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Outbound Investment Series: Investing in Europe
Market update 2015
www.pwc.com/jp/e/tax
PwC
Agenda
Section I. Capital Trends
Section II. UK Trends in Taxation
Section III. German Trends in Taxation
Section IV. French Trends in Taxation
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
Section I
European Capital trends: Real Estate & Loan Pools
Market update 2015
3
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
What are Global Real Estate Leaders saying about the industry?
On Global Views:
On London Market:
Jon Gray (Blackstone) says REIT Buyouts Loom Amid Bearish Market: “There’s a disconnect, and that creates opportunity”.
Sam Zell (EGI) says there are too many REITs, and in fact, the industry is a flutter with talk of REIT combinations.
Toby Courtland (Great Portland Estates) is positive on London office outlook: “Despite elevated levels of economic uncertainty since the summer…vacancy rates are now at record lows in the West End and, with much of the inventory of space under development already pre-let, we can look forward to further increases in rents”.
John Burns' (Derwent) comments that “The current year is our best ever for lettings”.
6
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
European sectors and most active countries
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
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Vol YOY
(€B) Chg
Office 78.3€ 18%
Industrial 16.1€ 0%
Retail 52.8€ 55%
All Commercial 147.2€ 26%
Apartment 30.4€ 59%
Hotel 15.4€ 27%
Land 7.7€ 40%
Grand Total 200.7€ 30%
Q3'15 Transaction Summary
Q1 - Q3 2015Vol YOY
(€M) Chg
1 United Kingdom 67,342.9€ 32%
2 Germany 46,207.1€ 40%
3 France 18,391.5€ 6%
4 Sweden 9,471.8€ 6%
5 Netherlands 8,847.3€ 49%
6 Spain 7,912.5€ 19%
7 Itlay 6,890.8€ 107%
8 Finalnd 3,117.2€ 14%
9 Russia 3,283.8$ -10%
10 Poland 1,968.4$ -20%
11 Denmark 3,013.2$ 97%
12 Belgium 1,978.1$ 27%
13 Czech Republic 1,949.4$ 68%
14 Ireland 3,284.2$ -2%
15 Portugal 1,901.9$ 640%
Other Europe 15,118.3$ 111%
200,678.6€ 30%
Most Active Countries in Q3'15
Q1 - Q3 2015
PwC
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
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Capital markets UK Listed Real Estate Sector Valuations
PwC
2015 volumes continue to grow as a result of competitive pricing and investor appetite for record deals
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UK, €10bn
UK, €23.5bn UK, €21.5bn [SERIES NAME], €29bn
Ireland, €3bn
Ireland, €2bn
Ireland, €30.5bn [SERIES NAME], €11bn
Spain, €9bn
Spain, €9.5bn
Spain, €21bn
Spain, €6bn
Germany, €10bn
Germany, €10bn
Germany, €6bn
Germany, €15bn
France, €9bn
Belgium, €11.5bn
Italy, €4bn
Italy, €5bn
Italy, €7.5bn
Italy, €11bn Netherlands, €2bn
[SERIES NAME], €2bn
Other, €1bn
Other, €0.5bn
Other, €4.5bn
In progress, €85bn
-
20
40
60
80
100
120
140
160
2012 2013 2014 2015 (9 months)
Face V
alu
e (
€b
n)
Source: PwC analysis Note: Based on the location of the head office of the bank selling the assets
Value of Transactions by Country
€46bn
€64bn
€91bn
€159bn
PwC
2015 volumes continue to grow as a result of competitive pricing and investor appetite for record deals
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
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CRE, €13bn CRE, €18bn
CRE, €48.5bn
[SERIES NAME], €28bn Secured Retail, €6bn
