Wednesday, June 3, 2026

Seeding Tomorrow's Tax Base: The Formalisation Argument the Finance Commission Hasn't Made Yet

Direct tax collection in India is heavily concentrated: a small number of states account for a large share of receipts, while many others contribute far less than their population or economic size would suggest. This concentration is often read along regional lines. That reading is incomplete. The underlying driver is not geography but the degree to which a state's economy is formalized and digitized - how much of its economic activity runs through salaried employment, registered enterprises, and traceable digital transactions rather than cash and informal arrangements. This piece sets out that pattern using data for FY 2024-25 and the preceding years, and considers what it implies for the 16th Finance Commission as it designs devolution and equalisation mechanisms.

The fiscal anomaly

The data show that five states - Maharashtra, Karnataka, Delhi, Tamil Nadu, and Gujarat - together contributed 76% of total direct tax collections in FY 2024-25, while accounting for only around 27% of the country's population.

In other words, roughly one-fourth of the population contributes three-fourths of direct tax revenue.

Figure 1 & 2: "27% of people, 76% of tax"






(Click on the image to zoom)

A services-digitalisation corridor

India's direct tax map is best read not as a map of population, but as a map of formalisation and digitalisation. The same five states that generate over three-quarters of corporate and personal income tax collections house little more than a quarter of the population.

What these states share is not size but infrastructure for the formal economy: a concentration of salaried employment in organised sectors, large corporate head offices, filings related to ESOP income and capital gains on listed securities, a deep gig and platform economy, and high levels of digital adoption.

This can be described as a "services-digitalisation corridor" - a set of economic geographies, running broadly from Ahmedabad through Mumbai to Delhi and Bengaluru and on to Chennai, where the formal wage economy is densest, digital payment penetration is highest, and the gap between GDP and taxable economic activity is smallest.

Figure 3: Tax collection intensity (Tax collected, FY 2024-25 / total population, 2011 Census)



(Click on the image to zoom)

States such as Uttar Pradesh and Bihar together hold a little over a quarter of India's population but contribute less than 3% to the direct tax corpus. This is not primarily a function of lower income levels; it reflects the structure of the economy - a larger share of income arising from agriculture, trading, and small-scale business that sits outside self-assessment regimes by design, not by choice.

The policy message that follows is straightforward: expanding the direct tax base is less a question of rates or enforcement and more a question of formalisation.

Figure 4: Ratio of tax collection to GSDP



(Click on the image to zoom)

Each additional job created in the organised sector, each small trading firm that adopts GST-compliant invoicing, each contractor who moves onto the books, is a taxpayer at the edge of formalisation. The base widens as formalisation spreads.

Direct tax collection tracks formalisation and digital visibility rather than population or GDP alone. The tax map is, in effect, a map of where the formal services economy is concentrated.

Formalisation trajectories: fast movers and slower starters

Looking at the compound annual growth rate (CAGR) of direct tax collections for FY19–FY25 shows that formalisation is not fixed to any one place - it can spread over time.

Telangana recorded a 44% CAGR in direct tax collections over this period - evidence of its emergence as a technology and pharmaceutical hub, marked by large campuses, salaried workforces, and listed companies.

Haryana's 18% CAGR reflects a related pattern: Gurugram's concentration of corporate registered offices and high-salary employment is now visible in the tax data. Together, these two states illustrate that formalisation can extend beyond its original centres, and that direct tax growth tends to follow closely behind.

By contrast, Bihar, Assam, Madhya Pradesh, Uttarakhand, and Andhra Pradesh recorded CAGRs at or below zero over the same period - meaning their direct tax base is not just small in absolute terms but static or shrinking.

Figure 5: CAGR of direct taxes, FY 2019–25



(Click on the image to zoom)

This pattern is not simply a proxy for state income levels - some of these states have recorded reasonable GSDP growth over the same period. The more fundamental issue is that growth in these states is often concentrated in agriculture, informal construction activity, small-scale retail, and subsistence services - sectors that sit largely outside the reach of income tax administration as currently structured.

The distinction that matters for tax policy is not which state is growing, but whether that growth is occurring within organised, documented economic activity or within a large informal sector that remains outside the income tax net.

Concentration over time: the Lorenz curve

A single summary statistic captures a broader shift: the Gini index for direct tax concentration across states rose from 0.6342 in FY19 to 0.6506 in FY25.

Direct tax collection has become more concentrated over the past six years. The FY25 curve sits further from the line of equality than the FY19 curve, meaning that the lower 60–70% of states (by tax contribution) now account for a smaller share of the total than they did six years earlier, while the highest-contributing cluster has pulled further ahead.

It is worth being precise about what this concentration represents: it is not primarily a story of already-wealthy states becoming wealthier in income terms. It is better understood as growing divergence between formal and informal segments of state economies.

