REIT ASIAPAC MAGAZINE REITASIAPAC 2Q 2019 ISSUE | Page 14

REIT ASIAPAC E D U C AT I O N What is the typical structure of REITs in India, such as are they internally or externally managed, and what are the tax requirements? also provide for a strong governance and reporting structure. One of the hallmarks of a good REIT is having a strong “sponsor” company that can continue to feed the REIT with a pipeline of cashflow-generating properties in the years to come. In India, since real estate assets are generally held in SPVs (Special Purpose Vehicles), the REIT structure would be the trust holding the SPV shares. Interest distributed by the SPVs to the REITs and the REITs to investors is subject to 5% withholding tax in the hands of foreign investors. Dividend is exempt from DDT (dividend distribution tax). Current REIT regulations in India provide for external management of REITs. REIT regulations Indian REITs are also mandated to distribute not less than 90% of its income; at least 80% of the value of REIT assets shall be in completed and revenue generating properties. The threshold is lower at 75% for Singapore-REITs (S-REITs), while a number of S-REITs also voluntarily commit to distributing 100% of its income. “It will be more straightforward to structure an India REIT listing onshore rather than offshore, as there is an additional layer of regulations to negotiate for holding property in a foreign jurisdiction for tax efficiency. ” What taxes do local and foreign investors into Indian REITs need to be mindful of? C Income received by investors from REITs could be in the form of interest, dividends, or gains on sale of REIT units. Interest and dividend income received from SPVs by the REITs would be pass through, that is, such income would not be taxable in the hands of REITs. The taxes on the different streams of income for domestic and foreign investors are discussed below: A INTEREST INCOME Distribution of interest by REIT to its investors should be subject to withholding tax at the rate of 5% (plus surcharge and cess) for foreign investors and at the rate of 10% for domestic investors. While there is no further taxation of such interest income for foreign investors, domestic investors should be required to pay additional tax on such interest income at the tax rate applicable to them. Credit for such taxes withheld should be available for both domestic and foreign investors. B DIVIDEND INCOME Dividend paid by SPV/ Holding Company (in a two-tier structure) is not subject to DDT when paid to a REIT. However, dividend paid by SPV to Holding Company should be subject to DDT at the rate of 20.56% on the dividend distributed. Further, there should be no DDT on distribution of dividends by a REIT to its investors. Dividend received by investors from a REIT should be exempt on pass through basis. 14 CAPITAL GAINS 1. There should be no income- tax implications on swap of shares in SPV for units in the REIT. At the time of eventual sale of such REIT units, period of holding and cost of acquisition of shares in SPV should be available for computing capital gains on sale of the REIT units 2. Gains arising on sale of REIT units should be liable to tax as under: • Long-term capital gains exceeding INR 100,000 (US$1,431) on sale of units held for more than 36 months – 10% (subject to payment of securities transaction tax) • Short-term capital gains on sale of units held for up to 36 months – 15% (subject to payment of securities transaction tax) Mumbai skyline The route for a foreign investor to invest into India isn’t so straightforward. For example, I can trade most ASEAN markets and Hong Kong, Japan, Australia, China, and the U.S. through a general brokerage in Singapore, but not India. Are you able to share the most straightforward method for a foreign investor to trade India REITs and InvITs? there are currency risks since income is generated in India and distributed by a Trust in that country’s currency. Indian listing also gives an opportunity for local retail investors to participate. Being an emerging market, office real estate in India has witnessed growth considerably higher than the mature / developed REIT markets. Unlike the other developed REIT markets including Singapore, REIT returns in India have a significant contribution from growth. Internationally, REIT’s distribution yields have been 100-200 basis points over the treasury yields with little growth. In India, however, Total Shareholder Return shall be a healthy combination of distribution yield and growth. Also, under-renting of many assets provides these portfolios with higher growth potential. Hence, on a Total Return Basis, Indian REITs offer a robust return equal to or higher than the global REIT issuances. Further, there are no India-focused REITs in Singapore as all are structured as business trusts: Religare Health Trust (RHT) and Ascendas India Trust. Although most business trusts listed here have opted to voluntarily introduce thresholds, business trusts are not subjected to any limit on development activities. All Foreign Portfolio Investors (FPIs) need to be registered and traded through registered brokers in India. Aside from India, there have been offshore listings of Indian assets such as Singapore’s Ascendas India Trust. How do you view the relative pros and cons of a listing in India and offshore listing - including cost of capital, tax structuring, etcetera? It will be more straightforward to structure an India REIT listing onshore rather than offshore, as there is an additional layer of regulations to negotiate for holding property in a foreign jurisdiction for tax efficiency. For example, tax is paid in India prior to repatriation to Singapore for distribution. Further, On governance also, REIT regulations in India provide for a strong governance framework on lines similar to International REIT regulations. REIT regulations in India mirror Singapore REIT Regulations. 15