Mixed Blessing of Being Designated a Small Business: A Four Country Comparison

This article will focus on how four countries' income tax laws define a small business and how the taxing authorities and legislators attempt to prevent small business definitions from being exploited by potentially unintended users or for unintended purposes. We will use the experiences from four diverse countries (Australia, Ireland, South Africa, and the U.S.), which take their roots from the same legal system (England) to see if there are best practices that can be adapted for these and other countries as well. A fundamental question that arises when discussing tax incentives and disincentives for small business is why carve out special provisions for this segment of the business community? The answer, as discussed below, is two fold: one, the economic benefits that small business yields the economy is material and significant; two, economies of scale as to both regulatory (including tax) compliance costs as well as costs of goods and materials warrant incentives to level the playing field with large businesses.