The Government backdown on GST reform is another example of how short-term politics will nearly always trump good longer-term policy

The Government backdown on GST reform is another example of how short-term politics will nearly always trump good longer-term policy

  • A new tax bill causes a massive storm but what happens next?
  • Also a brief run-through of what other tax measures are in the Taxation (Annual Rates for 2022-23, Platform Economy and Remedial Matters) Bill. (TL:DR – a lot!)


Tax ultimately is politics. And that was very clearly demonstrated this week when the Government introduced and then withdrew within 24 hours its proposals to apply GST on management services supplied to managed funds as part of the Taxation (Annual Rates for 2022–23, Platform Economy, and Remedial Matters) Bill.

On the face of it this was a provision to address a technical issue which had developed over time where fund managers were applying different treatments to how they determined what proportion of the fees they provided were taxable supplies subject to GST and what portion represented GST exempt financial services.

The proposal determined by Inland Revenue was to standardise the approach and apply GST service and fees. This would have taken effect from the 1st of April 2026. We’re therefore talking about a measure three years in the future, but which would have netted an estimated $225 million a year in GST. That in itself probably wouldn’t have caused many issues except the Regulatory Impact Statement which accompanies the Bill, included modelling by the Financial Markets Authority which on the assumption that the increase in GST would be fully passed on to KiwiSaver fund members, KiwiSaver balances would be reduced by an estimated $103 billion by 2070.

And then the fun kicked off. There clearly was quite a bit of misunderstanding about this measure with some people thinking the Government would be charging GST on KiwiSaver balances. The Government was taken completely by surprise and the furore was such that it decided to abandon the proposal within 24 hours of announcing it, which is some form of record. It certainly made for an entertaining 24 hours in tax. You can hear more about what happened in this week’s edition of the Spinoff’s podcast When the Facts Change where Bernard Hickey and I discuss the background to the proposal and how it fits into the history of tax reform since 1984.

But it should be noted that the particular issue of an inconsistency of approach by fund managers still remains. So, what’s going to happen now? Probably Inland Revenue will have to negotiate with fund managers and come to some form of agreement over what proportion of fees it deems to be acceptable to be treated as taxable supplies.  This was what happened back in 2001, but that agreement has long expired. Such an agreement is going to take some time, although maybe negotiations already started. We’ll have to wait and see how that pans out.

Ironically the GST on fund management proposal was a relatively minor part of the Bill, although it would have had the biggest single tax effect. The rest of the Bill, as its name implies, covers a whole range of matters, including the gig economy, more GST issues, cross-border workers, fringe benefit, and the bright-line test to name a few.

Addressing the Platform Economy

A number of reporting and other tax issues have arisen around economic activity facilitated by digital platforms. That is where an app connects buyers and sellers and includes accommodation services such as Airbnb and transportation services, such as the ride sharing apps, Uber and Zoomy and Ola together with other professional services provided through digital platforms.

The Bill intends to ensure Inland Revenue has better access to information about income earned by sellers using digital platforms based in New Zealand or offshore. These provisions build on proposals developed through consultation by the OECD. Inland Revenue will get greater information and it will also share that information with foreign tax authorities where it relates to non-residents.

The Bill also wants to maintain the sustainability of the GST system. Digital platforms will be required to collect GST on services provided through them in New Zealand. This will be done by extending the rules that currently apply to imported digital services and low value imported goods. These will now apply to accommodation, ride sharing and food and beverage delivery services all currently provided through digital platforms.

There is a proposed flat rate credit scheme intended to reduce the compliance costs for those accommodation hosts and drivers who are not required to register for GST because the value of the services they provide over 12 months is less than $60,000. The GST changes will come into effect from 1st April 2024 and the net impact is expected to be around $37 million per annum.

These changes reflect the growing impact of the digital economy and the moves by tax authorities to ensure they know what’s going on and close potential gaps in loss of revenue may be arising because some of this may be happening under the table. It also reinforces something we see a lot of already and which we’ll see more of, and that is information sharing with other jurisdictions as appropriate.

We’re still working through the impact of COVID-19. And one of the areas where I’ve seen quite a bit of interesting work develop is in relation to cross-border workers. In the wake of the pandemic, we’ve seen a lot of people return to New Zealand from overseas. In many cases these returnees continue to carry on working remotely for their previous employer. This pattern of working remotely has expanded greatly as a result of the pandemic, and I don’t think that’s going to change significantly. But it was also another one of the situations where tax legislation and reporting and withholding tax obligations haven’t kept up with developments.

