Irish Property Market chat II - *read mod note post #1 before posting*

PropQueries

snow_bunny wrote: »

Can someone exain why they aren't already taxed this way and why the government aren't making it priority no.1 to do so? Apologies if this is a stupid question.

I think it's got to do with the message we send out internationally that we are reliable from a taxation point of view and won't change tax rates when it suits us just for political reasons.

As long as they're not buying already built units, then it's a good policy from my point of view. What the government could do that wouldn't impact our taxation message is if they modified it so there's no land hoarding or vacant homes can be allowed i.e. they're welcome in but not as a pure speculative bet. I'm sure (outside the funds making a financial bet) they would understand and have no problem with that.

AlmightyCushion

snow_bunny wrote: »

Can someone exain why they aren't already taxed this way and why the government aren't making it priority no.1 to do so? Apologies if this is a stupid question.

They aren't taxed directly as long as they pay out more than 85% of the rent as dividends to their shareholders. The shareholders then pay tax on the dividends. So if you taxed the REITs profits, you would be taxing the shareholders twice. They would pay tax on the REIT's profits and then pay tax on the dividends they earn from the REIT. Whereas a normal landlord only pays tax on their profits. So, it would make REITs a worse investment than just being a landlord.

However, the problem with that is, if the shareholder is resident in another country they pay tax on dividends in that country and not here so Ireland loses out on the taxes. An easy solution to this would be to introduce a dividend withholding tax, a few other countries do it like the US and Germany. I don't see why we can't do it too.

yagan

snow_bunny wrote: »

Can someone exain why they aren't already taxed this way and why the government aren't making it priority no.1 to do so? Apologies if this is a stupid question.

I believe it was Noonan brought it in to get new property built as bank lending was extremely restricted after the financial crisis, but it's actually an international problem and not just affecting us.

After the bailouts low dividend yields and interest rates made many pension funds seek out other options and so rental property went from about 20% of their portfolios to about 50% now.

They've probably created their own bubble that may leave us with vertical ghost estates. How it unwinds isn't clear yet but Fianna Fail are wedded to wasteful policies that keeps prices elevated and cement mixers turning.

PropQueries

yagan wrote: »

I believe it was Noonan brought it in to get new property built as bank lending was extremely restricted after the financial crisis, but it's actually an international problem and not just affecting us.

After the bailouts low dividend yields and interest rates made many pension funds seek out other options and so rental property went from about 20% of their portfolios to about 50% now.

They've probably created their own bubble that may leave us with vertical ghost estates. How it unwinds isn't clear yet but Fianna Fail are wedded to wasteful policies that keeps prices elevated and cement mixers turning.

I don't think that was his thinking at the time. NAMA and banks still had most of their non-performing/negative equity property/site related loans on their books at that time. It had more to do with finding a buyer for them as we couldn't afford another bank bailout.

What the buyers have done, are doing at the moment or planning to do with all the non-performing property/site related loans they purchased is the real question from my point of view.

Villa05

PropQueries wrote:

As long as they're not buying already built units, then it's a good policy from my point of view. What the government could do that wouldn't impact our taxation message is if they modified it so there's no land hoarding or vacant homes can be allowed i.e. they're welcome in but not as a pure speculative bet. I'm sure (outside the funds making a financial bet) they would understand and have no problem with that.

I don't think it's right that entities that benefit from infrastructure provided by the state should be exempt from contributing something back.

There is also the issue of competitive fairness which could be easily addressed by a flat rate tax on rents

Maybe there is an argument for where the funds exclusively fund the development but again should be time limited

Villa05

AlmightyCushion wrote:

They aren't taxed directly as long as they pay out more than 85% of the rent as dividends to their shareholders. The shareholders then pay tax on the dividends. So if you taxed the REITs profits, you would be taxing the shareholders twice. They would pay tax on the REIT's profits and then pay tax on the dividends they earn from the REIT. Whereas a normal landlord only pays tax on their profits. So, it would make REITs a worse investment than just being a landlord.

This is normal, dividends are paid from after tax profits on goods and services that are subject to vat

yagan

PropQueries wrote: »

What the buyers have done, are doing at the moment or planning to do with all the non-performing property/site related loans they purchased is the real question from my point of view.

That's my question too.

It's going to take a few quarters of reopening to get a proper sense of where the international investor dynamic is at.

