SICAFIs may have leverage of 50% of the company’s assets at the time the loan agreement is concluded and they must distribute 80% of their net profit in the form of dividends. Capital gains do not have to be distributed and remain tax-free provided they are reinvested within four years after they are obtained. Profits must be distributed on an annual basis.
In France12, at the end of 2003, the SIIC (Société d’investissement immobilier cotée) tax regime was created in order to promote the development of real estate investment funds and strengthen their position in the market with respect to Dutch, Belgian and German open-ended funds. 本文来自优.文-论^文·网原文请找腾讯32491.14 of the Autorité des Marchés Financiers.
Any listed real estate investment company, or any subsidiary whose capital is at least 95% held by the parent company, can adopt this legal form.
A SIIC’s main activity must be passive investment in the real estate industry, although it may also commit to other activities providing they remain ancillary to the main qualifying activity. Financial leasing is permitted but may not account for more than 50% of the company’s gross assets. Other ancillary activities such as real property development or brokerage are also permitted, but they may not account for more than 20% of the company’s gross assets. In addition, these other activities do not have the same tax privileges. Unlimited leverage is permitted.
SIICs must distribute 85% of profit from real estate leasing and 100% of the dividends received by any subsidiary that has opted for the SIIC regime.
新会计政策对公司业绩的影响-毕业论文Fifty percent of capital gains arising from the transfer of real assets or the shares of real estate companies, as well as from the shares of any subsidiary companies which have opted for the SIIC structure, must be distributed.
1994 saw the introduction in Italy of FIIs (Fondi di investimento immobiliare), special funds which are not pure REITs.13
FIIs are defined as “Fiscally non-tax-transparent investment funds which invest exclusively in immovable assets, rights in rem in immovable assets and shareholdings in real estate companies. They are not legal entities, but rather pools of investment owned jointly by the unit holders. The unit holders of FIIs are taxed only when a profit is distributed or when they dispose of their units”. FIIs are not permitted to lend money or invest in financial instruments issued by the SGR.
FIIs are tax-exempt and are managed by a managing company, called a “Società di gestione del risparmio” (SGR). They can have a leverage of 60% of the value of the real estate and 20% of the value of other assets. As regards tax, they are under no obligation to distribute operating profit or capital gains.
The following table sums up the tax treatment given to the different REIT regimes in Europe.
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