The Bill therefore has measures to deal with cross-border workers. The PAYE, FBT and employer superannuation contribution tax rules are very strictly applied, but they are incredibly inflexible. They really don’t take into account that employees might be working in New Zealand for non-resident employers and have very different compliance circumstances to those employees of New Zealand resident employers.

The Bill’s proposals acknowledge that such people coming in and working remotely for overseas employers justify taking a different approach to help reduce compliance costs for those cross-border workers. The key amendments are to allow more flexible application of the PAYE rules in specific circumstances. For example, it might allow PAYE to be paid annually. There’s also a repeal of a little used PAYE bond provision.

Alongside those rules are changes to the non-resident contractor rules which relate to the performance of services by non-resident contractors in New Zealand. These are essentially a withholding tax which operates to try and manage the tax risk of people coming in for a short period to perform contract work on a project and then return overseas. Without these non-resident contracting rules, no tax would be deducted. These rules have been in place for a very long time. Apparently, they were first introduced in the wake of the ‘Think Big’ projects of the late seventies and early eighties. They also apply quite extensively to the film industry as well which is where I first encountered them.

The non-resident contractor rules are being tweaked to update them and manage the compliance costs for those subject to them. Again, this reflects a trend that had been developing but has accelerated in the wake of the pandemic. The changes for the PAYE and non-resident contracting rules take effect from 1st April next year.

Notwithstanding what went on with the GST on managed funds issue, there’s quite a bit of other GST matters addressed in the Bill. These include provisions to address issues in the GST apportionment and adjustment rules. These are intended to reduce the compliance costs these rules impose and supposedly better align with current taxpayer practises.

There will be a principal purpose test for goods and services acquired for $10,000 or less GST exclusive. This would enable a registered person to claim a full GST input tax deduction. The other key change is to allow GST registered persons to elect to treat certain assets that have mainly private or exempt use, such as dwellings as if they only had a private or exempt use.

That latter change addresses an issue which has popped up from time to time in is that people may have made claimed GST as part of a home office deduction. If so, then potentially when that property is sold, is it therefore not the case that some portion of the sale will be subject to GST? This was a matter which technically existed, but probably wasn’t being addressed by many taxpayers and advisors.

This issue is generally covered by the GST apportionment and adjustment rules which are very complex and have high compliance costs. Under these rules if you have claimed an input tax deduction based on the estimated use business use of an asset, you are meant to track the business use of the asset.  Where the actual use is different from the estimated business use, then you calculate and return an adjustment at the end of the tax year.

This is quite an involved process, and this measure is intended to try and simplify the matter. It’s a sensible change, in my view, which reflects the fact that although GST is a very broad-based tax, you can’t actually really describe it as a simple tax in its operation. There are all these issues around its margins regarding what represents business use, what proportions become taxable and therefore subject to GST, etc. And as we saw in relation to the GST and fund management services, the sums involved can be quite large actually. These proposed changes to try and simplify matters and will take effect from 1st April 2023.

I frequently discuss tax and environmental issues and I’m therefore pleased to see a proposal in the Bill for an exemption from fringe benefit tax (FBT) for certain public transport fares which are subsidised by an employer. This will take effect from 1st April 2023.This is a good example of tax being used as a behavioural change and comes about by looking at the bigger picture of how we address greenhouse gas emissions and what role can tax have in that. The Tax Working Group identified that the FBT treatment of parking is inconsistent and in many cases is not subject to FBT. By contrast, FBT is applied to subsidised public transport.

When you step back and take a wider environmental policy perspective about this, what’s happening is the opposite of what you really would want. The policy should be to tax parking to help reduce emissions and encourage the use of public transport. That’s what this measure is intended to do. It’s a very welcome move which is estimated to cost about $9 million a year. This would also appear to be a good example of how environmentally friendly changes can be achieved at relatively low cost.

Outside of the main policy issues we just discussed, the Bill, as is typical, contains a whole heap of provisions relating to many other issues. For example, there’s a number of changes in relation to the Bright-line test and interest limitation rules introduced last year.