Secured Retail, €9bn
Secured Retail, €18.5bn
[SERIES NAME], €28bn
Unsecured Retail, €10bn
Unsecured Retail, €15bn
Unsecured Retail, €13.5bn
Unsecured Retail, €7bn
SME/Corporate, €3bn
SME/Corporate, €4.5bn
SME/Corporate, €9bn
SME/Corporate, €10bn
Specialised, €14bn
Specialised, €17.5bn
Specialised, €1.5bn
[SERIES NAME], €1bn
In progress, €85bn
-
20
40
60
80
100
120
140
160
2012 2013 2014 2015 (9 months)
Face V
alu
e (
€b
n)
Source: PwC analysis Note: Based on the location of the head office of the bank selling the assets
Note: ‘Specialised’ includes certain structured and asset backed products, shipping, infrastructure, energy and aviation
Co
mp
lete
d
Value of Transactions by Loan Type
€46bn
€64bn
€91bn
€159bn
PwC
Performing loans – gathering pace……the percentage of performing loans to all loans being sold in the market…
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
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9%
18% 20%
40%
0%
20%
40%
2012 2013 2014 2015(9 months)
Source: PwC analysis Note: Based on the location of the head office of the bank selling the assets
PwC
REAL ASSETS - Unexplored European Markets …some markets are at or near the 2007 peaks
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
10
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
€0B
€5B
€10B
€15B
€20B
€25B
€30B
€35B
€40B
€45B
€50BIn
vestm
ent V
olu
mes
H1'07 vs H1'15 - Investment Volumes
H1 2007 H1 2015 % of 2007
PwC
Global Real Estate Capital Flows
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PwC
Capital Flows in Europe exceeding €250bn in 2015?
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
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€0B
€50B
€100B
€150B
€200B
€250B
€300B
€350B
'08 '09 '10 '11 '12 '13 '14 '15
European Investment by Capital Source
Other
MidEast
Asia
North America
Continental
Domestic
0%
2%
4%
6%
8%
10%
12%
€0B
€5B
€10B
€15B
€20B
€25B
€30B
'08 '09 '10 '11 '12 '13 '14 '15
Asian & Mid. East Investment in Europe
MidEast
Asia
%Total
PwC
JAPAN……………… Outbound real estate investment by Japanese investors has been increasing since 2011,
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0.5
1.0
1.5
2.0
2.5
3.0
2007 2008 2009 2010 2011 2012 2013 2014
$ b
illi
on
Total Japanese outbound real estate investments
Others
Asia
Europe
North America
2014 $1.8 billion
PwC
……………………..mainly driven by investment in North America and Europe
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Japan
Source: Real Capital Analytics, CBRE, London
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
$ b
illi
on
2014 $1,348 million
0.2
0.4
0.6
0.8
1.0
1.2
$ b
illi
on
2014 $211 million
0.1
0.1
0.2
0.2
0.3
0.3
0.4
0.4
0.5
$ b
illi
on
2014 $165 million
$211m
$165m
$1,348m
PwC
Section II
UK Taxation Trends
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PwC
Trends in Taxation Introduction to structuring The UK – A well established jurisdiction for inbound investment
• The UK tax framework for non-resident investors in commercial real estate is well established and relatively favourable, particularly as regards:
• Stamp taxes on acquisition
• Taxation of rental income and relevant deductions
• Taxation of capital gains on exit
• Use of debt financing
• Non-residents engaged in “trading” in real estate or involved in the residential sector can however be faced with additional complexity.
