From Mumbai to Shanghai, With a Side Trip to Hong Kong : China, India, and the Future of Progressive Taxation in an Asian-Led World

Progressive taxation has historically been discussed primarily in the context of developed, Western nations. This article considers its application in two developing, nonwestern economies, emphasizing differences in political, economic, and (especially) cultural contexts and their effect on the progressivity equation. In India these differences include long-standing attitudes, such as the the Hindu tradition's historic ambivalence about utilitarian arguments, and shorter-term institutional arrangements, such as the division of power within India's federal system and the tax exemption for agricultural income. In China they include the legacy of marxism as well as a more long-standing tendency to resolve legal and policy issues based on notions of communal rather than individual welfare. Both countries have limited administrative resources and (by western standards) a relatively small middle class, so that the income tax remains a relatively small if growing source of national revenues. The article considers the impact of these factors, and concludes by asking if a similar "tax life cycle" will apply to both countries or whether political and cultural differences will result in divergent tax patterns. The article further evaluates the progressivity problem as a case study in comparative taxation and the need to develop a more sophisticated methodology for dealing with institutional, attitudinal, and other cultural differences