Unsurprisingly, given the complexity of those rules, we are seeing a number of tweaks and clarifications about how they operate. One such example relates to when relief is available under the bright line test, when land is transferred on the death of the owner to the executor of or beneficiaries of the estate. Such a transfer is meant to be exempt, and the Bill has provisions making that clear.

There are some other provisions relating to rollover relief, that is when the bright-line test does not apply to transfers between related parties in certain circumstances. Most of those amendments will take effect the day after the Bill receives Royal Assent, which will probably be in late March next year. But some pleasingly have a retrospective effect back to when the changes to the Bright-line test and the interest limitation rule were announced on 27th March 2021. I fully expect we’ll see more such technical changes in the future, possibly even with some Supplementary Order Papers to this particular tax bill.

Another provision deals with a potential issue with the foreign trust regime and the exemption for foreign trusts whereby income from a non-New Zealand source is not taxable in New Zealand so long as it’s not distributed to a New Zealand resident. In some instances, a trust can make use of that provision but not have to comply with the foreign trust, registration and disclosure rules. The Bill therefore has provisions addressing that issue and some other minor technical matters applying to foreign trusts.

The recently announced build to rent exemption from interest limitation is also part of this bill. According to the supporting Regulatory Impact Statement this will cost $2.1 million if applied to existing build to rent assets.

Then inevitably, as in any of these tax bills, there’s a whole heap of other little remedial matters tidying up technical issues that have arisen around student loans, financial arrangements, provisional tax look-through companies, dual resident companies and more.

Ordinarily, this type of tax bill would barely get a mention in the press, so this week’s drama was quite unexpected. Now the dust has settled, it’s worth remembering that the issue around inconsistent treatment of GST on fund management services still remains.  Ultimately, the Government backdown is another example of how short-term politics will nearly always trump longer-term policy.

Well, that’s all for this week.  I’m Terry Baucher and you can find this podcast on my website or wherever you get your podcasts.  Thank you for listening and please send me your feedback and tell your friends and clients.

Until next time kia pai te wiki, have a great week!

A tax law change could be of major benefit to Kiwis with Australian superannuation funds

  • A tax law change could be of major benefit to Kiwis with Australian superannuation funds
  • Rethinking the taxation of redundancy
  • Google’s 2019 results highlight the difficulties of taxing the digital giants


This week, a seemingly arcane tax change could be of major benefit to Kiwis who have Australian superannuation funds, rethinking the taxation of redundancy and Google’s 2019 results highlight the difficulties of taxing the digital giants.

Right now, New Zealand citizens or New Zealand permanent residents are the only people who can get into the country. And as the news headlines over the past couple of weeks have shown, testing at the border has become incredibly important in ensuring that COVID-19 does not gain another foothold in the country.

What you are also seeing is a significant rise in the number of Kiwis wanting to return to New Zealand. There are approximately one million Kiwis around the world, including nearly 600,000 in Australia. And the way the pandemic has been handled so far has made many expatriate Kiwis look at returning to New Zealand.

And a significant number of those may come from Australia. Now Australia has compulsory superannuation under which you and your employer are required to make contributions to a superannuation scheme.  Unlike KiwiSaver, where you can only ever have one KiwiSaver scheme, it’s quite possible to have a number of Australian superannuation schemes. And what sometimes happens is that people lose contact with their superannuation schemes or vice versa.

Under Australian law, after a while unclaimed superannuation money is required to be repaid to the Australian Tax Office. This could affect Kiwis who have returned to New Zealand but have lost their records relating to an Australian superannuation scheme. After a while the Australian scheme must pay the funds in that scheme to the Australian Tax Office as unclaimed superannuation money.

All this sounds a little arcane, but there are absolutely billions and billions of dollars invested in these schemes (A$2.7 trillion as of the end of the March 2020 quarter), and the amount of unclaimed superannuation money can be quite significant.

Since 2013, New Zealand and Australia have had a Trans-Tasman Savings Portability Agreement in place to mainly encourage or rather remove barriers to workers freely moving across the Tasman.

So the potentially significant amounts involved and the Trans-Tasman superannuation agreement are the reasoning behind a measure in the recent the introduced The Taxation (Annual Rates for 2020-21, Feasibility Expenditure, and Remedial Matters) Bill introduced a few weeks back.