• Diverted profits tax – BEPS comes early …
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
Trends in Taxation Indicative structures for non-UK resident investors
Typical offshore structures
• 20% UK tax on rents, net of interest, other expenses and tax depreciation (“capital allowances”)
• Nil UK tax on capital gains (asset or entity sale)
• No UK withholding taxes (on rents - subject to clearance; on shareholder interest - if non-UK source; or on dividends)
• Shareholder debt subject to transfer pricing rule (debt amount and interest rate)
• 4% stamp duty land tax (“SDLT”) levied on purchaser of commercial real estate (or partnership interest), but currently no stamp taxes on offshore entity purchase (market acceptable)
• For sovereign immunity (where applicable) from UK tax on rents, would need to beneficially hold asset directly or through a partnership or offshore unit trust (no “blocking” corporate vehicles)
• Special considerations to structuring apply if “trading” not “investing”
• Vital that offshore entities not centrally managed & controlled in the UK
• Compared to onshore structure
• Up to (currently) 20% tax on all profits (including rents, capital gains and trading profits), although reduction to 19% by 1 April 2017
• Withholding tax exemptions on shareholder interest potentially more difficult, and more prescriptive thin cap and other anti-avoidance rules
• Stamp duty at 0.5% on UK incorporated company purchase
• Notes:
• More complex rules can apply to residential property
• Investors need to factor in any applicable “home country” tax rules
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Fund/Investor
OffshoreCo
UK Property
OffshoreCo
UK
Property
Debt
Instruments
Offshore
Unit Trust
PwC
Trends in Taxation UK tax rates overview (non-residential investment property)
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Acquisition phase
• Stamp duty land tax
• VAT at asset acquisition
• up to 4% of the (VAT-inclusive, if applicable) purchase price (0%/0.5% stamp on entity deals)
• 0%/20% (on purchase price; to extent VAT-opted unless TOGC)
Holding phase
• Tax on income
• Withholding taxes (rent)
• Withholding taxes (other)
• Thin-cap/TP restrictions
• Property tax rates
• Use of losses
• Tax depreciation
• Value added tax
• 20% (income tax) v up to 20% (corporation tax, although reduction to 19% by 1 April 2017)
• nil (subject to advance clearance for non-residents)
• nil/20% on interest subject to sourcing rules/exemptions/treaties, nil on non-REIT UK dividends
• arm’s length test (amount of debt and rate of interest), debt cap rules for corporation tax only
• generally borne by tenants
• indefinite loss carry-forward provided rental business continues
• capital allowances regime (plant & machinery main rate 18%, special rate 8%)
• 0%/20% (option to tax)
Exit phase
• Tax rate on asset sale • nil CGT for non-residents v up to 20% for residents (corporation tax, reducing to 19%)
Sovereign immunity (where applicable)
• the UK recognises the principle, practice is to obtain advance tax authority clearance
PwC
Trends in Taxation UK limited liability partnership/limited partnership
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UKLLP/LP
UK Property
Investors
Advantages
• Simple well known structure
• Potentially attractive to overseas investors for investment activities
• Onshore management may be possible
• Transparent structure
Disadvantages
• SDLT on disposals and movements in income profit sharing ratios
• Income taxed on investors
• Gains or income not able to be ‘rolled up’
• No interest relief for borrowings taken out by individual partners
• Loss of exemption for pension funds if LLP adopted as denied CGT and investment income exemption
Residential property
• Restriction on interest relief or residential land (planned in year 2017/18)
• Non resident CGT charge on residential property
PwC
Trends in Taxation UK company
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
UK Co
Advantages
• Simple
• Income taxed at low(er) rates (maximum 18% by 2020/21)
• Indexation relief reduces capital gains
• Note restrictions on interest relief
• Lower rate of stamp duty (0.5% vs 4%) may enhance marketability
Disadvantages
• Tax on asset sale
• Difficult to extract property tax efficiently
• No step up in base cost on sale of company shares
Residential property considerations
• ATED annual charges (subject to exemptions)
• Higher rate of SDLT on dwellings >£500,000 from April 2016 (does not apply for acquisitions)
Structuring considerations
• Debt funding – lower cost of extraction. Excess interest treated as distribution.