The practical implication for policy: the current trajectory does not, by itself, widen the geographic base of direct taxation.

Compliance mechanisms operating within the corridor -  an expanded TDS regime, capital-gains reporting, the Annual Information Statement, and related measures - are working efficiently wherever formal incomes already exist. None of these instruments, by design, reach into informal economic activity in places such as Bihar, eastern Uttar Pradesh, or rural Madhya Pradesh, where the underlying gap widens each year that growth occurs without accompanying formalisation.

Figure 6: Lorenz curve of direct tax distribution, FY19 vs FY25



 

(Click on the image to zoom)

Four fiscal archetypes

A fiscal-digital alignment chart - plotting a digitalisation index against the tax-to-GSDP ratio - is arguably the most policy-actionable view in this analysis, because it moves past "why is there a gap" to "what can be done about it." The answer differs across four broad clusters.

States in the high-digitalisation, high-tax-yield quadrant have already become mature fiscal hubs. For these, the priority is not to push further but to institutionalise: build compliance infrastructure and reduce leakage in treaty benefits and capital gains reporting. One large state sits just below this group -  highly digitised, but with some extraction headroom still available.

A second, emerging-formalisation cluster - including Telangana, Haryana, and Kerala -  has reached meaningful levels of digitalisation but has not yet converted this fully into tax yield, suggesting the gains are still working their way through the system.

A third cluster - an "industrial middle" that includes Gujarat, Tamil Nadu, and Andhra Pradesh - shows moderate-to-high digitalisation alongside comparatively low tax-to-GSDP ratios, consistent with a large presence of proprietorship firms and trading enterprises where digital payments are common but account-level transparency is limited.

A fourth, catch-up cluster - including Uttar Pradesh, Bihar, Rajasthan, Madhya Pradesh, Odisha, and the north-eastern states - shows low levels on both dimensions. For this group, incremental compliance measures or nudges are unlikely to move the needle, because the underlying preconditions for direct taxation - organised employment and registered enterprise - are not yet present at scale.

Figure 7: Digitalisation index vs tax-to-GSDP ratio



(Source: Digitalisation Index data from the State of India's Digital Economy Report 2024)

(Click on the image to zoom)

The chart's implicit message for the Finance Commission is that equalisation and devolution design should account for tax administration capacity, not effort alone. Expecting any state to match the tax-to-GSDP ratio of a mature fiscal hub without first closing the formalisation gap sets an unrealistic benchmark.

India's direct tax geography remains in motion, and decisions made over the next five years will shape whether that motion moves toward convergence or further concentration.

The devolution paradox

The Finance Commission's horizontal devolution formula is designed specifically to offset this kind of imbalance: states that collect more, and are more fiscally efficient, receive proportionally less in devolved funds, while less prosperous states receive more. There is nothing wrong with this design in principle. The difficulty is that the gap it is meant to bridge is widening faster than transfers alone can close it - because transfers address fiscal need, not fiscal capacity. Additional allocations do not, by themselves, make an economy more taxable.

The missing instrument

The gap is not primarily a case for more redistribution. It calls for investment - distinct from redistribution - in the preconditions without which direct taxes cannot be levied in the first place.

This includes expanding digital payments infrastructure in tier-3 cities, supporting GST compliance for micro-enterprises, and helping proprietorships and MSMEs formalise.

These are not welfare measures; they are supply-side fiscal investments that expand the tax base over a ten-year horizon and, over time, ease the burden currently concentrated on a small number of states. Every small enterprise that moves from a cash-based to a formal footing - wherever it is located - is a taxpayer in the making.

The Commission could usefully frame formalisation not as a development outlay, but as fiscal infrastructure.

An equation for where India is heading

The 16th Finance Commission inherits a direct tax geography that is more concentrated, and more unevenly digitised, than that faced by any of its predecessors. It also has access to a richer body of state-level data than before - on formalisation, UPI transaction volumes, GST compliance rates, and AIS-based income information - that can inform a devolution design aimed at expanding the future tax base, not only redistributing the present one. States on the cusp of formalisation do not need special dispensation; they need the enabling conditions to complete that transition.

A formula for the decade ahead

India's direct tax landscape in 2035 will be shaped by decisions taken now. A commission that looks only at the past can build a formula based on the past; a commission that looks ahead can build a formula for the decade to come. The 16th Finance Commission has the opportunity to do both.

 

Disclaimer: The views expressed herein are solely those of the author in a personal capacity and do not represent the official views or position of the author's organisation.

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Seeding Tomorrow's Tax Base: The Formalisation Argument the Finance Commission Hasn't Made Yet

Direct tax collection in India is heavily concentrated: a small number of states account for a large share of receipts, while many others co...