A. Introduction
1. The United Party for National Development (UPND) believes in being a forward-looking party, keen to lend reliable and sound advice on socio-economic, political and law-related issues for inclusive and sustainable development in Zambia. We believe that every sitting Government, including ours after we form Government in 2021, should be open-minded, impressionable and keen to listen to its citizens in order to benefit from the ideas of the best and brightest minds in our society, irrespective of religion, sex, age, political affiliation, tribe or nationality.
2. We are therefore pleased to present our expectations of the 2020 National Budget. It is our hope that our carefully considered expectations will generate the necessary insights to interrogate and debate the National Budget, including at the level of the National Assembly.
3. We therefore, in this submission, articulate macroeconomic policy objectives and reforms as well as economic stability, expenditure, revenue (including tax and non-tax), fiscal deficit and public debt, private sector development and external sector measures that, if adopted and adhered to, would spur the economy to stability, sustained economic growth and inclusive development. We have taken an evidence-based point of view, learning from where Zambia has been in the recent past, where we are today and where we hope to be, particularly in 2030 according to the national long-term aspiration, the Vision 2030.
4. We would expect a theme for the Budget that captures the following tenets: “Rebuilding resilience, stability and growth for transformation and inclusive development”. This will ensure that the recent economic malaise and growing hardships are adequately addressed in the short- to medium-term for the betterment of the Zambian people.
5. The rest of this document is split into five sections. Section B, which ensues, looks at the economy from the global perspective narrowing down to our domestic environment.
B. The Economy
6. The international economy remains quite constrained due to emerging protectionist foreign policies in major global economic players, climate change effects and humanitarian challenges in some parts of the world. However, the world economy continues to grow at an estimated 3.5% in 2019 and a projected 3.6% in 2020. This means that despite the trade war between The United States and China, and United Kingdom BREXIT issue, there is positive growth. Other factors that may have an effect on world economic growth could also include instability in the middle east, which if sustained could have a negative effect on oil prices.
7. The African regional economy has remained quite the same over the past decade or so, with very little transformation. In Eastern and Southern Africa, COMESA, EAC and SADC came together to form the Tripartite Free Trade Area in 2015, establishing a building block for the African Continental Free Trade Area (AfCFTA), which came into force in 2019. This clearly demonstrated a good amount of political will for regional and continental integration in Africa. For Zambia, the pace and direction of integration also signifies growing market opportunities for both export promotion and sourcing of more affordable imports for alternative African markets. With economic growth expected to peak at 4% by end of year and 4.1% in 2020, it means that Africa remains a place of massive opportunities which Zambia must seize without delay. Rwanda grew at 8.6% and Ethiopia grew at 9.2% in 2018. There is no reason Zambia is not growing at a comparable rate.
8. Zambia’s domestic economy has continued to contract under the weight of excessive spending and a heavy debt burden. A debt burden which is as a result of excessive borrowing since 2012. Real GDP growth has fallen from around 7-8 percent in 2012 to 2 percent in 2019. Zambia, in 2019 spends 40% of its budget on debt servicing, a further 50.1% on civil service emoluments leaving 9.9% for social and productive sector spending. With this miniscule amount to spend on social and productive sectors, economic growth remains farfetched.
9. Most of Zambia’s economy is operating in an informal and rather disorderly fashion. The public sector has fallen into a vicious cycle of start-stop economic policy management, pronouncing and reversing decisions on almost a daily basis. This has caused widespread policy inconsistencies. The rationality of many of the policy decisions is also brought into question. In the private sector, most of the businesses (especially the small and medium scale enterprises) are informal. Meaning they are not paying taxes and their employees are outside the national social security system. Informality is particularly common in the agriculture sector. By failing to address the growing issues of informality, the Government is not only missing out on higher tax revenues that would come from broadened formalisation of the economy. The narrow tax base puts pressure on the Treasury. It is therefore prudent to ensure that Government moves fast on organized, orderly, systematic and comprehensive tax reforms that broaden the formal economy and formal tax base. This is the only way the Treasury will recover from this heavy debt burden and jump start the economy. The Government must thus start by looking inwards for suppliers of goods and services, to encourage formalisation and reduce pressure in the kwacha which will then reduce the exchange rate.