PwC
Trends in Taxation Offshore company
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
EU Co
Advantages
• 20% income tax on rental profit (but rate not reduced in line with CT rate)
• Potential to shelter rental profit by gearing (subject to thin cap)
• Register under NRLS to avoid withholding tax
• No CGT on disposals of commercial property (for non-resident shareholder)
Disadvantages
• NRL tax rate 20% - Inefficient if let to UK company paying CT at 18%
• Central management and control issues
• Diverted Profits Tax needs consideration in group context
Residential property considerations
• ATED charges (subject to exemptions)
• ATED CGT (subject to exemptions)
• Non resident CGT
PwC
Trends in Taxation Jersey property unit trust
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
JPUT
UK Property
Investors
Advantages
• Transparent structure for income purposes (no multiple layers of tax)
• Gains realised offshore and not taxable for non UK resident investors (commercial property)
• Units can be disposed of/ sold down free of SDLT and stamp duty
• Structure commonly used and acceptable to purchasers
Disadvantages
• Structure not suitable for trading activities
• Offshore residence needs to be maintained
• Legal certainty on trust formation
Residential
• ATED - skill applies
• ATED CGT for non-residents
• Non resident CGT
PwC
Trends in Taxation The UK as a holding company regime?
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
UK HoldCo
UK/European investments
Japanese investors
Key tax implications – Japan
• Main concern likely to be the application of Japanese CFC rules. Key consideration, is the UK company a CFC?
• Unlikely under current rules as 20% tax rate.
• If the UK company operates a real business, possibly qualifies under the active trade or business exemption.
• Taxation of:
• Gains;
• Dividends;
• Interest.
PwC
Appendix 1
Continue the conversation…
Presenter CVs
24
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
Presenter CVs
Chris Mutch
Partner, Real Estate Deals
TEL: +44 775 392 8161
E-mail: [email protected]
[Photo here]
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
Presenter CVs
26
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
Richard Williams
Director
PwC UK
Phone: +44 (0)20 7804 4491
Email: [email protected]
2015 - Tokyo Real Estate Event
Germany
www.pwccustoms.com
PwC
5 October 2015
Tax Overview
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2015 Asian Pacific Real Estate Conference
3 Tax Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
1. German tax environment
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2015 Asian Pacific Real Estate Conference
Corporate Income
Tax
15.825%
Real Estate Transfer Tax 3.5. – 6.5%
Trade tax
7 – 17%
VAT
19%
Land Tax
Withholding Tax
26.375%
Federal Taxes
Country Taxes
Municipal Taxes
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
1. German tax environment
13
2015 Asian Pacific Real Estate Conference
4 German tax environment
German legislation &
administration
German Fiscal Courts
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
2. Tax structuring objectives
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2015 Asian Pacific Real Estate Conference
Mitigation of transaction taxes (e.g. RETT)
Reducing CIT leakage
Utilizing Trade Tax relief
WHT – optimized repatriation
Anticipated exit planning
Aligned operational set up
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
3. RETT - rates
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2015 Asian Pacific Real Estate Conference
Baden-Wuerttemberg 5,0%
Bavaria 3,5%
Berlin 6,0%
Brandenburg 5,0%
Bremen 5,0%
Hamburg 4,5%
Hesse 6,0%
Mecklenburg West-Pomerania 5,0%
Lower Saxony 5,0%
North Rhine-Westphalia 6,5%
Rhineland-Palatinate 5,0%
Saarland 6,5%
Saxony 3,5%
Saxonly-Anhalt 5,0%
Schleswig-Holstein 6,5%
Thuringia 5,0 %
As per 1 January 2015
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
4. Tax structuring
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2015 Asian Pacific Real Estate Conference
Investor
Germany
Operationally very efficient; but • Analysis of the Investor’s tax status
• Foreign (non-EU) tax relief almost not
utilisable
• Taxation of the Investor / its stakeholders in Germany
• German CIT burden (15.825%)
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
4. Tax structuring
