The ACA's policy paper, Budget Priorities 2013, says the Australian economy now faces reduced global commodity prices, a persistently high dollar and rising unemployment.
"The Australian coal industry is experiencing the most difficult operating conditions in 10 years, with the suspension of major projects, the closure of mines and some 9000 jobs shed over the past 12 to 15 months," the report states.
"Current economic conditions reinforce the need for predictable policy settings that encourage additional international investment in Australian coal projects and do not constrain the industry (and hence the economy) with increasing tax or duplicative regulatory burdens."
The paper says the coal industry is among the highest taxed in Australia, at over 40% when company tax and royalties are combined. Instability in taxation arrangements risk making Australia an undesirable destination for coal mining investment.
In submitting the report to government, ACA chief executive Nikki Williams said it was “imperative the Government used the forthcoming Budget to rebuild its structural position through significant restraint in expenditure, both recurrent and one-off”
"It would be of grave concern to the Australian coal industry if the government sought to improve its own balance sheet through new, inefficient taxes on business," she said.
“Industrial transformation in Asia provides global export opportunities for Australia.
"However, despite this positive outlook, government policies need to recognise that the coal boom is over and that the coal industry faces an acutely challenging environment, which is impacting its future competitiveness and ability to attract investment.
"The seriousness of the current international coal market environment and its implications for the Australian economy must be recognised.
"Attacking bipartisan and long-standing tax arrangements – including the immediate deductibility of exploration and waste rock removal expenses, the Fuel Tax Credit Scheme and thin capitalisation rules – would serve only to undermine future private investment and growth and, therefore, future streams of tax revenue."