The bill has a provision which is to allow the direct transfer of New Zealanders’ Australian unclaimed superannuation money from the Australian Tax Office into a KiwiSaver scheme.

This is a measure to get around the issue that once the Australian superannuation scheme deems the funds lost, it’s impossible under Australian legislation for Kiwis to get their money out.

Another handy thing to keep in mind, is that unlike the tax treatment of other foreign superannuation schemes, if you have an Australian superannuation scheme and you transfer it into a KiwiSaver scheme, you will not be taxed, even if that transfer happens more than four years after your return to New Zealand.

So, this is a measure which is favourable for those who have Australian superannuation schemes and may have forgotten what they’ve got and now want to bring the funds across. They can do so tax free into a KiwiSaver scheme. As I said this seems a little bit arcane, but it occurs to me given the numbers of returning New Zealanders we’re likely to see, this could become quite important over the next few years.

Taxing redundancy payments

Moving on, a few weeks back, I was talking to Newshub’s Madison Reidy about the taxation of redundancy payments.  At present, redundancy payments are simply treated as ordinary pay and taxed at the normal rates, which means that for someone receiving a substantial redundancy payment much of it will be taxed at the top rate of 33%. I suggested this was something that needed to be looked at.

Based on an article in the Herald this week it seems that the Minister of Revenue, Stuart Nash, has received correspondence on the matter and is asking officials to look into it, which is encouraging to see.

The problem is given the circumstances we’re in right, now this sort of thing ought to be dealt with quite urgently. Maybe if we’re going to move forward with changes, it would be opportune to include some form of measure in the tax bill I mentioned earlier, which is going through Parliament right now.

One thing to think about regarding redundancy payments, is because they’re treated as ordinary pay, that means if you have a student loan 12% of the payment will be deducted. If you’re in a KiwiSaver scheme, then a further 3% at a minimum will be deducted and to your KiwiSaver scheme, fortunately, ACC does not apply.

There’s an additional bite to this for those who might receive a payment of over $30,000 before tax.  This group of people are not eligible for the COVID-19 income relief payment. This is the special relief benefit for anyone who’s lost a job because of COVID-19 between 1 March and 30 October 2020.  Such persons are entitled to a weekly benefit payment of $490 if they were working for more than 30 hours.  The payment is untaxed and is nearly double the payment someone would normally receive who is unemployed.  Fortunately, MSD has lifted its requirement for someone to spend all their redundancy before they can apply for the job seeker payment of $250 a week.

Nevertheless, the current tax treatment of redundancy needs to change urgently. But it can only be done by a statutory amendment. So, it would be good to see Inland Revenue and the Minister of Revenue moving quickly on this to make a change to help those who are going to lose their jobs or have lost their jobs in the past few months.

Taxing Google

Google New Zealand not so long ago released its financial statements for the year ended 31 December 2019. These show that its income tax bill has risen to $2.4 million.

Now, Google’s 2019 accounts were the first ones prepared as part of its more transparent country by country reporting. The accounts showed that its New Zealand revenue had increased significantly since previous years to $36 million with a pre-tax profit of just over $10.6 million.

What the accounts also show is the difficulty of taxing the digital giants and how little revenue will come through for income tax purposes. According to the accounts the pre-tax profit of $10.6 million represents the value of sales less the direct costs of sales for its advertisements and cloud services. And tucked away in the financial statements, was a note that well over $500 million was paid in service fees to related offshore parties.

And this shows the problem with the digital economy.  Because so much is now driven off intellectual property, and New Zealand is at the tail end of the world in Google’s case we don’t create much intellectual property. Our right to tax is therefore quite limited.

This is not a problem unique to New Zealand. All around the globe countries are grappling with this question that Google and Facebook are piling up billions of dollars in earnings, but not much income tax is being paid in the relevant jurisdiction.

To deal with this matter the OECD has been working on a coordinated approach. The problem is, in the last week or so, that it’s hit a big hurdle with the US Treasury Secretary, Steve Mnuchin, withdrawing the US from the negotiations.  Presently the United States and Europe are at pistols drawn stage, arguing over the question of digital taxation, and Mnuchin and the US pulled out of talks in the last week. This is not good for the whole global economy, and it’s not good for moves to try and get a fairer share of the enormous revenues Google and other digital companies generate.

