PwC Real Estate Leasing* *connectedthinking Content 1. Accounting Dan Marinescu, Senior Tax Consultant PricewaterhouseCoopers 2. Tax Richard Grotendorst, Tax Manager PricewaterhouseCoopers 3. VAT Diana Coroaba, VAT Manager, PricewaterhouseCoopers Real Estate Leasing PricewaterhouseCoopers Slide 2 19 October 2005 PwC Real Estate Leasing* Accounting Dan Marinescu – Senior Tax Consultant *connectedthinking Operating Lessor Accounting Rental Income Costs Recognise on straight-line basis Costs, including depreciation, over the lease term incurred in earning the lease income are recognised as expenses Unless some other systematic basis is more representative of Depreciation allocated on a the time pattern in which the systematic basis consistent with the benefit derived from the leased lessor's policy for similar assets asset is diminished Initial direct costs (e.g. legal fees) on an operating lease Defer Real Estate Leasing PricewaterhouseCoopers or Recognise Slide 4 19 October 2005 Operating Lessee Accounting Rental expenses Investment property under IAS 40 Recognise on straight-line basis over the lease term A real estate property interest held under operating lease can be classified as investment property Unless some other systematic basis is more representative of the time pattern of the lessee’s benefit Property interest is accounted for as finance lease Costs The fair value model must be adopted Costs for services, maintenance and insurance are recognised as expense when incurred Provided the Real Estate property is held for capital appreciation or to earn lease rentals Real Estate Leasing PricewaterhouseCoopers Slide 5 19 October 2005 Finance Lessee Accounting Recognises the asset and the lease obligation on balance sheet at the lower of the present value of the minimum lease payments (MLP) and the fair value of the asset Initial direct costs incurred by the lessee in securing the lease (e.g. commission and legal fees) are included as part of the recognised asset Real Estate Leasing PricewaterhouseCoopers Use interest rate implicit in the lease if this is practicable to determine; if not, use lessee’s incremental borrowing rate Slide 6 19 October 2005 Finance Lessor Accounting Receivable Fixed Asset Gross investment in the lease = MLPs from the lessor’s point of view + unguaranteed residual Net investment in the lease – unearned finance income Real Estate Leasing PricewaterhouseCoopers Slide 7 19 October 2005 Summary Finance Lease - Lessee Balance Sheet Income Statement Asset Finance Charge Lease Obligation Depreciation Expense Accumulated Depreciation Reduction in Lease Obligation Finance Lease –Lessor Operating Lease -Lessee Receivable Finance Income Reduction in Receivable Profit/Loss on Sale N/A Rental Expense Operating Lease - Lessor Asset Rental Income Accumulated Depreciation Depreciation Expense Real Estate Leasing PricewaterhouseCoopers Slide 8 19 October 2005 Leases involving land and buildings Need to consider land and buildings individually MLP allocated between Land & Buildings (L&B) Land in principal operating lease (unless title passes) Buildings decide whether finance or operating lease Under IAS 17 (Separate measurement is not required if land is immaterial or lessee’s interest in L&B are classified as an investment property) Real Estate Leasing PricewaterhouseCoopers Slide 9 19 October 2005 Complex issues Subleases Sale and leaseback Linked transactions Lease and leaseback Leases between related parties Sale and leaseback with special purpose entities Real Estate Leasing PricewaterhouseCoopers Slide 10 19 October 2005 Sale and Leaseback Sale of Real Estate by the vendor followed by leasing of the same asset to the vendor Finance Lease Operating Lease Sales proceeds 100 Carrying amount (80) Sale price = FV Sale price < FV Sale price > FV 20 Recognise any profit or loss immediately Recognise profit or loss immediately Defer and amortise excess over period of asset use Defer and amortise over lease term Real Estate Leasing PricewaterhouseCoopers If loss compensated by lower future lease payments at below market price defer and amortise it in proportion to the lease payments Slide 11 19 October 2005 Linked transactions Lease and leaseback Leases between related parties