Rodamco Europe qualifies and has opted for the SIIC status in France. The SIIC status in France entails a tax exemption for current income from French real estate and also for capital gains.
The SIIC regime may be compared with Rodamco Europe’s status as Fiscal Investment Institution under Dutch tax law. “SIIC” stands for “Sociétés d’investissements immobiliers cotées”. The SIIC regime applies to Rodamco Europe starting for the year 2004.
CEO Maarten Hulshoff: “For now we will start with approximately one third of our French portfolio, but in the future, Rodamco Europe may further extend the application of the SIIC regime”.
The value of Rodamco Europe’s French portfolio is € 1.1 billion; the SIIC regime applies to a part of the portfolio with a value of approximately € 320 million.
The SIIC status requires the distribution as dividend of at least 85% of the tax exempt property income and of 50% of tax exempt capital gains. The SIIC also requires the parent company to have a listing of its shares in France. Rodamco Europe has a listing on Euronext Paris since several years.
The one-time cost for opting for the SIIC status is an estimated tax cost of around
€ 12 million, the greater part of which is the so-called exit tax of 16.5% on the difference between market value and fiscal book value of the property. The tax cost is covered by the deferred tax provision at year-end 2003 and will not have a negative impact on the 2004 net profit.
Source: Rodamco Europe