“The subjects of every state ought to contribute towards the support of its government as nearly as possible in proportion to their respective abilities, that is, in proportion to the revenue which they respectively enjoy under the protection of the state. The expense of government to the individuals of a great nation is like the expense of management to the joint tenants of a great estate, who are all obliged to contribute in proportion to their respective interests in the estate. In the observation or neglect of this maxim consists what is called the equality or inequality of taxation. Every tax, it must be observed once for all, which falls finally upon one only of the three sorts of revenue above-mentioned [viz., rent, wages, profits] is necessarily unequal in so far as it does not affect the other two. In the following examination of different taxes I shall seldom take much further notice of this sort of inequality, but shall in most cases confine my observations to that inequality which is occasioned by a particular tax falling unequally upon that particular sort of private revenue which is affected by it.” The first sentence implies (a) that every Government has the right to exact contributions for its support from all its subjects. According to this view, the right of taxation is derived directly from the conception of sovereignty. It was the determination to insist on this principle which led to the retention of the 3d. per lb duty on tea, that “figment of a tax, that peppercorn rent,” which lost the British their American colonies. The Americans opposed to this absolute doctrine the maxim that taxation ought to be coincident with representation,— that only those who shared in the powers should have the burdens of government. If the latter opinion is strictly construed it would follow that all taxes on articles of universal consumption are unjust except in a country where all who have the natural have also the legal capacity of voting. The doctrine of sovereignty as the basis of taxation, pushed to its logical extreme, results in the maxim that a Government should impose such taxes as are “most easily assessed and collected, and are at the same time most conducive to the public interests” (M t Culloch). Just as a general looks to the efficiency of his army as a whole, and is prepared to sacrifice any portion if necessary, so, it may be said, the state should not regard the particular interests of individuals, but should rather consider the nation as an organism, or, to adopt older phraseology, a leviathan. So far as the political existence of a state is concerned, this view seems to meet with general acquiescence even in modern times, when patriotism is often classed amongst the doubtful virtues, but no ideal of a perfect state has yet met with such acceptance in any nation as to render popular a complete neglect of private interests.

Accordingly, a second basis of taxation (6) is found in the expansion of the term “abilities” used by Adam Smith, which leads to the position that taxes ought to be levied so as to involve equality of sacrifice on the part of the contributors. This is the ideal of taxation which was advocated by Mill and Fawcett. “Equality of taxation as a maxim of politics,” says the former, “means equality of sacrifice. It means the apportioning the contribution of each person towards the expenses of government, so that he shall feel neither more nor less inconvenience from his share of the payment than every other person experiences from his.” It is admitted that this standard cannot be completely realized, but it is thought to furnish a proper foundation of remission in some cases and of proportional increase of taxation in others. It is generally on this ground that it is proposed to leave incomes below a certain amount untaxed,—a plan which, so far as direct taxes are concerned, has been adopted in the United Kingdom. It is clear, however, that any taxes on commodities in general use must infringe this canon, whilst the distinction between “necessaries” and “luxuries,” as Adam Smith pointed out, is difficult to draw in communities advancing in civilization; and certainly a considerable portion of the taxes on stimulants is, as a matter of fact, derived from persons whose incomes are below what is generally considered a reasonable minimum for the standard of comfort, and such persons would probably consider enforced abstinence a greater sacrifice than the payment of a direct tax. It is also principally on the ground of equality of sacrifice that the proposal for graduated or progressive taxation rests. It is argued that a person with <£10,000 a year can pay 10 per cent, (for example) as easily as a person with £1000 can pay 5 per cent. It is to be observed that the principle of equality of sacrifice regards the payment of taxes as duty imposed on the subjects of a state independently of the advantages they may derive individually from the expenditure of the amount levied.

A third basis of taxation, however, is found in the principle (c) that taxes ought to be considered as payment for valuable services rendered by the state to individuals, and this seems to be the position Adam Smith had in view in introducing the clause “under the protection of the state,” and in comparing the individuals of a great nation to the joint tenants of a great estate. It is easy to show, as Mill does, that, if protection is taken in its narrowest signification, as a matter of fact the poor need more protection than the rich, but the argument becomes more plausible, and more consonant with the general teaching of Mill, if stress is laid on the protection and assistance afforded by the state in the process of acquisition of individual fortunes—a view of taxation sometimes called the social dividend theory (cf. Walker, Helferich). It is really on this ground that Mill proposes that the “unearned increment” from land should be taken by the state, and, as has often been pointed out, “unearned increments” are by no means confined to land. Without much exaggeration the state may be regarded as a partner in all industrial undertakings, and is therefore entitled to a share in the proceeds. In a somewhat similar manner, poor rates, education rates, <tc., have been regarded as of the nature of insurance paid by the rich against the carelessness of the poor. The principle under consideration has been generally applied in cases in which the service rendered by the state and the benefit accruing to individuals are easily discovered and estimated, especially in connexion with local taxation.

