehicles, or indeed making any ‘green’ capital
investment, these capital allowances should be increased to 120% of the investment’s
value. The policy should also be extended to the zero emission vehicles leasing and
rental sectors.

• Vehicle Excise Duty (VED):

Business welcomes the government’s call for evidence on VED, supporting the
need for it to be reformed to aid the transmission to low emission road transport.
However, simply increasing first year VED rates is not an effective response to
solving the challenge of changing behaviours and purchasing decisions. Further
consideration should be given on how costs can be spread over multiple years and
the lifetime of vehicles.
14 Tax and Regulation: Greening the tax system

• VAT:

VAT applies to the price of vehicles, their fuels and electricity. The government
should conduct a review of the applicable VAT rates in respect of zero emission
vehicles-related transactions with a view to bringing more consistency and
simplification. The government should prioritise the following areas:

– Bring more consistency around the VAT treatment of electricity charging

at home (reduced rate) vs. public (standard rate) electric vehicles charging
points. Bringing the public charging VAT rates down to 5% to match domestic
charging would support those without access to domestic charging.

– 
Reduce the VAT rate applicable to the sale of zero emission vehicles. There
currently is no difference between buying an electric, hybrid or traditional
fuel car when it comes to VAT. The government should particularly look to
target sales at the cheaper end of the market, where price parity is moving
more slowly (e.g., a small city electric car remains much more expensive
than traditional fuel equivalents). The VAT incentive could be introduced
alongside the current plug-in grant (PICG), or after the PICG comes to
an end in 2023 to support delivery of the 2030 and 2035 target dates for
ending the sales of new internal combustion engine cars and vans.

– 
Review the VAT rate on Personal Contract Hire (PCH) for zero emission
vehicles. As an increasing number of zero emission vehicles are leased or
acquired by PCH (which currently attract VAT on the monthly payments),
reviewing this presents an important impact opportunity to encourage the
uptake of the zero emission vehicles.

– 
Allow VAT recovery on company cars that are battery electric vehicles (BEVs)
where they are in private use.
 Tax and Regulation: Greening the tax system 15

2. Support more energy efficiency, low carbon heat and use of renewables in buildings

Direct GHG emissions from buildings (mainly as a result of burning fossil fuels
for heating) were around 17% of the UK total in 2019. Including indirect emissions
(emissions from electricity use), buildings accounted for 23% of the UK total8. There
is clearly a way to go to make residential, public, and commercial buildings more
energy efficient and encourage switching to low-carbon heating. The government
needs to ensure the tax system enables and not hinders these ambitions.

• Business rates9:

The tax environment determines many business decisions and, while the
government can use certain taxes to incentivise positive business behaviours,
such as encouraging investment in certain areas important for societal and
environmental benefits, taxes can also be used to disincentivise negative
behaviours. In some cases, taxes unintentionally create barriers and stifle what
would otherwise be welcome activity. An example of this is business rates.

Business rates are often cited as a barrier to investment in non-domestic property

improvements, such as investments aimed at increasing the energy efficiency of
the property and reducing its carbon footprint. This is because a business rates
bill is based on the rental value of a property, which increases as improvements
are made. In addition, the calculation of a business rates bill also includes certain
plant and machinery (P&M) items, so installing any of these items also comes with
an associated business rates cost. The high burden of business rates (a tax rate of
close to 50%) often means that the costs associated with improving the property
outweigh the benefits and can make the investment commercially unviable. Green
technologies such as solar panels are included in the business rates calculation,
which can be the tipping point of that investment not going ahead. This means
that too often these investments do not take place, which is out of kilter with the
government’s net-zero ambitions.