C. Macroeconomic Objectives
10. In 2019, the performance of the economy is less than impressive as can be seen in Table 1 below. But because of the deep damage to the economy and the continuing macroeconomic problems, it is important to be realistic about what can be done in terms of macroeconomic programming. Table 1 summarises the performance targets we would expect for growth recovery and positive impacts in ensuring fair wealth distribution and poverty reduction.
Table1: Macroeconomic outcomes in 2019 and expected targets for 2020
2019
GDP 2.0 percent
Inflation 9.9%
Jobs 62000
Domestic Revenue 19.2% of GDP
Expenditure 24.2% of GDP
Fiscal Deficit 4.8% of GDP
Forex Reserves 1.6 months of Import Cover
Domestic Credit to Private Sector 7.6%
2020
GDP At least 5.5%
Inflation 6-8%
Jobs 100,000 (69,000 rural and 31,000 urban)
Domestic Revenue 18.5% of GDP
Expenditure 21.5% of GDP
Fiscal Deficit 3.0% of GDP
Forex Reserves At least 4 months of import cover
Domestic Credit to the Private Sector at least 15 percent increase
D. Public Policy Measures and Reforms
11. We expect to see a significant shift in focus from poverty redistribution to reestablishment of the privates sector as the engine for economic growth and development. Enough of the jokes and unserious thinking that the Government can get into the business of creating new wealth in Zambia. We expect the Government to put the private sector back in the driver’s seat of doing business and withdraw itself from dominating the business arena. The Government should be a facilitator that focuses on fixing and enhancing the business climate through expanding credit to the private sector, spearheading business and competitiveness reforms, offering tax concessions to the private sector, re-organizing key services sectors, and harnessing the opportunities of regional integration. It is these things that will restore real robust growth. And in turn, it is growth above anything else that the economy needs for jobs, industrialization, more domestic revenue generation and a renewed resilience to deal with the excessive public debt. An ambitious growth path will not be easy to attain given the current damage to the economy, but now is not the time to be fainthearted and blame climate change for all our past mistakes. It is time to be bold in taking decisive transformative actions to ensure that the quantitative restrictions currently prevailing over the private sector are eliminated; 2020 is time for a bold Budget.
12. The excessive appetite for public expenditure must be arrested at all costs, especially for consumption and unnecessary capital items and large projects (e.g., fire tenders, national airline, Presidential jet, etc.), through legal means. We would expect a 2020 Budget which will return to rational priority setting. Excessive capital expenditure on urban road infrastructure must be stopped and capital expenditures must now be refocused to critical items like alternative electric energy installations. Essentially all projects that have not moved to commitment control must be suspended until economic stability and real GDP growth beyond 5.5% is attained. Wasteful expenditure on very low-priority items such as fire tenders, national airline, Presidential jet and so on must be stopped completely. In the interest of decency and a show of empathy with the hardships experienced by the Zambian people, the Presidential Jet must be sold and its proceeds used in poverty reduction programmes such as women and youth empowerment programmes, which have not received any funding in 2018 and 2019.
13. The excessive fiscal deficit, excessive public debt stock and very large debt service burden must be stopped through a well-formulated and transparent debt management plan. Despite all the warnings from local experts and international organizations such as the IMF and World Bank, the Government has continued its heavy borrowing since 2012 to fulfil the excessive expenditure needs of past campaign promises. Even when the problems of the growing debt have become manifest, the PF Government has continued borrowing to the extent that in 2019, the fiscal deficit is expected to be more than 9 percent on a commitment basis and the debt stock is expected to increase to higher levels of unsustainability of 92 percent of GDP. Because of these things, already in 2019, the debt service burden increased so that the country had to spend 27 percent more on debt interest payments than the Government had planned in the 2019 budget. The debt interest payments alone were taking up 34% of domestically financed expenditure. The poor debt management record of the PF Government is costing the country dearly. We expect a believable debt management plan that puts in place emergency legal safeguards that will force discipline on the Government and prevent further borrowing. The debt management plan must also be transparent and clearly show the levels of accumulated/cleared VAT refund claims and arrears relating to FISP, FRA, subsidies on electricity and fuel, public investment projects (including wasteful ones like the Presidential Jet), and pension arrears, economic empowerment and so on.