Pension managers are most likely to keep pumping their members money into rentals as most contributors are passive about how their pensions are managed. But all it takes is one major fund to go bust and they could become very vocal about cutting losses.

I doubt pushback will come from any Irish passive investors the worst that happened with our banking collapse was one rotten egg being thrown at a shareholders meeting. In contrast the Belgium riot squad had to be called to the Fortis shareholder meeting!

Cal4567

Villa05 wrote: »

Podcast Mick Clifford - Homing in on the pandemic, Mick and Daniel McConnell discuss many of the issues raised here. First half deals with housing

Mick makes the point how the reluctance to change tax laws that stoke demand echos mistakes made in the noughties with section 23 and others. They may serve a purpose when first introduced but they should be time limited.
Daniel states that investment funds are laughing at us with the effective gifts they are getting from the state

I listened to that and he briefly passed over, although he expressed it very succinctly, the complete inability of the Dept of Housing to do anything promptly. If you are not a developer or an approved housing body, it won't mean much to you. The only answer I ever got was that back in the good old CT years, everyone was as corrupt as f&ck and this is why we now need regulating and proper processes. Charming.

It reflects the controlling aspect of the state apparatus but also how blinded it is to change. This housing and affordability crisis is bringing to the boil a number of inherent problems with our governing processes.

Villa05

PropQueries wrote:

What the buyers have done, are doing at the moment or planning to do with all the non-performing property/site related loans they purchased is the real question from my point of view.

Best guess is that the state will long term lease these leave the occupants in situ to avoid mass eviction scenario

Max cost for the state, investment funds laughing all the way to the bank with the loot all tax free of course.

Who needs 7 random numbers in euro millions when it's this easy

snow_bunny

AlmightyCushion wrote: »

They aren't taxed directly as long as they pay out more than 85% of the rent as dividends to their shareholders. The shareholders then pay tax on the dividends. So if you taxed the REITs profits, you would be taxing the shareholders twice. They would pay tax on the REIT's profits and then pay tax on the dividends they earn from the REIT. Whereas a normal landlord only pays tax on their profits. So, it would make REITs a worse investment than just being a landlord.

However, the problem with that is, if the shareholder is resident in another country they pay tax on dividends in that country and not here so Ireland loses out on the taxes. An easy solution to this would be to introduce a dividend withholding tax, a few other countries do it like the US and Germany. I don't see why we can't do it too.

Thanks for taking the time to explain that, it makes sense.
So, I suppose if we try to bring in a tax now, not only will it spook these investment funds but it will also spook the likes of Facebook who use us as a tax haven. It really is a tangled web.

Your solution of introducing a dividend withholding tax seems like a complete no-brainer?

Ace2007

yagan wrote: »

After the bailouts low dividend yields and interest rates made many pension funds seek out other options and so rental property went from about 20% of their portfolios to about 50% now.

I don’t think it’s that high - and certainly very few pension schemes would have a very high allocation to property funds.

Investment funds provide finance for a wide range of industries - say there could be 15+ options and residential property is just one of these.

yagan

Ace2007 wrote: »

I don’t think it’s that high - and certainly very few pension schemes would have a very high allocation to property funds.

Investment funds provide finance for a wide range of industries - say there could be 15+ options and residential property is just one of these.

Not all funds, but the trend is towards increased exposure to property.

The IMF estimates that pension plans have doubled their allocations to illiquid assets over the past 10 years, and for about a fifth of funds these capital commitments amount to more than half their liquid assets.

https://www.ft.com/content/c95deea4-03e2-11ea-9afa-d9e2401fa7ca

AlmightyCushion

Villa05 wrote: »

This is normal, dividends are paid from after tax profits on goods and services that are subject to vat

Yes but A REIT must distribute 85+% of its income as dividends. That is not normal and REITs aren't journal companies. The problem with REITs isn't a tax issue. If you tax them they will still be snapping up properties left, right and centre. Changing the tax structure won't change that.

mcsean2163

yagan wrote: »

The sexual liberation came from around 1986 on when you could start buying condoms from the Virgin music store at O'Connell Bridge.

Ryanair coming along then meant the boat was no longer the budget option. I can relate to a lot of the stuff mentioned in the post you replied to, especially the mid-week pints. Back then it was far more common for pubs to be also family homes so staying open mid week for a few retirees who'd sip one pint over a couple of hours wasn't bad business.