Lease accounting based on the substance of risks and rewards True economic substance of the transaction prevails over the legal form Up-front lease payment followed by leaseback for shorter periods with annual rental payments Transactions frequently not conducted at arms length terms criteria for an operating leaseback may not be met Option to extend the lease Finance arrangement Real Estate Leasing PricewaterhouseCoopers Slide 12 19 October 2005 Sale and lease back with special purpose entities Involves the transfer and leaseback of an asset by the seller, to a special purpose entity (lessor) wholly or partly funded by bank borrowings or debt securities Accounting treatment of such transactions is complex Seller could de-recognise the asset unless control substantially all the risks and rewards of the asset Real Estate Leasing PricewaterhouseCoopers Slide 13 19 October 2005 PwC Real Estate Leasing* Taxation Richard Grotendorst - Tax Manager *connectedthinking Definition under Fiscal Code Finance lease Art. 7 (7) FC A lease whereby at least one of the following conditions is met: The risks and benefits of the ownership of the leased property are transferred to the lessee upon inception of the leasing contract. The leasing contract expressly provides for the transfer of ownership of the goods subject to leasing to the user upon expiry of the contract. The leasing term covers at least 75% of the useful life of the leased property (including any extensions of the lease term). Operating lease Art. 7 (8) FC Any leasing contract that does not fulfill the conditions to be classified as a finance leasing. Real Estate Leasing PricewaterhouseCoopers Slide 15 19 October 2005 Fiscal Aspects Financial lease The asset is depreciated by the lessee. The interest expenses are deducted by the lessee. The building/land taxes are paid by the lessor. Insurance premiums are paid as agreed between the lessor and the lessee. Fx gains (losses ) are taxable (deductible). Operating lease The asset is depreciated by the lessor. The lessee deducts the lease instalments. The building/land taxes are paid by the lessor. Insurance premiums paid as agreed between the lessor and the lessee. Real Estate Leasing PricewaterhouseCoopers Slide 16 19 October 2005 Interest deductibility Two deductibility criteria: 1. Limitation of interest expense Loans from non-financial institutions (e.g. group companies) Limits: - NBR reference interest rate (RON) - 7% (foreign currency) Non-deductible interest cannot be carried forward 2. Thin capitalisation rules (debt to equity 3:1) Interest and foreign exchange differences (debts > 1 year) Non-deductible interest can be carried forward ! The criteria are not applicable to leasing companies (leasing operations only) and to finance leases Real Estate Leasing PricewaterhouseCoopers Slide 17 19 October 2005 Tax Depreciation (1) finance leasing - lessee is the owner Depreciation of the asset at the level of the lessee operating leasing - lessor is the owner of the leased asset Depreciation of the asset at the level of the lessor ! The general depreciation rules apply for leasing operations Real Estate Leasing PricewaterhouseCoopers Slide 18 19 October 2005 Tax Depreciation (2) Difference between accounting and tax depreciation Based on useful lives stated in the Catalogue of Fixed Assets: Buildings (40 – 60 years), technical equipment (commonly 5 - 20 years), office equipment (2 - 6 years) Land is not depreciable, but costs for land modernisation depreciable (10 years). Depreciation methods: straight-line (buildings), accelerated, reducing balance Complex assets (e.g. buildings) may be depreciated by subcomponents Valuation report by an independent appraiser recommended For assets acquired after having been partially utilised, useful life could be determined by technical experts Revaluations are not recognised for fiscal purposes after 1 January 2004 Real Estate Leasing PricewaterhouseCoopers Slide 19 19 October 2005 Leases vs. Rental Rental contracts have similar profit tax treatment as operating leases Financing costs are fully tax deductible under leases as no thin capitalisation rules apply and there are no other limitations Limitation of tax deductibility of financing costs for pure rental