The Tax Working Group recommended going along with the OECD approach. But it also said that we should have a digital services tax ready to go if negotiations do not go well. We’ve also been watching what the Australians are doing and for the moment they have backed off a digital services tax. But over in Europe, then Britain, which needs a trade deal with the United States, has actually introduced a digital services tax. The French have got one up and running and the Germans are talking about one, too.

So international tensions are building on this and it’ll be interesting to see what the Government decides to do over the next few months as this plays out. But as part of the general upheaval in the tax world going forward we’re going to be seeing this development with the US pulling out of the talks with Europe is not a good one. We’ll monitor developments as they happen, but for the moment it looks like tensions will continue to escalate.

Well, that’s it for this week.  Next week, I’ll be joined by Josh Taylor of tax pooling company Tax Traders. We’ll be discussing how tax pooling was able to help businesses’ cash flows in the past few months.

Until then, I’m Terry Baucher, and you can find this podcast on or wherever you get your podcasts. Please send me your feedback and tell your friends and clients. And until next time, thanks for listening. Ka kite anō.

This week a look at the new Wage Subsidy Extension scheme

  • This week a look at the new Wage Subsidy Extension scheme
  • Capital gains tax is back on the agenda
  • Time to top up your KiwiSaver contributions


From last Tuesday, businesses and the self-employed can now apply for the Government’s Wage Subsidy Extension.

Eligible businesses can get a lump sum payment for a further eight weeks of $585.40 per week per full time employee. The criteria for this has changed from the original wage subsidy scheme. Now a business to qualify must have had a revenue loss of at least 40% for a 30 day period in the 40 days before they apply, compared with the previous closest period last year. So, for example, you’d look at your revenue in this month, June 2020, and compare it with the revenue for June 2019.

Applications for this are open until 1st of September. And as in the case of the existing wage subsidy scheme, it will be administered by the Ministry of Social Development who will be working closely with Inland Revenue on this matter. As I understand it, what happens is the application comes in and MSD will check and then if they’ve got any enquiries, they’ll give Inland Revenue a call.

The tax treatment of this subsidy amount remains the same as previously advised. That is, it is not subject to GST, is non assessable and non-deductible for the employer, although when the payments are made to the employees, they’re taxed as regular income through PAYE.

This does lead to a rather cumbersome tax and accounting treatment and some of us are looking at this and thinking for ease of accounting and to avoid slip ups, it may be better for the employer to treat it as all taxable and deductible. The net effect is the same anyway.  We’re looking at the accounting treatment of this, which can get a little awkward because of this mismatch between the wage subsidy payment being non-deductible for the employer but remaining taxable for the employees.

Speaking of ongoing government support, last Friday after I recorded last week’s podcast, the Finance Minister announced that the Small Business Cashflow Scheme would now be extended until 24th of July. This has been an extremely successful initiative for small businesses. So far, $1.33 billion dollars has been lent to well over 70,000 businesses.

And as I discussed last week, it had taken the space that the Government’s Business Finance Guarantee Scheme had not filled. And the comparison between lending under both schemes is quite stark. As I mentioned, the Small Business Cashflow Scheme has been accessed by approximately 70,000 businesses and they’ve borrowed $1.33 billion dollars.

By comparison, lending under the Business Finance Guarantee Scheme has been $86 million to just 503 businesses, according to the latest business lending numbers from the Bankers Association.

Now, it’s not like the banks are not lending. In fact, according to the Bankers Association, business lending since March 26th has been quite extensive. They’ve lent over $10 billion dollars to over 16,000 customers, as well as the separately reducing the loan payments on another $12.5 billion for 13,000 customers. In addition, they’ve deferred all loan repayments on one billion dollars owed by 3,105 customers.

So, the banks have been working in the background. It’s just that the Business Finance Guarantee Scheme, which was quite a headline project at the time, isn’t designed to do the type of lending that businesses are looking for right now. That is short-term, immediately accessible and with an uncomplicated process.

Unfortunately, the Business Finance Guarantee Scheme ticks none of those boxes and that possibly is down to the design of it and the understandable wish of Treasury to protect the Government’s risk.

As I said last week, one of the things about the benefits of the Small Business Cashflow Scheme is it deals with a matter of resourcing for small businesses. The process to borrow under the scheme is very straightforward and money is delivered quickly.

