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Carbon Tax Phase Two Discussion Paper for Comment - deadline 13 December 2024

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A high-level summary of the proposed changes is summarised as follows:

Allowance

Proposed Changes

Basic Tax-Free Allowance

The Basic Tax-Free Allowance is reduced by a large 10% in 2026, and by smaller increments of 2.5% per year from 2027 – 2030.

Performance Benchmark Allowance

5% increase for fuel combustion emissions (10% performance benchmark allowance for fuel combustion).

Allowance remains the same for process emissions.

Carbon Offset Allowance

15% increase in the carbon offset allowance for fuel combustion and process emissions.

Therefore, a 25% carbon offset allowance on fuel combustion and 20% carbon offset allowance for process emissions.

Trade Exposure Allowance

The trade intensity index will increase allowing more companies to benefit from the trade exposure allowance. The proposed changes to the trade exposure allowances are provided in more detail in the document.
It is proposed that to adjust for the increase in carbon offset allowance and performance benchmark allowance, the trade exposure allowance falls away for fuel combustion.

Carbon Budget Allowance

Carbon Budget allowance falls away from 1 January 2026 (previously planned to fall away from 1 Jan 2025).

Mandatory Carbon Budgets

A higher carbon tax rate of R640 per ton CO2e on emissions exceeding the carbon budget allocation from 1 January 2026. Legislative changes to the Carbon Tax Act will follow to enforce this.

Electricity Price Neutrality

Proposed that the carbon tax replaces the electricity generation levy from 1 January 2026, electricity generators to deduct a portion of the renewable energy premium from their tax liability where there is a difference.

Section 12L Energy Efficiency Incentive

It is proposed that eligible projects under the Section 12L tax incentive are absorbed under the carbon offset mechanism. 

Tax Incentive for Green Hydrogen

Extension of the 100% depreciation allowance for solar PV to green hydrogen production in line with the recommendations from the Green Hydrogen Commercialisation Strategy approved by Cabinet in 2023.

A high-level summary of the impacts on business includes:

  • The nominal tax rates were published from 2023 – 2027, and these tax rates included a 19% increase in 2024, 24% increase in 2025 and 31% increase in 2026.
  • Based on the above changes to the allowances, the impact includes a large increase in 2026 of 130% above the rate increase for fuel combustion, and a 200% increase for process emissions.
  • This calculation does not consider the carbon offset allowance as companies need to invest in carbon credits to benefit from the allowance.
  • It will be important for companies to understand what the changes in the Trade Exposure Allowance means – we would recommend challenging the removal of the trade exposure allowance from fuel combustion emissions.
  • It is also recommended that clarity be sought on the revised Performance Benchmarks and if there will be potential to expand this to more industry sectors.
  • The way in which the carbon budget penalty will be levied is not clear and business needs to request clarity.
  • Similarly for Section 12L projects – it is not clear from the Discussion Paper how energy efficiency projects will be absorbed by the carbon offset scheme. The details for this will need to be clarified.

 

Call to Action:

The following companies need to consider the impact of the carbon tax proposals on their business and consider to make submissions by the deadline date:

  • Companies with a current carbon tax liability
  • Companies which use significant amounts of diesel and petrol due to carbon levy included in fuel price
  • Companies that use buy electricity and pay the electricity levy which will be replaced by the carbon tax

Carbon credit project developers.  

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