The tax burden of Reis was relieved
On January 29, the Ministry of Finance and the State Administration of Taxation issued the announcement on the pilot tax policy of real estate investment trusts (REITs) in the field of infrastructure, which opened the prelude to the tax preference of public offering REITs. The announcement puts forward two preferential tax policies mainly for the original equity holders, and provides policy support for the income tax in the issuance, establishment, survival and operation of infrastructure REITs, which stipulates that special tax treatment or deferred payment can be applied. This is expected to effectively alleviate the tax cost and cash flow burden of original equity holders, so as to further alleviate the constraints in the development of REITs.
Core point 1: the internal reorganization before the establishment of REITs is subject to special tax treatment, and no enterprise income tax is levied
Prior to the establishment of REITs, the original equity holders may apply special tax treatment to the enterprise income tax that may arise in the process of restructuring the underlying assets and transferring them to the name of the separately established project company. The asset appreciation part will not pay income tax, that is, the original equity holders and the project company will not recognize the income tax according to the original tax basis of infrastructure assets, So you don't have to pay income tax. Special tax treatment preferential policies are conducive to reducing the tax burden cost of the issuer, so as to improve the enthusiasm of the issuer.
Core point 2: in the establishment stage of REITs, the strategic placement part of the original equity holders will offset the appreciation obtained from the transfer of the equity of the project company and give deferred payment
In the establishment stage of REITs, the fund units subscribed by the original equity holders due to strategic placement offset the value-added income obtained from the transfer of the equity of the project company, and the tax liability of this part is deferred to the actual transfer of fund units. The deferral of this part of tax can avoid double taxation. In addition, considering that the original equity holders may further increase their holdings of fund shares through the secondary market, in order to avoid mixing the increased holdings with the original holdings, Announcement No. 3 stipulates that priority should be given to the strategic placement shares according to the "first in, first out" principle, so as to form the actual tax liability of the deferred part in the early stage. The solution to the problem of double taxation has further effectively reduced the tax burden of the original equity holders.
Comparison of overseas REITs tax policies and relevant preferential policies to activate market enthusiasm
In the mature overseas REITs market, an important driving factor for the rapid development of REITs products is its preferential tax policies. Take the United States as an example. As long as REITs meet the requirements of ownership structure, assets, income and distribution, they apply special tax rules and enjoy preferential tax policies. The dividend part can be deducted when calculating income tax. Most other countries have set up special tax principles with reference to the American REITs system, so as to avoid the problem of double taxation and improve the issuance enthusiasm and product yield.
Reviewing the performance of REITs in the first year, the secondary trend exceeded expectations
2021 is the first year of the issuance of China's infrastructure REITs. A total of 11 infrastructure REITs are listed, covering the fields of environmental protection, transportation infrastructure, park infrastructure and warehousing and logistics. Since its listing, it has been highly recognized by the market. Outstanding performance in terms of secondary market growth and liquidity. In terms of growth, all products achieved positive returns, with an average increase of 36.18%, of which the highest increase was 74.92%. In terms of liquidity, the average daily turnover rate of 9 of the 11 infrastructure REITs exceeds 1.02% of that of Wande a, and the overall liquidity is more active than that of a shares.
Risk warning: infrastructure REITs operation risk; The quality of infrastructure REITs projects is lower than expected; The promotion of relevant policies was less than expected