Drinking as a business became a thing in the 90s, especially after the development of Temple Bar made the economic case for boozing as a leisure activity.

In ways I can see how the 80s were completely flipped by the 90s, but the saddest event of all was the assent of Boyzone which essentially killed music. That's when the new rot set in.

Edit to add, I can chime with that post about it been the norm to share rooms, the idea of a room of your own was the exception to the norm. I can well remember in the mid 90s the complaints starting about the average income combo of nurse and garda no longer being able to afford a house in Dublin, which led to the first Bacon reports which quickly forgotten about once Bertie got his "A lot done, a lot more to do" mandate in 2002.

I shared rooms in the nineties. Our kids share rooms now. Amazing music in the nineties e.g. stone roses, Paddy Frazer, future sounds of London, primal scream, nick cave, etc.

I know lots of people that still listen to the same music they listened to in the nineties. I've got a bit stuck myself too finding fewer music as time goes by but to say Boyzone killed music is bonkers and to say everyone has their own room is also untrue.

AlmightyCushion

snow_bunny wrote: »

Thanks for taking the time to explain that, it makes sense.
So, I suppose if we try to bring in a tax now, not only will it spook these investment funds but it will also spook the likes of Facebook who use us as a tax haven. It really is a tangled web.

Your solution of introducing a dividend withholding tax seems like a complete no-brainer?

I don't think it will spook them, Facebook or any other company from coming here. We had Facebook, Google etc long before REITs were a thing here.

The only reason I see for not introducing a withholding tax would be that it would tax all dividends regardless of that person's income. Here dividends are treated as income like normal PAYE income and taxed as such. Some people who don't have a lot of income could actually get dividends and pay no income tax on it. A withholding tax would affect these people and pensioners fall into this category of people. Now, can you imagine the uproar from the opposition if the government tried to introduce a tax that would negatively affect pensioners.

cnocbui

snow_bunny wrote: »

Thanks for taking the time to explain that, it makes sense.
So, I suppose if we try to bring in a tax now, not only will it spook these investment funds but it will also spook the likes of Facebook who use us as a tax haven. It really is a tangled web.

Your solution of introducing a dividend withholding tax seems like a complete no-brainer?

REITs are not treated the same as other companies like Google, they are extremely privileged and they shouldn't be. The argument for their special treatment is no longer valid and, IMO, they should be treated exactly the same as an individual property investor would.

I don't have the figures, but I would say if you looked at the shareholder register of the major REITs operating in Ireland, you would find that the vast majority of their shareholders are not tax resident in Ireland. This completely negates the rationale for their lenient tax treatment.

Australia sorted out the problem of double taxation of profits a long time ago. They have a far more sensible system than the US, where if I understand correctly, they have double taxation of profits, which is to a large extent why companies there are very reluctant to return profits to their rightful owners - shareholders - through paying dividends, forcing them to get a return by selling the shares at a profit and paying CGT on the gain.

Australia has something called Franking - which consists of dividend imputation credits. An Australian company pays tax on it's profits. It then pays it's shareholders dividends from the after tax profits. The company calculates the proportion of the dividend that has tax paid on it - it isn't always 100% but is usually significant, and communicates these as franking credits to the shareholder receiving the dividend. The shareholder than uses these franking credits when calculating their income tax return. If the Franking credit is 100%, then those dividends are tax free income.

This fixes the double taxation problem. Imagine if Ireland had this. The REITs would be charged tax on profits and capital gains - as they should. Irish unit holders would receive franking credits with their dividends so they are not double taxed, but the vast majority of unit holders - the German pension funds, the Canadian teachers union, etc, would not get those credits as they don't pay tax in Ireland. Depending on their local tax codes, those foreign shareholders may well be able to offset the tax paid in Ireland, but I don't care.

The way the total exemption from taxation of REITs currently works, is that Irish taxpayers are subsidising foreign shareholders, while at the same time buggering themselves and making housing more expensive.

Meanwhile, Fritz and Brunhilde, who own shares in the REIT, are able to afford bigger and better houses, courtesy of those hapless fools, the Irish taxpayers and home buyers.

Irish politicians are not only thick, they are traitors:

The Government of New Zealand has chosen to ban non-residents from buying houses to dampen down prices and increase the supply available to people living there. The Overseas Investment Act of 2018 was introduced as a measure to help curb house price inflation.

