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PIOJ Growth-Inducement Strategy - Planning Institute of Jamaica

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is too expensive and this reduces competitive pressures within the traditional banking<br />

system and between banking and capital market institutions.<br />

The GOJ’s medium-term economic policy framework also embodies a commitment to<br />

financial sector reform to reduce financial sector vulnerabilities and strengthen financial<br />

sector supervision. Within the securities markets, an important source <strong>of</strong> vulnerability is<br />

the lack <strong>of</strong> diversification in financial products <strong>of</strong>fered to investors and the need for<br />

securities dealers to realign their business models to reduce reliance on mainly short-term<br />

repurchase agreements (“repos”) to finance their inventories <strong>of</strong> medium to long term<br />

assets. The Financial Services Commission has signalled that the re-invigoration <strong>of</strong><br />

Collective Investment Schemes (CIS) is an important element for reducing systemic risks<br />

in the securities market. In particular, the FSC is introducing reforms aimed at<br />

strengthening the regulatory framework for CIS and importantly, allow for the<br />

establishment <strong>of</strong> a broader array on local CIS, including local mutual funds and hedge<br />

funds. 56 Current unit trusts are tax-advantaged compared with local mutual funds in a<br />

number <strong>of</strong> ways, including the fact that:<br />

<br />

<br />

investors in local mutual funds would be subject to ‘multiple” taxation <strong>of</strong> income,<br />

first on the investment income earned by mutual funds and then on redemption <strong>of</strong><br />

shares in the fund. Investment income earned by unit trust is exempt from income<br />

taxes<br />

the transfer <strong>of</strong> shares/ownership in unit trusts is not subject to transfer tax, while<br />

mutual fund shares would not currently enjoy similar treatment.<br />

Meaningful CIS reform cannot proceed without equalization <strong>of</strong> the tax treatment <strong>of</strong><br />

different types <strong>of</strong> CIS vehicles.<br />

In light <strong>of</strong> the above considerations, we recommend the following measures:<br />

4.0 Recommendations<br />

1. Remove the stamp duty on corporate debt securities (including demand<br />

promissory notes, bonds and debentures).<br />

2. Remove the transfer tax on the trading <strong>of</strong> debt securities, if indeed it is determined<br />

that the transfer tax is chargeable on these transactions.<br />

3. Harmonize the tax treatment <strong>of</strong> unit trusts vis-a-vis other collective investment<br />

schemes (mutual funds) and, in the context <strong>of</strong> this particular paper, we<br />

recommend exempting the transfer <strong>of</strong> mutual fund shares from the property<br />

transfer tax.<br />

56 The current mutual fund regulations allow for the establishment <strong>of</strong> local mutual funds. However, due to<br />

serious inconsistencies between the securities regulations and the Companies Act as well as the unequal tax<br />

treatment <strong>of</strong> mutual funds, it is economically unfeasible to establish and operate a local mutual fund.<br />

There are currently no local mutual in operation. CIS reform is also intended to address these structural<br />

impediments.<br />

153

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