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2015 Asian Pacific Real Estate Conference
5 Tax structuring
PropCo
Germany
Investor
Holding
The better way to invest in German real estate, • Using Property SPVs
• Implementing sufficient internal gearing
• Making use of trade tax reliefs
• Facilitating existing Holding platforms
• Teaming with JV partners
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
4. Tax structuring
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2015 Asian Pacific Real Estate Conference
5 Tax structuring
LP HoldCo
Germany
Investor
Holding
Possible structure:
• German operations by supporting PropCo LP
• LP HoldCo subject to 15.825% CIT on real
estate net income; Trade Tax planning possible
• Interest usually tax deductible (depending inter alia on volume)
• No WHT on profit distributions by PropCo LP
• Depending on HoldCo platform efficient transfer to the Investor
• Various exit options (incl. share deal)
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PropCo LP
PwC
5. Conclusion
18
2015 Asian Pacific Real Estate Conference
• Any structure should be aligned to the feasible operation set up
Operational Set Up
• Assets may have structuring specialities (e.g. development, residential)
Asset specific requirements • Ongoing process
of changing tax landscape (e.g. BEPS)
Tax & legal framework
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
French tax environment
PwC
Key tax principles General tax data (1/2)
Corporate income tax
• CIT rate: ranges between 33.33% and 38% (turnover considerations)
• Taxation of rental income and capital gains on disposal of properties and/or shares in land rich entities subject to CIT at standard rate
• Thin capitalisation rules apply on financing granted by related companies and bank debt guaranteed by group companies
• Non deductibility of net financial expenses above €3m
3% tax on dividend distribution (not reduced by DTT)
PwC
Key tax principles General tax data (2/2)
VAT
• VAT levied at a 20% rate
• VAT is recoverable (not a final cost) if option for VAT on rental income
3% tax on ownership or French RE properties
• 3% applied on FMV of the French property as at 1st January of the year
• Possible exemptions and non application of the tax subject to annual filing (specific return disclosing the ownership chain required) or commitment to communicate information on the shareholders’ chain
PwC
Focus DTT Japan/France
Nature of income French tax treatment DTT tax treatment
Dividend paid by French
companies to a Japanese
resident
30% WHT*
Reduced WHT rates :
- 0% (<15% ownership required)
- 5% (10%<15% ownership required)
- 10% (if less than 10% ownership)
Interest paid by French
companies 0% WHT*
10% WHT (many exemptions in the
DTT)
Capital gains upon disposal
of shares in land rich
companies (properties
located in France)
33.33% CGT** 33.33% CGT
*a 75% WHT rate may apply if the payment is made on a bank account located in a Non Cooperative State
PwC
Tax principles applicable to RE transactions Comparison asset deal vs share deal (1/2)
Subject Asset Deal Share Deal Best
Step up? Yes
If the acquired target company is
opaque: no
If the acquired target company is
transparent: yes
AD
Discount for latent tax
liability? No
If the acquired target company is
opaque: yes
If the acquired tarhet company is
transparent: no
AD
Capital Gain Taxation? 33.33%, 34.43%, 36.9% or 38% 33.33%, 34.43%, 36.9% or 38% Same
Use of carried forward tax
losses?
Yes but when the capital gain
exceed €1m, a cash out is to be
anticipated (use of tax losses
capped)
Same
If the acquired entity is a pass
through entity, the carried forward
tax losses remain at the level of the
seller
Same
PwC
Tax principles applicable to RE transactions Comparison asset deal vs share deal (2/2)
Subject Asset Deal Share Deal Best
Transfer duties & VAT?
1) acquisition of property of
less than 5 years
- Transfer duties: 0.715%
- VAT: 20% but recoverable AD
2) acquisition of property of
more than 5 years
- Transfer duties: 5.8% or 5.09%
- VAT: no SD
Notary fees?
0.825% of property FMV
(negotiable)
+
20% VAT
No SD
Land register tax ?
("Contribution de sécurité
immobilière ")
0.1% on property FMV No SD
Reps & Warranties? Very limited Extensive AD
Complexity? Low High AD
5% transfer duties on purchase
price (debts in the company reduce
the tax basis)
PwC
The Sppicav: a tailored investment vehicle for your RE investments
PwC
What is a Sppicav?