The Government in Germany has banned Real Estate Investment Trusts from buying up residential property. This decision was taken by the German Government in 2006 specifically to ensure that large international investment funds would not be attracted towards buying up homes and apartments.

https://www.thejournal.ie/readme/cuckoo-funds-housing-market-5416160-Apr2021/

Ace2007

yagan wrote: »

Not all funds, but the trend is towards increased exposure to property.


https://www.ft.com/content/c95deea4-03e2-11ea-9afa-d9e2401fa7ca

I was just chatting about Irish Pension schemes and not in general

yagan

Ace2007 wrote: »

I was just chatting about Irish Pension schemes and not in general

I won't be surprised if Irish pension funds are neck deep in property too.

The current housing minister previously worked for Irish Life if I'm not mistaken so he'd be well aware of exposure.

Ace2007

cnocbui wrote: »

REITs are not treated the same as other companies like Google, they are extremely privileged and they shouldn't be. The argument for their special treatment is no longer valid and, IMO, they should be treated exactly the same as an individual property investor would.

I don't have the figures, but I would say if you looked at the shareholder register of the major REITs operating in Ireland, you would find that the vast majority of their shareholders are not tax resident in Ireland. This completely negates the rationale for their lenient tax treatment.

Australia sorted out the problem of double taxation of profits a long time ago. They have a far more sensible system than the US, where if I understand correctly, they have double taxation of profits, which is to a large extent why companies there are very reluctant to return profits to their rightful owners - shareholders - through paying dividends, forcing them to get a return by selling the shares at a profit and paying CGT on the gain.

Australia has something called Franking - which consists of dividend imputation credits. An Australian company pays tax on it's profits. It then pays it's shareholders dividends from the after tax profits. The company calculates the proportion of the dividend that has tax paid on it - it isn't always 100% but is usually significant, and communicates these as franking credits to the shareholder receiving the dividend. The shareholder than uses these franking credits when calculating their income tax return. If the Franking credit is 100%, then those dividends are tax free income.

This fixes the double taxation problem. Imagine if Ireland had this. The REITs would be charged tax on profits and capital gains - as they should. Irish unit holders would receive franking credits with their dividends so they are not double taxed, but the vast majority of unit holders - the German pension funds, the Canadian teachers union, etc, would not get those credits as they don't pay tax in Ireland. Depending on their local tax codes, those foreign shareholders may well be able to offset the tax paid in Ireland, but I don't care.

The way the total exemption from taxation of REITs currently works, is that Irish taxpayers are subsidising foreign shareholders, while at the same time buggering themselves and making housing more expensive.

Meanwhile, Fritz and Brunhilde, who own shares in the REIT, are able to afford bigger and better houses, courtesy of those hapless fools, the Irish taxpayers and home buyers.

Irish politicians are not only thick, they are traitors:


https://www.thejournal.ie/readme/cuckoo-funds-housing-market-5416160-Apr2021/

Could you provide a link that isn't the Journal, from looking online there are posters on reddit calling BS on that story about REITS in Germany. Nothing on Wikipedia about them being banned either.

Ace2007

yagan wrote: »

I won't be surprised if Irish pension funds are neck deep in property too.

The current housing minister previously worked for Irish Life if I'm not mistaken so he'd be well aware of exposure.

But as a % allocation of their funds, there not that exposed to property funds either directly or indirectly.

Directly - it's too illiquid and all sorts of issues with it
Indirectly - it's fairly highly correlated with equities - but does offer some diversification. Irish pensions schemes would be looking more towards international investment property funds - which invest in wide range of industries and not just residence property - like medical facilities, distribution channels etc.

yagan

yagan wrote: »

I won't be surprised if Irish pension funds are neck deep in property too.

The current housing minister previously worked for Irish Life if I'm not mistaken so he'd be well aware of exposure.

I know Irish life bought four apartment blocks from the developer before work started, in South county Dublin, for the rental market

Ace2007

bubblypop wrote: »

I know Irish life bought four apartment blocks from the developer before work started, in South county Dublin, for the rental market

Yea i'm not saying they aren't invested , but the % of overall pension assets - your talking 5/10% max for most schemes. - that' could be equate to billions in total - but for each scheme individually wouldn't really be heavily exposed, as they are invested in funds and not directly.