operations financed by loans granted by other entities (either group companies or not) or shareholder’s loans based No option right of tenant to purchase the real estate or minimum value of rented property required as opposed to leases The rental period could be less than one year while the period of the lease contracts exceeds one year No authorisation or computation method are required for rental agreements Real Estate Leasing PricewaterhouseCoopers Slide 20 19 October 2005 Other tax issues Cross-border leasing – Non-resident owners of Romanian Real Estate Real Estate leased to residents and Permanent Establishment’s of non-residents Real Estate leased to non-residents Potential WHT implications Local taxes – payable by the owner of the leased asset Land tax – fixed amount per sqm depending on the location Building tax - 0.5% to 1% of the building’s value or, if not revalued, between 5-10% Real Estate Leasing PricewaterhouseCoopers Slide 21 19 October 2005 Potential legislative amendments? Fiscal Code Specific provisions as regards Real Estate leasing (operating vs. finance lease) Tax depreciation of Real Estate investments. Tax incentives (investment allowance, re-investment reserve). Law 332/2001 on direct investments with significant impact on the economy Real Estate leasing to be included. GO 51/1997 on leasing operations Define sub-lease. Establishes a regulatory body on the leasing market. Real Estate Leasing PricewaterhouseCoopers Slide 22 19 October 2005 PwC Real Estate Leasing* VAT Diana Coroaba - VAT Manager *connectedthinking Leasing-Real Estate Current treatment EU Accession Subject to VAT Exempt with option to tax Option to tax the leasing => Mandatory taxation of any subsequent transaction (?!) Real Estate Leasing PricewaterhouseCoopers Slide 24 19 October 2005 Financial leasing Current treatment EU Accession VAT on principal Option to tax VAT on installments Interest not subject to VAT Real Estate Leasing PricewaterhouseCoopers (principal + interest) Slide 25 19 October 2005 Adjustment period Twenty years starting: from 1 January of the year during which the right to deduct arises, for the construction, purchase, transformation (20%) or improvement (20%) of a building from 1 January of the year during which the building was first used Real Estate Leasing PricewaterhouseCoopers Slide 26 19 October 2005 Adjustment method The adjustment is made once only for the whole period of adjustment still to be covered The adjustment should be performed on an yearly basis in case the destination of the building is changed from taxable to exempt operations or vice-versa Real Estate Leasing PricewaterhouseCoopers Slide 27 19 October 2005 Examples of one - off adjustment - 20 years - Real Estate Leasing PricewaterhouseCoopers Slide 28 19 October 2005 Example 1 A leasing company purchases a building on 15 December 2007 for the price of 7.140 RON incl. VAT (19% = 1.140 RON). It deducts 1.140 RON. It uses the building for operations with a right to deduct.On 2 February 2009, the company concludes a leasing contract for the building. It does not opt to tax the operation and therefore the leasing will be exempt without a right to deduct. Solution Year 1 (2007) is taken into consideration Year 2 (2008) is taken into consideration The loss of the right to deduct VAT appears in year 3 (not taken into consideration) Adjustment in favour of the State: 1.140 RON x 18/20th = 1026 RON to be paid Real Estate Leasing PricewaterhouseCoopers Slide 29 19 October 2005 Example 2 A leasing company purchases a building in 2007 for the price of 11.900 RON incl. VAT (19% = 1.900 RON). It knows it will use the building for exempt operations (i.e. leasing) and does not deduct the input VAT. The company concludes a leasing contract for the building for 5 years starting with 2007 and does not opt for taxation. In 2012, the leasing company concludes a new leasing contract with another beneficiary for the next 15 years. Real Estate Leasing PricewaterhouseCoopers Slide 30 19 October 2005 Example 2 Solution In 2007 the company is not entitled to deduct the input VAT In 2012 the company leases the building and opts to tax the leasing => The company must adjust the initial input VAT The right to deduct VAT appears in year 