• Sociétés de placement à prépondérance immobilière à capital variable (Sppicav)
• Alternative Investment Fund specialised in real estate investments
• Corporate form with variable capital
• Managed by a management company subject to supervision and control of the Authorité des Marchés Financiers (French Market Supervisory Authority)
• Mark-to-market accounting and valorisation reporting required to investors
• Respect of certain ratios: investment in real estate assets, loan-to-value, etc
• When dedicated to corporate investors, higher flexibility in leverage and minimum capital requirements
A RE regulated vehicle tailored for institutional investors
PwC
What is the CIT treatment of the SPPICAV?
• Exempt from CIT over its real estate income to the extent it would redistribute them
• Distribution of dividend from Sppicav can be subject to French WHT. Rate depends on the location of the investor and the eligibility of the Sppicav to Double Tax Treaty.
• Distributions are not subject to the French 3% distribution tax.
A vehicle benefitting from an attractive tax regime
PwC
Direct investment by a Japanese company
SPPICAV
JapanCo
Sub SIIC
SCI
30% WHT on dividend according to French law
No application of the reduced WHT rate as per DTT to dividend from Sppicav
PwC
Preferred alternative: investing via a Luxembourg company
Common investment structure in the market
During the holding period: a favourable tax regime
•Full CIT exemption at the French level
•No thin-cap issues
•No trapped cash at the level of SCI (statutory interest)
•No WHT upon interest paid
•No contribution of 3% upon dividend distributions
•WHT of 5% upon dividends distributed to LuxCo1
At exit: flexibility and tax efficiency
• WHT of 5% upon dividends distributed to LuxCo1
• If disposal of shares in SCI:
No discount for inside latent capital gain as free step up in basis can be achieved by purchaser
Reduction of transfer taxes if SCI is leveraged
French property
LuxCo1
French property
1 share
French SPPICAV
ManCo Fund
Management
Interco loan
French SCI
100 % - 1
share Interco loan
PPCPECs/PPL
LuxCo2
Interco loan
PwC
Impact of the Protocol to the French / Lux. DTT
SPPICAV SAS
SCI
LuxCo
SPPICAV SAS
SCI
LuxCo
Before After
No taxation in France 33.33% 33.33% if > 10%
PwC
Preferred structure under the Protocol to the French / Lux. DTT
SPPICAV
Sub SIIC
SCI
LuxCo
L JJ J
!
Respect the legal requirements for
SPPICAVs
PwC
Appendix 2
Continue the conversation…
Presenter CVs
50
December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
Bruno Lunghi Real Estate Tax Partner [email protected] +33 (1) 56 57 82 79
Thank you.
© 2015 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member
firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further
details.
PwC
Appendix 3
German and French Market Overviews
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December 8, 2015 2015 PwC Asia Pacific Real Estate Conference
PwC
5 October 2015
German Market Overview
3
2015 Asian Pacific Real Estate Conference
1 Market Overview Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
Strong position of German investment market among Europe’s most attractive real estate markets
2015 Asian Pacific Real Estate Conference •
Section 1 – Market Overview
Note: Transaction volume in EUR billion Q1 – Q3 2014.
Source: PwC Research, Emerging Trends in Real Estate Europe 2015 survey.
Top 4 German cities, €10 billions Q1-Q3 2014
4
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
1 Market Overview
Stuttgart
City of cars Population: 0.6 m
Frankfurt/Main
Financial centre Population: 0.7 m
Dusseldorf
Fashion, trade fair Population: 0.6 m
Hamburg
Hanseatic trading city, port Population: 1.8 m
Berlin
Capital of Germany Population: 3.5 m
Hamburg
Düsseldorf
Stuttgart
Munich
Frankfurt/Main
Berlin
Major centre in South Germany Population: 1.4 m
Munich
Source: JonesLangLasalle
Note: The colour indicates the total transaction volume in € millions (Q1-2013 to Q4-2014)
2015 Asian Pacific Real Estate Conference
The “Big Six” hot spots experience strong demand
5
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
9.7
21.2
30.7
9.2
5.8
11.1
12.2
14.3
18.1
22.3
- 5 10 15 20 25 30 35
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
Investment volume in € bn.