The object of taxation is in general to provide the state with an adequate revenue, but in all cases the indirect effects are important, and sometimes provision of revenue is considered of secondary importance. Accordingly it has been maintained (<7) that the state ought to use its powers of taxation for the promotion of various social ends. Adam Smith remarks that “it has for some time past been the policy of Great Britain to discourage the consumption of spirituous liquors, on account of their supposed tendency to ruin the health and corrupt the morals of the common people,” and in our own times the falling off in the revenue from alcoholic drinks often furnishes a subject for apparent congratulation in “budget” speeches. German writers with socialistic tendencies (e.g., Wagner) have emphasized this social point of taxation; and Mill, although disapproving of graduated taxation of income, advocated the imposition of extremely heavy succession duties, with the object of promoting a better distribution of national wealth and compelling individuals to rely on themselves. Many nations again have imposed duties on imports with the view of protecting and encouraging home industries, and most of the import duties levied in England before the great reforms of Peel were of this nature. Accordingly, both theoretically and practically, the promotion of social or moral ends may be considered as a fourth basis of taxation. It is worth noticing that in early times the fines received in the courts of justice were an important source of revenue.

V hatever basis of taxation be adopted, the elementary principle of justice noticed in the conclusion of A. Smith’s first canon must be considered. If it is just to tax A, it is just to tax B under precisely similar circumstances. Thus stated, the principle seems almost formal, but for practical purposes small differences in circumstances may be neglected, and it is clear that in any great nation the taxpayers may be arranged in a limited number of groups, within each of which the constituent individuals may be regarded as similarly situated. A tax on rent, or wages, or profits would be obviously unequal if those in one place or employment were taxed while those in another were left free. The practical difficulty is to discover what cases may fairly be regarded as similar, especially if equality of sacrifice be taken as the ideal.

As a matter of fact, in every civilized community a complex system of taxation is adopted, the different parts of which rest in different degrees upon the various principles just noticed. Some taxes are justified on the grounds of their convenience to the sovereign power, and others are increased or diminished in certain cases in accordance with the principle of equality of sacrifice; some are regarded as payments for services rendered by the state, others partake of the nature of sumptuary regulations or are approved on various social or moral grounds; and sometimes the imposition of one productive tax involves, on the ground of simple equality, the adoption of similar taxes which are hardly worth collecting.

The remaining canons of Adam Smith are partly, like the first, ethical in character partly purely economic. Of the second—the canon of certainty— Adam Smith remarks :— “The time of payment, the manner of payment, the quantity to be paid, ought all to be clear and plain to the contributor and to every other person [on the ground of the otherwise arbitrary powers which are given to the taxgatherer] .... The certainty of what each individual ought to pay is in taxation a matter of so great importance that a very considerable degree of inequality, it appears, I believe, from the experience of all nations, is not near so great an evil as a very small, degree of uncertainty.” Perhaps the best example of the infringement of this canon is furnished by the taxes levied from the miserable provincials by their Roman governors.

The third rule—the canon of convenience— which enjoins that “every tax ought to be levied at the time or in the manner to which it is most likely to be convenient for the contributor to pay it,” may be justified, not merely on general grounds of good government, but also on the special economic ground of the increase in the productiveness of taxes which satisfy the condition. It has been found possible to raise a considerable revenue by taxes on commodities, the payments of which by the consumers are made in insensible portions, when it would have been impossible to collect the same amount by direct taxation at comparatively long intervals. Taxation is in this respect like bleeding.

The fourth rule—the canon of economy— states as its general principle that “every tax ought to be so contrived as both to take out and to keep out of the pockets of the people as little as possible over and above what it brings into the public treasury of the state.” Taxes may, according to Adam Smith, break this rule by requiring a large number of officials for their collection, by restraint of trade and production, by encouraging smuggling, and by causing unnecessary vexation; “and, though vexation is not, strictly speaking, expense, it is certainly equivalent to the expense at which every man would be willing to redeem himself from it.” On smuggling Adam Smith elsewhere remarks that “to pretend to have any scruple about buying smuggled goods would in most countries be regarded as one of those pedantic pieces of hypocrisy which serve only to expose the person who affects to practise them to the suspicion of being a greater knave than his neighbours.” It may be observed that in practical politics it is generally taken for granted that a tax which can be evaded will be evaded, and indirect methods of taxation are to a great extent devices by which possibilities of evasion are restricted.