And the process small businesses go through when applying for loans to the banks, they struggle with that. They have to get a lot of material together. It costs some money to get if they bring in their accountant to assist. And there’s no guarantee they’ll get the funds.

So as I said last week, I think once we’ve gone through everything, the Government should look very carefully at how a future scheme to help small businesses could be designed.  Maybe we want to have a look at what the Small Business Administration in America does. How it guarantees loans and works together with banks on lending.

A simpler process for small businesses could be very helpful for the future growth of our country. Because it’s accepted by all that, we’re going to have to grow our way out of this recession if we are to get the massive amount of debt that the Government has rightly borrowed for this emergency under control again.  [Updateit appears that preliminary discussions about a permanent iteration of the Small Business Cashflow Scheme have taken place.]

Still a live public policy debate

And as part of getting the Government’s debt to GDP ratio under control again, capital gains tax has popped up on the agenda again in a couple of instances this week. Firstly, James Shaw, the co-leader of the Green Party, talking to Jenée Tibshraeny raised it as something that we should be considering. Shaw’s view was that a capital gains tax made more sense now,

“It was our policy when we entered parliament in 1999; it remains our policy today. The extent to which we’ll lead with that or with something else [at the election] is yet to be revealed,”

And talking of rebuilding and still on the tax side, PricewaterhouseCoopers (PWC) issued a report called Rebuild New Zealand, which set out seven planks, as it called them, to rebuild New Zealand.

One of these is about addressing tax reforms.  And what it says about that, to pick up a theme of last year’s Tax Working Group, is that tax reform must be considered to broaden the Government’s revenue base and remove investment bias. It refers to the elephant in the room being a capital gains tax. It’s probably no coincidence that Geof Nightingale, who’s a partner at PWC, was also a member of the Tax Working Group.

The report goes on,

“In our view, there is now a greater need than ever to broaden New Zealand’s tax base so it relies less on taxing income. So is it time to look again at a simple, broad based CGT?”

The report cites the example of the introduction of a broad-based GST over 30 years ago as a model for designing a future CGT, and goes on to say,

“The debate on CGT would be very different if New Zealanders had a better understanding of the extent to which it could actually impact them during their lives and also the trade-off that there might be an eventual trade-off between CGT and income tax.”

And this is something I think should be considered: by broadening the tax base to include capital gains tax the need to increase the top rate of income tax, for example, is minimised. There is a trade-off here and I agree with PWC we should be having that discussion. I don’t think we had a great discussion last year.

We’ll probably see more discussion about this during this election. And it will be interesting to see how the parties all fence around the issue. As I said, in April in this Top Five piece, COVID-19 means we are going to need to have a look at the tax system. Whether tax rates rise or CGT comes in are all on the table for discussion.

Getting the max KiwiSaver

And finally, you have until 30th of June to make sure you have contributed a minimum of $1,042 86 to your KiwiSaver scheme in order to qualify for the maximum government top of $521.43 cents. Now, the government contribution isn’t a lot, but it’s free money, so you should take advantage of it if you can.

Incidentally, PWC’s Rebuild New Zealand report suggested the question of boosting savings should be considered in order to help address the funding of New Zealand Superannuation.  It noted “While there is much to be admired with Kiwisaver, it remains a lightweight compared to the compulsory savings regimes in other countries, notably Australia”.

The report doesn’t say so but we’re still paying for the decision in 1975 by Muldoon’s third National Government to scrap the compulsory superannuation savings scheme established by the third Labour Government.  In my view that decision by the Muldoon Government probably ranks as the single most economically harmful act by any New Zealand government in the past 50 years.

As I said, we’ve been paying for it for the last 50 years, particularly since the Baby Boomer generation reached retirement. And the matter will not go away. The Tax Working Group noted that structural deficits would be increasingly likely by the latter part of this decade. So the issue of addressing the cost of superannuation – how it’s funded – isn’t going to go away.

And on that bombshell, that’s it for this week. I’m Terry Baucher. And you can find this podcast on my website or wherever you get your podcasts. Thank you for listening. Please send me your feedback and tell your friends and clients.  Until next time, Kia Kaha,  stay strong.


A Digital Services Tax is proposed

Top news stories this week

  • New Zealand’s Government proposes a digital services tax
  • 450,000 taxpayers receive a surprise – they had not applied the correct prescribed investor rate to their PIE accounts
  • Inland Revenue is feeling the strain

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