While reforming business rates is not the silver bullet, it has an important role to
play in ensuring business rates are no longer a barrier to investment in property.
Encouraging commercial property investments through a minimum 12-month
exemption on any business rates increase associated with property improvements
will help businesses to make viable investment cases, while regularly reviewing
P&M regulations will ensure the system keeps pace with the need to modernise
as new technologies are developed. Extending the original exemption for property
improvements that result in an improvement in the building’s Energy Performance
Certificate (EPC) and exempting certain green P&M will incentivise businesses to
make those green investments that reduce the carbon footprint of their buildings,
helping to deliver sustainable economic growth and prosperity – including through
increasing productivity.
16 Tax and Regulation: Greening the tax system

• Capital allowances:

Existing systems in buildings are responsible for a significant element of GHG

emissions. Businesses should be incentivised to upgrade their energy, waste
management and pollution prevention systems. For example, if heat pumps are
to be retrofitted to buildings that are currently using natural gas, higher capital
allowances rates could be used to incentivise upgrading such systems. To qualify
for the higher rates, the upgrade could be linked to the improvements in the EPC
rating bands, for example, to A or B, or to any other measure of environmental
performance that was considered appropriate.

Further, as of April 2020 the 100% First Year Allowance for energy saving products,
the list of which was highly restrictive, was ended. This 100% allowance should be
reinstated (and in line with the point made on vehicles above, potentially increased
to 120%), with the qualifying criteria made much broader and principles-based, to
encourage investment in a much wider range of beneficial technologies.

• Structures and buildings allowance (SBA):

Introducing a variable rate structure for SBAs could be used to incentivise a

sustainable construction, renovation or conversion of buildings and structures. The
government should also ensure that, where possible, SBAs are incentivising the
retrofitting of existing buildings rather than demolition.

• VAT on energy saving materials:

The government has set a challenging target of reaching 600,000 heat pump
installations per year by 202810. A reform of the reduced rate VAT provisions for
energy saving materials, including heat pumps, could help with incentivising the
adoption of such materials.

Under the current rules it can be extremely difficult for the reduced rate to apply
at all because measures are frequently implemented as part of a single supply of
a heating system or do not conform with the very narrow list of allowed materials.
The government should expand the permitted list and allow concrete and specific
aspects of supplies to be carved out to allow the reduced rate to be applied to
energy saving materials.

Furthermore, to facilitate the development of more sustainable and circular

economy compatible products, goods produced using secondary materials, i.e.
where the VAT has already been paid once, should be exempt from further VAT.
This would promote the use of secondary materials and help address the situations
where it is often less expensive to use virgin materials than recycled ones.
 Tax and Regulation: Greening the tax system 17

3. Motivate companies to innovate in industrial emissions reduction

Another sector critical for supporting the net-zero transition is the industrial sector.
The sector has improved its emissions through a shift to lower-carbon fuels and
improvements in energy intensity. However, deeper emissions cuts are required. The
CCC has identified this as a key sector for government to supports11.

The government needs to deliver credible policy frameworks to encourage and

enable economically viable further emissions reduction across this sector, whilst
mitigating the risk of carbon leakage. In the immediate term, the forthcoming BEIS
Industrial Decarbonisation Strategy must enable further emissions reduction across
heavy-emission sectors, and a supportive tax policy environment needs to align to
this strategy.

Innovation and the deployment of new technologies, such as fuel switching, more
efficient industrial processes, and carbon capture and storage are at the core of
enabling deeper emissions cuts by the industrial sector. The government must put
in place policy rules that encourage businesses to make net-zero investments and
support cost reduction in new technologies. The cost of these, instead of eventually
being passed onto a consumer, could reduce the additional cost to consumers
longer-term (for example, in packaging, any innovative solutions could result in
businesses not being subject to a new plastic packaging tax and thus not needing
to pass it on to end consumers).

Tax could play a crucial role in stimulating this innovation which in turn would result
in reduced costs of alternative processes and products relative to carbon-intensive
ones. The government should make it absolutely clear that R&D tax credit applies
to innovative, sustainable, cleantech solutions. Expenses incurred in relation to the
piloting and development of installations, e.g., in respect of the development of
hydrogen power, carbon storage, clean heat etc., should qualify for the tax credit.

