Michel Habib

[Kurzfassung: Angesichts der Covid-19-Pandemie bietet der Bundesrat Unternehmen Zugang zu garantierten Krediten. Diese verschaffen den Unternehmen Liquidität zur Deckung der trotz Krise weiterlaufenden Kosten. Angesichts der oft engen Margen kleinerer Unternehmen kann aber eine zusätzliche Verschuldung längerfristig in den Bankrott führen. Eine prüfenswerte Alternative wäre daher eine Staatshilfe in Form von Beiträgen, die nicht direkt zurückbezahlt werden müssen, sondern via die im Steuersystem angelegte Risikoteilung zwischen Staat und Unternehmen an den Staat zurückfliessen. Ein solches „Geschenk“ an eine Unternehmung in einem Verlustjahr führt zu höheren künftigen Gewinnen. Im idealtypischen Beispiel fahren Staat und Unternehmung gleich gut wie bei einer Kreditgewährung, jedoch ohne Konkursrisiko für die Unternehmung (Urs Birchler)]

A few days ago, in order to help businesses deal with the collapse in demand most businesses have experienced in the wake of the Covid-19 pandemic, the Federal Council announced that it would be guaranteeing bank loans made to Swiss businesses. Guaranteed loans can be no larger than 10% of annual turnover; loans of up to CHF 500,000 are guaranteed in their entirety, loans between CHF 500,000 and 20 million, the maximum loan amount possible, are guaranteed at a rate of 85%, the lending bank being responsible for the remaining 15%. The interest rate on the smaller loans, those up to CHF 500,000, is 0%; that on the larger loans is 0.5%.
There is not the least doubt that these loans have been a very welcome lifeline to Swiss businesses: demand for the guaranteed loans has been extremely high, reflecting the urgent need for liquidity of businesses that have been required to close in order to help stem the spread of the virus yet still need to meet their fixed charges—interest, rent, essential maintenance—even where employee wages can be covered by unemployment insurance and variable costs have declined to near zero in line with the collapse in demand.
Yet, there is a danger to relying on debt financing to meet the challenges posed by the current situation. The character of the small farmer who lost his family farm because of his inability to repay loans contracted in difficult circumstances is a familiar one in world fiction, because the reality of such farmers has alas been all too common across the world. While this is still the case in many countries today, it is by and large no longer so in Switzerland, thanks to farm support policies. The plight of yesterday’s small farmer may instead become that of today’s small business owner: many small businesses operate on very thin margins; even a closure of a few months may make these businesses unable to pay back their loans, thereby driving them into bankruptcy.
There is an alternative to loans, one which nonetheless differs from the grants eschewed by the Federal Council. This alternative exploits the risk-sharing nature of the tax system, which makes the government a partner of the firm in sharing profit, that is, in reaping revenue and in bearing cost. The government’s share equals the corporate tax rate.
Adopting the risk-sharing perspective has many advantages. It makes it clear that the government will be bearing part of the cost of the crisis, through reduced tax revenues. This observation suggests that government help to firms may in fact be not so much a grant as an advance: the government may pay its share of costs immediately, thereby providing much needed help to the firm, rather than paying its share when the firm returns to profit, through the reduced tax that results from the firm’s ability to carry its loss forward (the example below will make that reasoning concrete). If that share of costs borne by the government, which we recall equals the tax rate, is deemed too small to help firms survive, then the advance can be increased, to be offset by decreased cost deductibility in future years.
The simple example below may help. It proceeds in three steps. The first step illustrates the manner in which the tax system has the government bear part of the cost of the crisis, even if there should be no grant or guarantee whatsoever. An important limitation of the current system is that the government will bear its share of costs after rather than during the crisis. The second step shows how a tax system that treats profit and loss symmetrically can serve to make the government bear its share of costs during the crisis, thereby providing much needed relief to firms faced with the Herculean task of financing fixed costs out of little to no revenues. The third step shows how a desire to increase the share of costs borne by the government whilst still eschewing grants can be accommodated by limiting expense deductibility after the crisis.
Consider a firm that, in normal times, has revenues 300 and fixed costs 200. The firm is assumed to have no other costs: this assumption is in line with our focus on fixed costs; it also simplifies our analysis. The corporate tax rate is 20%. In a normal year, then, the firm has taxable income 300-200=100 and pays tax 100×20%=20.
The assumption that the firm in the example is a corporation does not detract from the generality of the reasoning below, which applies to corporations, partnerships, and sole proprietorships alike: owners’ personal tax rates replace corporate tax rates in the case of flow through entities such as partnerships and sole proprietorships.
Step 1: The present tax system
Suppose a given year, denoted year 1, sees a collapse in revenues to zero. The firm still has fixed costs 200, so it makes a loss of that same amount. It pays no taxes, but is able to carry its 200 loss forward.