14. We expect legal reforms for debt management. In particular we expect that the Government will, with urgency, update the law on debt contracting (Loans and Guarantees Act) in line with the Constitution. The Republican Constitution clearly states in Article 114 (1)(d) that “The National Assembly shall oversee the performance of Executive functions by… (d) approving public debt before it is contracted” and yet the Loans and Guarantees Act is evasive on this point, causing a contradiction with the supreme Law. This lacuna must be fixed in this session of parliament in order to restrain the Executive from further excessive borrowing.
15. We observe with much disappointment that the Government is just not sensitive to the growing suffering of citizens, insisting instead on honouring irrational political pronouncements made around 2011/2012. In particular, the creation of 44 new districts from an initial base of 72 in 2012 has meant supporting a total of 116 districts with administrative infrastructure and human resources. The creation of new districts has become a huge drain on the National Budget. It is time to hold the creation of new districts. Administrative infrastructure development must be suspended in all new districts where less than 90 percent of the total required infrastructure has been installed. What we would further expect is that the Government quickly implements the Decentralisation Policy in its entirety to relieve pressure off the central Government as far as revenue collection and policy implementation is concerned.
16. The wage bill must be contained. The top-heavy structure of public sector organizations, particularly Ministries, Province and Government Agencies must be rationalized. The multiplicity of Ministries and Government Agencies with duplicated mandates and functions must be resolved through an organized reform, which will cushion the impact on the wage bill. Immediately, we expect the Government to reduce the number of ministries. We propose a maximum of 18 Cabinet Ministers (and an equal number of ministries) from the current 38. We also propose a reduction in the number of Permanent Secretaries to one across all ministries except the Ministry of Finance, which should have two Permanent Secretaries. We also propose that the President delegates his constitutional prerogative of appointing Permanent Secretaries and Statutory Body Board members to the public service commission and his Cabinet Ministers. Such restructuring will help to increase the efficiency of the the public sector as civil servants will be hired on merit. The fiscal space created from the restructuring should then be redirected to supporting frontline workers in education, health, water and sanitation and other key sectors like Agriculture as well as to revamping the social protection and poverty reduction programmes, which have been neglected into complete collapse.
17. A far-reaching public sector reform is long overdue. The wastefulness in the public sector, blotted size of cabinet with many redundancies, poor human resource management particularly travel management, unaddressed and thus demotivating allegations of corruption and other illicit and unfavourable practices and so on, all require a deep-rooted public sector reform to resolve. The mind-sets of professionals have been tainted by the combination of economic hardships and overreaching political influences, nepotism, tribalism, cadreism and other vices in the civil service, which have made working life and professional conduct all but impossible. We expect to see immediate reforms of the civil service to make it professional. There are low hanging fruits that can immediately be moved onto electronic platforms with a view to making the civil service efficient and save the Government money. Mantras such as “doing more with less” simply won’t help if the mind-sets of our civil service remain constrained due to the lack of a structured programme of public sector reform.
18. The 2020 Budget will need a specific programme for removing the inefficiencies of public investment. In 2017, Zambia’s public investment experienced estimated efficiency losses of 45 percent compared to an average of 36 percent for SSA countries. The main areas where the losses emanate include the lack of vetting of projects, lack of systematic appraisals of domestically-financed projects before their inclusion in the budget, and weak procurement processes that undermined efficiency and created opportunities for corruption (we all recall the fire tender scandal and numerous others after it). We expect the Government to establish and implement a credible public investment management system for coordinating and undertaking prior appraisal of all new public investment projects; and to back this up with a specific legal framework. We also expect the Government to urgently enact the long overdue Planning and Budgeting legislation, which has been in the pipeline since 2014, and to revisit the Loans and Guarantees Act as alluded to above.