Villa05

AlmightyCushion wrote:

Yes but A REIT must distribute 85+% of its income as dividends. That is not normal and REITs aren't journal companies. The problem with REITs isn't a tax issue. If you tax them they will still be snapping up properties left, right and centre. Changing the tax structure won't change that.

What other countries give tax free status to these funds?

Are all these funds actually REITS for example pension funds vulture funds?
The first company in here Kennedy Wilson, are they a REIT?

Ace2007

Villa05 wrote: »

What other countries give tax free status to these funds?

Are all these funds actually REITS for example pension funds vulture funds?
The first company in here Kennedy Wilson, are they a REIT?

Yea Kennedy Wilson is a Global REIT.

Their website shows you what they own: https://www.kennedywilson.com/properties

They own the Shelbourne Hotel for instance

cnocbui

Ace2007 wrote: »

Could you provide a link that isn't the Journal, from looking online there are posters on reddit calling BS on that story about REITS in Germany. Nothing on Wikipedia about them being banned either.

Yes, massah, jus ah soon ah finish this row of cott'n, massah.




I have confirmed from other sources that it appears to be the case. More specifically, they are excluded from residential property built prior to 2006/7 and must build their own

Germany excludes housing from REITs

23 October 2006

GERMANY - The German finance ministry has abruptly decided to exclude residential housing from German real estate investment trusts (G-REITs), due to be legalised by the government from January 1, 2007.

Speaking in Regensburg, deputy finance minister Axel Nawrath said the exclusion of residential housing from the law on G-REITs was necessary to ensure its approval by both the government and parliament.

Last week, German construction minister Wolfgang Tiefensee had indicated he would not support the G-REITs law if it included residential housing. The law was to be approved by ministers of the federal cabinet this Wednesday. Owing to the abrupt change, however, the cabinet is now to approve the law on November 2.

Amadan Dubh

On the point about whether shareholders in REITs are non-Irish based, that is correct. They are, for the most part, not Irish. Which means, due to the operation of double taxation treaties, the salary paid to the employee who pays rent to the REITs essentially ends up exiting the jurisdiction with zero tax paid in Ireland at the time it is paid as rent and at the time it is distributed to the shareholders of the REITs. And the government then wonders why it is so tough to abolish USC or reform income tax and why there is such outrage from any attempts to raise more money directly from the individuals of the State instead of just taxing those who receive tax-free the after tax salaries of the individuals.

yagan

bubblypop wrote: »

I know Irish life bought four apartment blocks from the developer before work started, in South county Dublin, for the rental market

I won't be surprised if property is more than half their assets. Irish investors are pathologically wedded to property as we saw from the 1.800 Irish investors that got burned by that Germany Property Group pyramid scheme.

It's like they simply can not see risk in property.

Villa05

Listening to radio this morning reporting that our electricity grid is coming under serious pressure with blackouts predicted

Data centres are currently using 10% of the power with this predicted rise to 27%

One would imagine that the companies putting these facilities here would have the where with all to also build there own power source that would compensate for what is used

There appears to be no limits to what we will give away unconditionally to the most wealthy

Ace2007

yagan wrote: »

I won't be surprised if property is more than half their assets. Irish investors are pathologically wedded to property as we saw from the 1.800 Irish investors that got burned by that Germany Property Group pyramid scheme.

It's like they simply can not see risk in property.

Again no, you think an investment manager like ILIM is solely in property? Just look at their website - They only have approx 3 billion in property.

ILIM is in investment management company, investing in equities/bonds/property/alternatives, etc.

The Germany Property Group - was well property as the name suggests.

cnocbui

Villa05 wrote: »

Listening to radio this morning reporting that our electricity grid is coming under serious pressure with blackouts predicted

Data centres are currently using 10% of the power with this predicted rise to 27%

One would imagine that the companies putting these facilities here would have the where with all to also build there own power source that would compensate for what is used

There appears to be no limits to what we will give away unconditionally to the most wealthy

They do compensate for what's used, by paying for it, the same as any other user. They don't need to worry as they build significant backup systems. The kicker is their net contribution to CO2 emissions and the massive fines the country will have to pay the EU for breaching the unrealistic CO2 targets.

I'd be more worried by EVs. Each EV is like adding an entire extra household to the grid. Thankfully the numbers are small at the moment.