To these general rules of taxation explicitly given by Adam Smith, the following may be added, most of which are implied in different passages of his treatment of taxation, but have been expounded and emphasized by subsequent writers. A convenient summary is given by Helferich in Schönberg’s Handbuch der Politischen Oekonomie (vol. ii. p. 138). (a) A given amount of revenue is, as a rule, both from the point of view of the Government and its subjects, more conveniently raised from a small number of very productive taxes than from a larger number with smaller returns per unit. This was one of the principal financial reforms advocated by Adam Smith with reference to the customs duties, and has been carried out in the United Kingdom by Sir Robert Peel and his successors. The inextricable confusion of the customs duties levied before these reforms were effected can only be realized by those who study the details of the history of taxation. À similar process of simplification has been partially applied to the direct taxes, but in many cases (especially in local taxation) the rule is more honoured in the breach than in the observance. (6) A good system of taxation ought to provide for a self-acting increase in the revenue in proportion as the population and the consequent demands for governmental expenditure increase. It has been found by experience that an old tax causes less inconvenience than a new tax of smaller amount, a fact which is so striking in some cases as to have given rise to the saying that an old tax is no tax. (c) Those taxes are best which yield a steady and calculable return, instead of a return fluctuating in character and difficult to estimate. (<7) Those taxes are best which in case of need can be most conveniently increased in amount. It is this characteristic of the income tax which renders it so popular with chancellors of the exchequer, and it was partly on this ground that Mr Gladstone substituted a tax on beer for the tax on malt, (<?) Regard must always be paid to the real incidence of taxation, and care taken that the real burden of the tax falls on those aimed at by the legislature. No part of the theory or practice of taxation has given rise to so much controversy as the incidence of particular taxes, a subject indeed of so much difficulty and importance as to occupy the greater portion of the treatment by systematic writers.

Incidence of Taxation. —Taxes are generally divided into direct and indirect. A direct tax is defined by Mill as one “demanded from the very persons who it is intended or desired should pay it.” Others (e.g., M ζ Culloch) define it as a tax taken directly from income or capital. In the former definition non-transferable taxes on expenditure would be included (e.g., a tax on livery servants), but not in the latter. Mill’s definition has been generally adopted (e.<7., by Wagner, in the German Handbuch, vol. ii. p. 152); but in any case the most important direct taxes practically are those levied on income or capital directly, and the most important indirect the customs and excise duties. In examining the incidence of taxation the order of arrangement adopted by Adam Smith seems best. He discusses separately taxes on the three great species of income,—rent, profits, and wages (appending to the articles on the first two an examination of taxes upon the capital value of land, houses, and stock), and taxes intended to fall indifferently upon every species of revenue, viz., capitation taxes and taxes upon consumable commodities.

Taxes on Pent.— What is commonly known as rent consists in general of two parts, which may be termed economic rent and profit rent. Economic rent arises from the superiority of advantage of any source in the production of a certain amount of utility over the least productive source which the conditions of demand and supply (including transmission to market) render it possible to employ. Thus, in the production of food, some lands have an advantage in fertility or situation; again, in furnishing amenities of accommodation or facilities for business, some houses have from their situation a similar advantage; and again, different processes in the arts and manufactures are superior to others (giving rise to patents). In all these cases where the amount of the superior sources is limited (naturally or artificially), and recourse must be made to inferior sources of supply, economic rent is paid for the superior advantage. Any tax imposed on this species of revenue falls on the owner. If levied in the first instance from the lessee, he will pay so much less rent, and any new taxes imposed during the currency of leases ought, if intended to fall on the owner, to be taken directly from him. It may be assumed that every owner of a superior source has exacted the highest price obtainable for its use, so that he cannot transfer the tax to the tenant, nor through the tenant to the consumer. If, for example, a tax is imposed on the economic rent of agricultural land, the landlord cannot exact it from the tenant (for if the tenant could afford more rent, why under competition was he not forced to do so before ?) nor from the consumer of the produce, for the price is obviously determined independently of rent. Similarly a tax on the ground rent of houses, if it be assumed that the land is useless for other purposes, must fall on the owners; although a certain portion will be transferred to the occupier if the landlord could use it otherwise and escape the tax (cf. Mill, bk. v. ch. iii. § 6). Taxes on economic rent of various kinds, so heavy as to absorb the whole amount, have been advocated by some theorists on grounds noticed under Adam Smith’s first canon. It is said they would impose no burden on the state as a whole, that they would not affect production or accumulation, and even that the substitution of the state for private owners—who are simply nati consumere fruges— w ould really increase the wealth and power of the nation by compelling these unproductive consumers to work, and by lightening the pressure of taxation on industry. It is, however, obvious that the confiscation of rent would, seeing that land has for generations been in the circle of exchangeable commodities, strike at the roots of the institution of private property. Apart from this general objection, there would in the case of agricultural land be great difficulty in separating economic from profit rent, and any exceptional tax on the latter would obviously tend to check agricultural improvements.

Taxes on Profits.— Profits, as commonly used, is a term embracing three elements which, from an economic and financial point of view, are quite distinct in character, viz., interest (pure and simple), insurance against risk, and earnings of management. The interest on capital in any industrial area, lent on the same security, tends to equality. If, then, a tax is imposed on interest in every form, the incidence in the first place will be on the owners of capital. But two indirect consequences will follow. (1) As Adam Smith remarks, “the proprietor of stock is properly a citizen of the world, and is not necessarily attached to any particular country. He would be apt to abandon the country in which he was exposed to a vexatious inquisition in order to be assessed to a burdensome tax, and would remove his stock to some other country, where he could either carry on his business or enjoy his fortune more at his ease.” In this case the ultimate result would be that the country in which the tax was imposed would possess less capital, and thus would yield a higher rate of interest sufficient to counterbalance the burden of the tax. (2) The tax would tend to check the accumulation of capital within...