Real estate project financing (PF) had been rapidly grown until the middle of 2000 due to real estate boom. After that, development REITs have gained popularity as a new alternative of development finance as it reached to the limitation due to downtur...
Real estate project financing (PF) had been rapidly grown until the middle of 2000 due to real estate boom. After that, development REITs have gained popularity as a new alternative of development finance as it reached to the limitation due to downturn of general real estate economy including shrinking of the housing industry after the global financial crisis and, as a result, crisis of the financial industry including avoidance of new PFs by financial institutions and weakening project business areas.
It is well known that efforts to improve the system have been made for activation of REITs as they become an alternative of development finance. Despite that efforts on improving the system are continuously made, the reason why the number of REITs established does not meet what is expected is mainly located on the taxation system. According to comparison of rate of return and tax burden between self managed and commissioned REITs presented by an analysis model, rate of return and tax burden between two types of REIT differ by average 3 % and 20%, according to the level of exemption or reduction of corporate tax, respectively. The differences would be bigger if tax burden accompanied by the acquisition of real estate is removed.
Self managed RIETs are more useful for promotion of development projects because they have advantages in terms of agent costs and meeting shareholders' interest, compared to commissioned REITs. However, exemption of corporate tax can not be applied to self administrated REITs due to their nature under current legislation.
First, efforts on reconstruction should be made by self managed RIETs in advance. They should have sustainable growth power by securing diversified profit structures and professionalism.
Second, Act on Real Estate Investment Trust should be reformed in the investor's point of view. Some provisions are necessary to be revised including limitation of borrowing and issuing bonds that does not consider benefits of RIET's shareholders and accumulation of owner's capital according to the mandatory dividend rate
Third, in terms of taxation system, establishment of an asset management company by self managed RIETs as a subsidiary, which is a subject of imposing tax, should be allowed in order for it to perform actual roles of a conduit. With this system, difference in contents and forms between two types of REITs will be removed.
Fourth, exemption of corporate tax should be applied for a limited time through the special tax treatment control law and permanent exemption should be considered, based on various studies including performance analyses during the exemption period
Fifth, the rate of exclusion from gross revenue should be increased in order to attract investment from institutional investors and an effective promotion plan of development project should be devised to encourage payment in kind of land owners by introducing a deferred tax system into the capital gain tax.
Although debate on exemption of self managed REITs' corporate tax has a long history, reformation of the taxation system should be positively considered with downturn of real estate industry and effective promotion of development projects. To do this, efforts of self managed REITs on reconstruction and rearrangement of relative systems should be made in advance.