Furthermore, helping firms to research and develop, fund, and grow cleantech
supports delivery of the government’s 2050 commitment while strengthening the
UK’s economic recovery. With UK cleantech companies having attracted 73% more
venture capital investment in 2019 than in 2018, almost doubling China’s 37%
rate of investment growth12, it also provides an opportunity for the UK to become a
world-leading destination for the development of cleantech.
18 Tax and Regulation: Greening the tax system

Long-term vision: more certainty

and a holistic approach needed

To harness tax as an effective policy lever in helping the UK achieve net-zero,

business needs certainty in the long-term direction of travel, in particular
around transport and emissions taxation. Most importantly a long-term tax
policy framework is needed with the net-zero target at its core.

1. Review fuel duty

With the government’s announcement to end the sale of new petrol and diesel
vehicles by 2030, the need for a comprehensive review into fuel duty has never
been greater. It is crucial that this transition is supported by a progressive tax
system based on real world data to incentivise low emission driving, and more
importantly, encourage the purchase of the right vehicles for the right journeys.
The pandemic has highlighted the important role cars continue to play for mobility
across the country and in particular those localities where access to wider travel
options is limited. To meet emission reduction targets every effort must be taken
to ensure each mile driven is a low emission one. Long-term fiscal policy can help
incentivise this behavioural change.

To help achieve this, a complete review into the future of fuel duty must be
conducted. As acknowledged by the Chancellor in the March 2020 Budget, the
act of freezing fuel duty for the last 9 years has come at a cost to the taxpayer of
£110 billion, and he noted both this fiscal impact as well as the environmental cost
of this approach13. As a starting point, following the findings of the HM Treasury’s
‘Net Zero Review’ due in spring 2021, the government should commit to launching a
review into fuel duty in 2021. This should include providing clear signals of what will
replace the current system over the medium-long term to support decarbonisation
across transport modes - linking to the aims of the forthcoming Decarbonisation
of Transport Plan, and how fuel duty will be applied to petrol and diesel vehicles,
particularly where alternatives are less developed.
 Tax and Regulation: Greening the tax system 19

2. Provide certainty on the future of UK’s emissions taxation

Business welcomes the introduction of the UK’s Emissions Trading Scheme (UK
ETS), however long-term certainty is needed on the approach to carbon taxation in
the UK.

• UK ETS:

With the UK ETS having replaced the UK’s participation in the EU ETS, as set out in
the government’s ‘Energy White Paper’14, creating a new UK carbon market will be
the foundation on which the UK achieves net-zero emissions cost-effectively. With
the new UK ETS still in its early days, it is important that the government monitors
the effectiveness of the regime, whilst working with stakeholders on a long-term
plan to align the cap on the GHGs that businesses can emit with an appropriate
net-zero trajectory.

Commencing the auctions of UK ETS should be prioritised to reduce the risk of

unnecessary volatility and cost in the carbon and power markets, and ensuring
an adequate supply of allowances. In the interests of greater liquidity and cost
effectiveness, business also supports making progress towards linking with the
EU’s ETS, building on the commitments made in the UK-EU Free Trade Agreement
on exploring this possibility.

Furthermore, with the government’s plans to expand the UK ETS to two thirds
of uncovered emissions, and future tightening of the UK ETS cap to ensure
consistency with the CCC’s ‘The Sixth Carbon Budget’ and path to net-zero, it is
crucial that business is given enough warning to prepare and make plans for the
future. The tax treatment of the UK ETS needs to be set out as soon as possible.
The tax treatment of offsetting mechanisms for both providers and purchasers
also needs to be clarified so that potential projects have a clear framework for
investment decisions. Having early visibility of the trajectory of carbon pricing in
the UK will allow businesses to plan and make long term investments in emission
reduction projects with confidence. It is vital that any long-term plan is honoured, or
it would have the opposite effect, undermining investor willingness to commit.

Also, as the UK embeds its own ETS, progress should be made towards linkage
with the EU ETS. As this develops, consistency of UK Carbon Price Support signals,
such as the confirmation of CPS rates for 2022/23 in Budget 2021, can provide
certainty for business as the UK shapes a long-term approach to carbon pricing
that is forward thinking and supports sector pathways to net-zero.
20 Tax and Regulation: Greening the tax system

Finally, as the government develops its Industrial Decarbonisation Strategy, long-

term considerations are needed on the future of carbon pricing in this sector. It is
important to consider whether there is a more coherent and comprehensive way
of enabling industry to decarbonise (similar to the energy sector), where there is
a lesser need for compensation via free allocation. Such an outcome may not be
possible in the short-medium term but may be able to be considered into the next
few decades. Importantly, it would only be possible if there were cost-effective
alternative processes and technologies available, and if markets are created for
low-carbon industrial products to allow firms to pass-through costs to consumers
in a way that avoids a loss of competitiveness.