19. As already alluded to, Government should initiate comprehensive and systematic tax reforms that both broaden the tax base and reduce the tax burden on Zambian families and business. The escalation of tax and non-tax deductions through high income and other tax, skills levies, the National Health Insurance scheme, borehole levies, road tolls, fuel levies and many others has gotten out of hand. Moreover, the new Employment Code has dramatically increased the cost burden on employers. These issues have increased production costs and caused negative impacts on livelihoods. These issues cannot be addressed through ill-conceived piecemeal solutions such as the proposed re-introduction of Sales Tax, which should be avoided. It is high time the private sector and citizens got tax breaks and concessions as a matter of public policy. A listening and empathetic Government should be willing to reduce taxes (and the overall revenue to GDP ratio) and similarly reduce expenditure in order to create latitude for the private sector to increase participation in the economy and to grow. The overbearing tax policies and the inconsistences we are proposing must be addressed immediately as part of economic stabilisation, growth and recovery.
20. Let us move both away from sole dependency on copper for exports and further up the copper value chain. Let us do this as soon as possible, through a revival of the diversification agenda. We expect reforming the business environment to encourage investments in Agriculture, Services, Manufacturing and Tourism. Let us make Zambia the destination of choice for regional offices, meaning that we need to have reliable, affordable and good communications networks, transport and logistics services, electricity and financial services, among others. This we must do in practical terms and not pronouncements in empty speeches.
21. Import substitution is a good way of stimulating job creation, industrialization and productivity in the manufacturing sector. We need to ensure that whatever can be manufactured in Zambia is NEVER imported because importing is equivalent to forfeiting jobs and industrial development. This is emphasising the formalisation we highlighted above, less imports will reduce pressure on the kwacha thus reducing the exchange rates in major convertible currencies. This will reduce exchange rate induced inflation.
22. If we are going to promote and achieve manufacturing-led import substitution industrialization and also build our agriculture, tourism and other services, there is an urgent need to ensure that we have reliable electric energy through key investments in broadening the energy production and consumption mixes. The World Bank and other international agencies started warning Zambia over ten years ago to recapitalize our electricity subsector and pay particular attention to diversifying the energy mix. The Government did not listen and instead insisted on installing more large-scale hydroelectric power plants. But these hydropower stations have become increasingly ineffective as we keep experiencing drought.
23. From the multiplicity of reports about corruption, financial misappropriation, tax evasion, rent seeking and other illicit practices by the Auditor General’s Office, Financial Intelligence Centre (FIC) and other public agencies, it is high time the PF Government admitted that corruption in Zambia has become endemic. We expect the Government to use the 2020 Budget as a key instrument to address the growing corruption problem in Zambia. The PF Government cannot hide behind climate change on its appalling track-record of corruption and other social vices. In 2020, we expect to see decisive actions not rhetorical words in the fight against corruption. We expect to see well-resource public investigative and law enforcement agencies that are also legally highly insulated from undue influences. We expect the PF Government to stop the vilification of professional investigative wings that do their job well in exposing illicit practices in line with their mandate. A clear demonstration of commitment to fighting corruption would be if the President delegated to an appropriate Peer Review body (made up of members from the Executive, Judiciary and Legislature) his Constitutional prerogative to appoint the Board members of all investigative agencies, the Inspector General of the Zambia Police and the Commissioner General of the Zambia Revenue Authority (ZRA).
24. A recent report says that for every US$ that Zambia borrows, 63 cents of it ends up on corruption and corrupt activities. This is why our argument has always been that Zambia’s problem is not that of resources, but leadership that can manage resources in a prudent manner.
E. Proposed Tax Measures
Direct Taxes
Personal Tax
25. Pay As You Earn (PAYE), being the largest contributor to the national treasury must be broadened due to the large informal economy. How can we broaden the tax base, the proposal is to encourage businesses to formalise. We have a huge infrastructure programme going on, let us, in addition to the ZDA Act which provides for preference to Zambian owned companies, strengthen what foreign companies can and cannot do. For instance running a quarry, that indeed needs specialised equipment but as long as we do contract discrimination we can capture the informal economy and slowly bring them into the main economy from where we can benefit from PAYE. In this case we propose the following bands:-
Income Band (Month) Proposed Tax Threshold
< 4000 0% 4,001 – 5,000 10% 5,00 – 7,000 15% 7,001 – 10,000 20% 10,000 > 22.5%
26. We proposed these reductions so that the economy can be reignited through demand due to increased disposable income. When informality is addressed, and the whole stock of employees gets on the revenue collection platform, over two million employees will be contributing to PAYE in one way or another, this will address the anticipated losses due to these donward PAYE adjustments.