Total transaction volume in 2014 of €40 bn. in Germany
The total German real estate market grew by 30% in 2014
45%
Investments in Germany by property type (2014)
Development of investment volume in “Big Six” cities
Investments in German real estate market
0%
2%
4%
6%
8%
10%
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Ne
t p
rim
e y
ield
Office Retail Logistics
Development net prime yield “Big Six” cities
Source: BNP Paribas Real Estate Investment Market Report 2015
2015 Asian Pacific Real Estate Conference
1 Market Overview
42%
23%
11%
8%
16% Office
Retail
Logistics
Hotel
Other
Investment volume in € bn.
2013 2014 Growth in %
Office 13.5 17.0 25%
Retail 8.9 9.3 5%
Logistics 2.8 4.2 54%
Hotel 1.7 3.1 82%
Other 4.0 6.6 62%
Total volume 30.9 40.2 30%
Thereof "Big Six" 18.1 22.3 23%
7
Conclusion Tax structuring REIT - rates Tax structuring objectives German tax environment Contents
PwC
French RE market overview
PwC
PwC Real Estate France provides all relevant services through one centre of competence
Transport & Logistics,
Travel Services
Technology, Information &
Communication, Media
Retail & Consumer
Real Estate & Hospitality
Energy Chemical & Pharma
Medium-sized business
Financial Services
Tax / Legal
Tax advice
Legal advice
M&A
Due Diligence
Assurance
Audit of annual reports
Internal audit
SAS 70
IFRS
Advisory
Strategy & Operations
Risk & Compliance
Finance & Accounting
IT Effectiveness
Consulting
Transactions
Due Diligence
Valuation
Construction
Deals
10 Partners
More than 150 employees
Clients public authorities, investors, property funds, banks, property
companies, hotels, industry and retail companies
PwC
€ 6.8 billion was transacted in Q3 2015, overcoming the lacklustre second quarter, to nearly reach the exceptional Q3 2014 level
-
5 000
10 000
15 000
20 000
25 000
30 000
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
Investment in commercial real estate in France (€m)
Q4 Q3 Q2 Q1
Source : CBRE, Immostat
PwC
At 30 September 2015, core assets continue to be the most sought after investment
23%
14%
63%
Style of investments - Q3 2015
Value add
Core +
Source : CBRE, Immostat
Core
PwC
Deals over €100m represent more than 60% of the investment volume at 30 September 2015
> €500m
2 deals
< €25m
210 deals
€25m to €50m
39 deals
€50m to €100m
31 deals
Source : CBRE, Immostat
€100m to €200m
28 deals
€200m to €500m
12 deals
13%
9%
16%
28%
22%
12%
Investments by deal size - Q3 2015
PwC
Steady decrease in prime real estate yield rates since December 2013 to below pre-crisis lows at 30 September 2015
0,00%
1,00%
2,00%
3,00%
4,00%
5,00%
6,00%
7,00%
8,00%
9,00%
12/05 12/06 12/07 12/08 12/09 12/10 12/11 12/12 12/13 12/14 09/15
French real estate prime yields December 2005 through September 2015
Paris CBD prime office Regional prime office Prime shopping centre Class A logistics French Gov.t Bonds French Gov.t Bonds
Shopping Centres
3.50%
Logistics
6.25%
Regional office
5.30%
Paris CBD
3.30%
French gov’t. bonds
0.90% Spread between risk free rate & real estate remains large
Source : CBRE, Immostat
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