• Carbon Border Adjustment Mechanism:

The reality is that countries are pursuing climate change objectives at a different
pace and it is important that, when designing environmental tax policies, the UK
government is mindful of the potential risks of carbon leakage – i.e., emissions
increasing in foreign jurisdictions because of offshoring of activity driven by over-
stringent domestic climate policies. Carbon border adjustments, which can take
many different forms, are one option among others aimed at minimising carbon
leakage. The EU is currently working on their carbon border adjustment mechanism.

The EU proposals for a carbon border adjustment mechanism tackle the problem
of risk of carbon leakage and international competitiveness in a different way
from the EU ETS. Instead of relieving high emitting industries, charges and levies
would be applied and a carbon price of some form (tax or other) would be applied
at the border to level up the carbon charges borne by imported goods. Carbon
pricing is an international issue and, if the EU adopts a carbon border adjustment
mechanism, there could be significant distortion of trade if the UK did not follow
suit, e.g., diversion of cheap goods into the UK from low carbon price territories
undermining the competitiveness of UK business.

The UK government will need to consider the potential impacts if the EU adopts
a carbon border adjustment mechanism and any measures required to address
those impacts. While many businesses acknowledge the benefits of carbon
border adjustments in principle, the detail and implementation will be critical for
ensuring these operate as intended to support investment in low-carbon products
and processes.
 Tax and Regulation: Greening the tax system 21

• Transition to sustainable aviation:

According to the EU Aviation Safety Agency, the use of sustainable aviation fuel is
currently minimal and is likely to remain limited in the short-term. However, there is
a clear growth opportunity, and the UK has the industrial skills and capabilities to
lead this developing sector.

The government’s ‘10 Point Plan for a Green Industrial Revolution’15 was a positive
step forwards in developing a market for sustainable aviation fuels, but business
needs further targeted support for innovation (e.g., grants and loan guarantees),
a long-term revenue support mechanism to enable growth in the market, and
further support that develops a Sustainable Aviation Fuel clearing house. Given
the international nature of the aviation industry, the government should work with
its global counterparts through the Carbon Offsetting and Reduction Scheme for
International Aviation (CORSIA) to focus on supporting the ambitions the sector has
on sustainable fuels (renewable fuels, green gas etc.), hydrogen, and electrification.
22 Tax and Regulation: Greening the tax system

4. Set out holistic tax policy vision to achieve net-zero

It is crucial that the government determines the framework of both regulation and
tax in this Parliament to signal to all actors how net-zero is to be achieved and its
impact on them.

A growing number of firms are setting their own net-zero targets, which frequently are
well ahead of those set by the governments. For example, more than 1,000 businesses
worldwide are working with the Science Based Targets initiative (SBTi) to reduce their
emissions in line with climate science. Long-term regulatory and tax policy certainty
is crucial to facilitate the achievements of these science-based targets.

Clarity on the taxation and regulatory models that the government intends to
deploy will be key to establishing certainty and confidence within the private sector.
Climate change policy frameworks must not be at the whim of short-term political
change - they need to support long-term confidence for investment and effective
action. The Institute for Government sets out that the most sensitive area for the
Treasury is tax policy, which needs to support and not undermine progress to net-
zero16. The government needs to ensure that spending, tax, and regulation are all
consistent with the net-zero goal. Its tax strategy must support the move to net-
zero, showing taxpayers how and when taxes might change, and addressing such
important issues as the substantial loss of revenue from fuel duty as the vehicle
fleet is electrified. The roadmap should also reflect how increased remote working
will affect the environment and environmental taxes (e.g., less public transport use,
more energy consumption at home, reduced use of offices etc.).

