Tax status
Tax strategy
Corio’s tax strategy aims to support Corio’s overall strategy. Corio strives to minimize this tax burden in order to achieve the highest possible return on its investment activities. This not only entails the optimisation of the tax position on the going concern business, but also applying best practice in the acquisition and disposal of its real estate portfolio.
Corio explores continuously possibilities to optimise its tax structure within the boundaries of the law. Due to the diversity of the various tax systems applicable in those jurisdictions where Corio performs its activities, the optimal tax structure may differ per jurisdiction. As a result Corio’s current structure consists of a mix of taxable structures and tax exempt structures.
Geographical scope
Currently, Corio has activities in five countries: France, Italy, the Netherlands, Spain and Turkey. In the Netherlands and France Corio uses specific tax regimes (FBI and SIIC respectively), that results in an effective tax rate of 0% on the investment profit realised on virtually the entire local portfolio.
Activities in Italy, Spain and Turkey are taxed at the normal statutory tax rate, be it that the effective tax rate may be lower as a result of the combined effect of interest charges, depreciation and other operating expenses. With respect to these latter jurisdictions Corio is also investigating the possible application of tax-exempt regimes in these countries. If applying such a regime is deemed appropriate within the local investment structure and fits within Corio’s overall strategy, necessary actions will be taken.
Conditionality of special tax regimes
The tax-friendly regimes in the Netherlands and France are subject to certain conditions. The main conditions for an FBI entail restrictions on the maximum amount of externally borrowed funds, maximum shareholdership in an FBI, the scope of its activities and a 100% fiscal profit distribution requirement. Corio is constantly monitoring these conditions to make sure that no infraction is made that would jeopardize its status, whilst at the same time maintaining a dialogue with the Dutch government with a view to improving the existing FBI regime.
Similar conditions governing the distribution of the annual profit apply in France, but in this case the distribution may be spread over several years. On 1 January 2007, SIIC 4 came into force, stipulating that if a shareholder with an interest in Corio of, ultimately, more than 10% is not liable for tax, the SIIC must pay 20% tax on both its income and any capital gains that it has realised relative to this shareholdership. Corio is contesting this new law on the grounds that it is in violation of relevant EU legislation.
Source: Annual Report 2009, Chapter Overview & Strategy, page 23 (PDF, 13.679 kB)
Add to My report