5 (not taken into consideration) Adjustment in favour of the Company: 1.900 RON x 16/20th = 1.520 RON Real Estate Leasing PricewaterhouseCoopers Slide 31 19 October 2005 Example 3 A leasing company purchases a building in 2007 for the price of 11.900 RON incl. VAT (19% = 1.900 RON). It knows it will use the building for exempt operations (i.e. leasing) and does not deduct the input VAT. The company concludes a leasing contract for the building for 8 years starting with 2007 and does not opt for taxation. In 2015, the leasing contract expires and the leasing company decides to sell the building and tax the transaction. The sell price will be, due to unfavourable market conditions, 5.950 RON incl. VAT (19% = 950). Real Estate Leasing PricewaterhouseCoopers Slide 32 19 October 2005 Example 3 Solution In 2007 the company does not deduct the input VAT In 2015 the company sells the building and opts to tax the transaction => The company must adjust the initial input VAT The right to deduct VAT appears in year 9 (not taken into consideration) Adjustment in favour of the Company: 1.900 RON x 12/20th = 1.140 RON , however the deduction is limited to 5.000 x 19% = 950 RON ( the output VAT charged on sale) Real Estate Leasing PricewaterhouseCoopers Slide 33 19 October 2005 Compliance Main requirements: The taxable person must keep a list of the capital goods subject to VAT adjustment allowing the control of all tax deducted and adjustments made This list must be kept during a period of five years after the end of the adjustment Any other records, documents and books relative to capital goods must be kept during the same period Real Estate Leasing PricewaterhouseCoopers Slide 34 19 October 2005 In addition: More information will be included in the VAT return No longer – standard sales & purchase ledgers Quarterly recapitulative statements for intra-Community deliveries and acquisitions Real Estate Leasing PricewaterhouseCoopers Slide 35 19 October 2005 Possible case scenarios after Accession Real Estate Leasing PricewaterhouseCoopers Slide 36 19 October 2005 ROMANIAN LEASING COMPANY Leasing with option to tax Delivery of goods ROMANIAN CLIENT 2 operations: Leasing – service: Taxable (option) VAT on each installment (principal and interest) No input VAT adjustment Local supply of immovable goods at the end of the leasing contract (if option exercised): Mandatory taxation (?!) VAT on the sale price Real Estate Leasing PricewaterhouseCoopers Slide 37 19 October 2005 ROMANIAN LEASING COMPANY Leasing without option to tax ROMANIAN CLIENT Leasing – service: VAT exempt Leasing company must adjust the input VAT initially deducted in relation to the building, if any One – off adjustment method Real Estate Leasing PricewaterhouseCoopers Slide 38 19 October 2005 Leasing without option to tax FOREIGN LEASING COMPANY ROMANIAN CLIENT Foreign leasing company pays Romanian VAT on acquisition if the immovable property is a new building Leasing – service: VAT exempt Foreign leasing company does not have to register for VAT purposes in Romania Acquisition of new building (VAT) Romanian supplier Real Estate Leasing PricewaterhouseCoopers Slide 39 19 October 2005 Leasing with option to tax FOREIGN LEASING COMPANY Acquisition of immovable property (Exempt with option to tax) Romanian supplier Real Estate Leasing PricewaterhouseCoopers ROMANIAN CLIENT Foreign leasing company pays Romanian VAT on acquisition if the immovable property is a new building or if the supplier opts to tax the transaction Leasing – service: Taxable Romanian VAT on each installment (principal and interest) Foreign leasing company has to register for VAT purposes in Romania and is entitled to deduct the input VAT on acquisition Slide 40 19 October 2005 PricewaterhouseCoopers services Training Pre-accession review (included tailored training) Pre-accession Forum Real Estate Leasing PricewaterhouseCoopers Slide 41 19 October 2005 Your worlds © 2005 PricewaterhouseCoopers. All rights reserved. PricewaterhouseCoopers refers to the network Real Estate Leasing of member firms of PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. *connectedthinking is a trademark of PricewaterhouseCoopers. PricewaterhouseCoopers Our people PwC Slide 42 19 October 2005