The government should therefore publish a tax policy roadmap which places
achieving net-zero by 2050 at its core. The roadmap should set out consistent
and long-term environmental tax policy goals and a holistic vision of how tax
contributes to support net-zero objectives. The roadmap should also be supported
by a ‘net-zero test’ for all spending decisions from the Treasury and other
government departments.
Tax and Regulation: Greening the tax system 23
24 Tax and Regulation: Greening the tax system

References

1. Sixth Carbon Budget – Methodology Report, CCC, 2020.

2. For more detail see Principles for a low-carbon, sustainable and net-zero aligned
economic recovery post COVID-19, CBI, June 2020.
3. Climate Policy Leadership in an Interconnected World. What Role for Border Carbon
Adjustments?, OECD, January 2021.
4. Pathways to Net Zero. Using the IEMA GHG Management Hierarchy, IEMA,
November 2020.
5. Low Carbon and Renewable Energy Economy (LCREE) Survey direct and indirect
estimates of employment, UK, 2014 to 2018, ONS, 2020.
6. Green budgeting and tax policy tools to support a green recovery, OECD, October 2020.
7. Circular Trailblazers: Scale-Ups Leading the Way Towards a More Circular Economy,
World Economic Forum report, January 2021.
8. The Sixth Carbon Budget. Buildings, CCC, December 2020.
9. For more detail see Over-rated. Making the case for business rates reform, CBI,
September 2020.
10. The Ten Point Plan for a Green Industrial Revolution, HM Government, November 2020.
11. The Sixth Carbon Budget, CCC, December 2020.
12. UK Tech for a changing world, Tech Nation report, 2020.
13. Budget Speech 2020, HM Treasury, March 2020.
14. Energy White Paper. Powering our Net Zero Future, HM Government, December 2020.
15. The Ten Point Plan for a Green Industrial Revolution, HM Government, November 2020.
16. Net zero How government can meet its climate change target, The Institute for
Government, September 2020.
Tax and Regulation: Greening the tax system 25
26 People and Skills: Green light for investment

About the CBI

Founded by Royal Charter in 1965, the CBI is a non-profit business organisation

that speaks on behalf of 190,000 UK businesses of all sizes and from across all
sectors, employing nearly 7 million people between them. That’s about one third of
the private workforce. This number is made up of both direct members and our trade
association members. We do this because we are a confederation and both classes
of membership are equally important to us.
The CBI’s mission is to promote the conditions in which businesses of all sizes and
sectors in the UK can compete and prosper for the benefit of all. With offices around
the UK (including in Scotland, Wales and Northern Ireland) and representation in
Brussels, Washington, Beijing and Delhi, the CBI communicates the British business
voice around the world.

Our mandate comes from our members who have a direct say in
what we do and how we do it
The CBI receives its formal mandate from 9 Regional Councils, 3 National Councils
from Scotland, Wales and Northern Ireland plus 16 sector based Standing
Committees. These bodies are made up of members in that region, nation or sector
who serve a term of office. The chair of each Standing Committee and Regional and
National Council sit on the CBI’s Chairs’ Committee which is ultimately responsible
for setting and steering CBI policy positions.
Each quarter this formal engagement process across the CBI Council reaches over
1,000 senior business leaders across 700 of our members who have a direct say in
what the CBI do and how they do it, from refreshing their workplan to discussing
the key business issues of the day and re-calibrating its influence. Over 80% of
the businesses represented on the CBI Council are outside of the FTSE350 as the
CBI represents a wide range of sizes and sectors from the UK business community.
This formal governance process is supported by a wide range of working groups,
roundtables, member meeting and events that makes the CBI unparalleled at
listening to and representing British business.
 People and Skills: Greenlight for investment 27

CBI Council in numbers

1000+
Committee and Council representatives

28+
Regional and National Council and sector based
Standing Committees

50%
Representatives of the CBI Council at C-Suite level

80%
Of the CBI Council from non-FTSE 350 businesses
 March 2021
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Product code: 12647

To share your views on this topic or ask us a question, contact:

Milda Jardine
Principal Tax Policy Adviser, CBI
[email protected]

cbi.org.uk