Assume the situation reverts to normal in year 2. Despite the fact that the firm’s revenues in year 2, back at 300, are higher than the firm’s costs in that year, still 200, the firm does not owe any income tax because it can utilize 100 of its net operating loss (NOL) carryforward to offset its pre-NOL taxable income. The tax savings from NOL utilization are 20. They constitute part of the government’s share of the fixed costs incurred in year 1, the year revenues collapsed.
Year 3 is also a normal year. In that year as in year 2, the firm can take advantage of the loss carry forward to decrease its taxable income to zero, thereby paying no tax. The tax savings from NOL utilization are again 20. The sum of the 20 in year 2 and 20 in year 3 is 40, which is exactly the government’s share of the costs incurred in year 1: 200×20%=40.
There is no loss carry forward balance to be utilized in year 4; the firm pays tax again.
Step 2: A symmetric tax system
Note the asymmetry in the tax system’s treatment of profit and loss in step 1: the firm must pay tax when it is profitable, but it can only carry its loss forward to future years when it is loss making. In contrast, a symmetric tax system would have the government pay the firm in a loss-making year, the counterpart to the firm paying the government in a profitable year. In the context of our example above, the government would pay 20% of the loss to the firm in year 1 already, that is, 200×20%=40. The firm naturally would have no loss carryforward to years 2 and 3, as it otherwise would be double counting its year 1 loss. The firm will then be paying 20 in tax again already in year 2.
Further note that the decrease in government tax revenue is identical under symmetric and asymmetric tax: it is 40 in both cases. The difference is merely timing: the firm receives the 40 already in year 1 under the symmetric tax system, exactly at the time when it most urgently needs the money. That money is not a grant, it is an advance: the government will in any case have to forego 40 in taxes, but it does so at the time of greatest firm need for cash under the symmetric system. The money is not debt, either, at least not debt in its usual form: there is no repayment as such, and the resumption of tax payments naturally must wait for the return to profitability. In our example above, suppose for example revenues were to recover only to 200 in year 2, and that full recovery to 300 were to be delayed to year 3. Then the firm would just break even in year 2, it would pay no taxes, and it would carry its 200 loss from year 1 forward to years 3 and 4, which would now play the role of years 2 and 3 in our original example. This illustrates the risk-sharing nature of the tax system.
Step 3: From twenty to eighty percent
The reimbursement of 20% of fixed costs might be deemed insufficient to allow firms to weather the storm from the crisis. Suppose for example that it were desired to help firms cover 80% of fixed costs, the same percentage as the income replacement rate of unemployment insurance. Again, the use of the tax system can help achieve the desired result. Thinking in terms of risk sharing and of symmetry can help us devise an appropriate mechanism.
Return to the example above. An advance of 80% of fixed costs has the government pay 4 times its share of costs, 20%x4=80%, amounting to 200×80%=160. Having overpaid its share of costs in year 1, the government should be dispensed from paying its share of costs in the early years of recovery, specifically three years since the government would have paid three times more than its share of costs in the year of crisis, 160-40=120=3×40. This means that, if recovery to normal conditions were to occur in year 2, then the firm would have taxable income 300 in years 2 to 4, as the firm would now be bearing the entirety of the costs as opposed to sharing them with the government through the tax system. Tax would be 300×20%=60 per year, 40 more than the 20 that the firm would have paid had there been no additional advance from 20% to 80%. The additional tax revenues of 40 per year over the three years 2, 3 and 4 add up to the 120 additional advance made by the government in year 1.
Reality is of course far messier than our simple example: revenues and costs are not constant, even in normal times; some firms may try to manipulate the system, for example by substituting variable for fixed costs; last but not least, firms may go bankrupt. Yet, it is possible to address these issues whilst preserving the basic nature of the mechanism we have presented: the government makes an advance which constitutes a contribution to fixed costs; the government recovers that advance through the tax system by limiting firms’ ability to deduct costs in the computation of taxable income; bankruptcy by a firm jeopardizes recovery by the government, but the risk-sharing nature of the mechanism makes bankruptcy less likely than in the case of government-guaranteed loans. The mechanism bears much similarity to the student loans in countries such as Australia and the United Kingdom referred to by Bonardi, Brülhart, Danthine, Jondeau and Rohner (Batz.ch) in their analysis of desirable responses to the crisis, not least with regards to risk sharing, but the perspective we have adopted helps guide us in devising appropriate ways of recovering the advances made, though limited cost deductibility.

Michel Habib, University of Zurich, SFI and CEPR
The author would like to thank Urs Birchler and Alexandre Ziegler for helpful discussions, suggestions and comments. He is solely responsible for all errors.