Corporate and Business Tax
27. We have stated before that it is time the Zambians got more from the mines. This was our and your campaign promise. We are equally aware that the mines are not against paying tax, but all they want is a fair tax. We have reduced the debate on mines exclusively to them paying higher royalties instead of promoting more investment so that new jobs are created. This new investment can only happen if there if policy consistency. Right now, investments are being withheld because the mines are not sure whether it is VAT or GST or some hybrid of some sort. These inconsistencies, for an investment that could take as long as 15 years for it to be profitable, are counterproductive.
28. The revenue tax threshold for VAT purposes, can remain as it is at ZMW800,000 for SMEs, but we hope once the manufacturing and other sectors have been stimulated this can be adjusted downwards so that the VAT is captured. With the introduction of an online system by ZRA, we think this will no longer be a burden administratively.
Indirect Taxes
VAT
29. The VAT should be adjusted downwards to 14%. This is not only in line with the regional average but will provide relief to families that have been afflicted by increased basic commodity prices following the removal of subsidies and manufacturers who should remain competitive for export purposes. Import VAT should be zero rated for goods that will be used for manufacturing as well as capital goods such as machinery. The proposal is that the Ministry of Commerce, Trade and Industry, the Department of Industry put in place a strict mechanism to ensure that goods imported, are for manufacturing either goods for export or local consumption are really meant for that purpose to avoid tax evasion. The lost revenues will come in form of VAT charged on sales by the manufacturing companies as well as corporate tax.
Customs and Excise Duty
30. We propose progressive formalisation of the cross border trade. This is another source of revenue where Government does not fully realise the full potential especially that most of the cross border trade is informal.
Capital Equipment and Energy
31. Customs and excise duties must still be waived on engines, cranes, conveyor belts and an assortment of other productive goods. However, since we are going to prop up manufacturing, it should be limited to that equipment that cannot be locally sourced and manufactured.
32. In this category we also propose that the Minister considers equipment aimed at providing health care and education. All this equipment must be zero rated in as far customs and excise duty is concerned. Health equipment includes wheel chairs and other equipment used to aid the differently abled people.
33. Since we have energy deficit, equipment used for production of energy at low and high scale must be zero rated. What we have observed is that, whereas the wind turbine that produces the electricity is zero rated, the pole that holds the wind turbine will not be zero rated, we seek the Government to harmonise this or at best have it locally manufactured.
34. Zambia imports a lot of good some of which can be manufactured locally. The general rule however should be that whatever can be manufactured in Zambia but is currently being imported, should be taxed, we have in mind things like pneumatic tyres, especially second-hand tyres. Second hand tyres might be causing road traffic accidents that must be addressed by encouraging motorists to use brand new tyres. As such we propose a minimal tax on used tyres and encourage tyre manufacturers to come and set up plants in Zambia. This approach to taxation, where you give waivers on second hand items is what led to collapse of the textile industry.
F. Conclusion
35. We can all agree that the Zambian economy is currently doing very badly and it is weakening by the day. The current downward trajectory, with declining GDP growth and growing economic hardships, will continue if the measures we have highlighted above are not harkened to and implemented. The country is moving towards an election in 2021; there is a tendency for politicians to make populist statements that have potential to alter adversely the course of policy. We appeal to the PF to be sober and address the economic challenges they created with sobriety. Now is not the time to hide behind climate change as the excuse for past mistakes and failures. Now it the time for the PF Government to be morally upright for once and accept its incompetence and poor economic management record. The Government must take up the responsibility of fixing the economy, starting with the 2020 Budget.
36. There is no shortage of intellect and ideas in the UPND camp so we will continue offering advice to the Government, hoping that the Government will listen in the interest of ensuring that this economy starts to function again. Our advice is for the sake of the Zambian citizens. As the UPND, we also invest a lot in offering free evidence-based advice because we are not keen to inherit an economy in intensive care. However, should we be forced to inherit such an economy come 2021, we are more than equal to the task of restoring the economy to its former glory and take it to even higher heights than ever before; mark our words because these words are a promise to the Zambian people.
