NORTONROSE - Taxation of Airfin in D

8/11/2019 NORTONROSE - Taxation of Airfin in D

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1 Introduction

German law does not dene what leasing is nor is there a separate set of rules

dealing with leasing in particular. For civil law purposes, a lease is generallytreated as a special form of use agreement against consideration which is

akin to a rental agreement but may also contain elements of a loan and other

agreements which are dened by German statutory law. Practically, themost common forms of leases in Germany are operating leases and nancial

leases.

1.1 Operating leaseOperating leases are usually treated as regular rental agreements under

German law. They can be entered into for an indenite period of time and

may be terminated by both parties. The lessor normally bears the risksand rewards attached to the asset and is often also responsible for repairs,

maintenance and insurance. Upon termination of the agreement, the lessee

simply has to return the asset without any further obligation.

1.2 Finance leaseBy contrast, nance leases are typically structured in such a way that the

lessee pays a certain amount on a regular basis to the lessor during a xedterm for the use of the asset. The agreement cannot be terminated during

the xed term, so that it represents a stable calculation base for the lessor.

Typically, in these cases, the lessee bears the risks attached to the asset, inparticular risk of loss, destruction, etc. As a result, it is the lessee who bears

the investment risk.

Depending on whether the lease payments during the xed lease term cover

the lessor’s acquisition or production costs and his ancillary and nancing

costs, full pay-out agreements are distinguished from non full pay-outagreements.

Brieng

September 2013

Taxation of aircraft nancingin Germany



02 Norton Rose Fulbright – September 2013

Taxation of aircraft nancing in Germany

2 Accounting principles

German accounting principles are based on the German Commercial Code ( Handelsgesetzbuch

– HGB). As the German Commercial Code does not contain specic rules for the accountingof leasing assets, accountants follow the tax rules set by the German Federal Ministry of

Finance for the allocation of lease assets in the balance sheet.

The tax rules for the allocation of leases are based on the principle of economic ownership

(Section 39 General Tax Code – Abgabenordnung AO). This means that economic assets aregenerally allocated to the legal owner. However, where someone other than the legal owner

exercises eective control over an economic asset in such a way that he can, in practice

exclude the owner from using the economic asset during the normal period of its useful life,the economic assets will be attributable to this person.

For the interpretation of this general principle, the German Federal Ministry of Finance

distinguishes between full pay-out leases (nancial leases) and non full pay-out leases. A full

pay-out lease (nancial lease) requires the following:

• An agreement with a xed leasing period during which ordinary termination is not possible;

• The lease payments during the xed leasing period cover at least the acquisition or

production costs, plus additional costs, including the lessor’s renancing costs.

Where these requirements are not fullled, the German Federal Ministry of Finance assumesa non full pay-out lease.

2.1 Treatment of full pay-out leases (nancial leases)

Allocation of aircraft as between the lessee and lessor in the case of full pay-out leases

(nancial lease)

Type of Lease Fixed lease period

40%-90% of useful life

of aircraft*

Fixed lease period

< 40% or > 90% of

useful life of aircraft

Without renewal or

purchase option

Lessor Lessee

With purchase option Purchase price < Book

value at sale

Lessee Lessee

Purchase price ≥ Book

value at sale

Lessor

With renewal option Additional lease

payments <

remaining book value

(determined according

to straight line method)

Lessee Lessee

Additional lease

payments ≥

remaining book value

(determined according

to straight line method)

Lessor

* The useful life of aircraft is determined on the basis of tables issued by the Federal Ministry of Finance. The Federal Ministry of Finance

assumes a useful life of 12 – 14 years for aircraft.

N.B. In cases of special leasing, i.e. where the asset has been designed specically for the lessee’s requirements and can reasonably only by

used by the lessee, commercial ownership is generally ascribed to the lessee.



Norton Rose Fulbright – September 2013 03


Where the commercial features of a lease do not exactly t the criteria set out by the GermanFederal Ministry of Finance, economic ownership in general and in relation to aircraft inparticular must be determined on a case-by-case basis. Unless indicated otherwise below,

the allocation rules for assets in general can be applied to aircraft. Broadly, the key issue iswho bears the risks and rewards of the leased aircraft. Criteria for the determination of the

economic ownership are:

• whether or not the lessee has an option to acquire the aircraft for a xed purchase price at

the end of the lease term;

• who bears the risk of a total loss of the aircraft;

• whether the risks or rewards of a sale of the aircraft reside with the lessor or the lessee;

• who is responsible for the maintenance works during the lease term.

2.2 Treatment of non full pay-out leases over aircraftDecrees by the Federal Ministry of Finance deal with three types of non full pay-out leases

which run over a xed period of more than 40% but less than 90% of the useful life of amovable asset (here aircraft). The following lease terms normally should not aect economic

ownership of the lessor:

• Obligation on the lessee to purchase the leased aircraft at a pre-determined price upon

request of the lessor if the lease is not renewed at the end of the xed lease period.

•Obligation on the lessee to reimburse a loss of the lessor if the aircraft is sold at the end ofthe lease period at a loss. If a gain is realised upon the sale of the aircraft, participation of

the lessor in such gain of at least 25%.

• Termination of the lease by the lessee after the xed lease period in which case lessee has

to make a nal payment to the lessor equivalent to the dierence between lessor’s totalcost and payments made during the term of the lease. 90% of the sale proceeds realised

by the lessor are credited against the nal payment to be made by the lessee.

Where the commercial features of a lease do not match the criteria above, economic

ownership must be determined on a case-by-case basis (cf. criteria under 2.1).

2.3 Sale and lease back

There are no specic accounting rules for sale and lease back transactions.





3 Income taxation

3.1 General considerations regarding investment structureThere are various structural options for German aircraft lessor activity, which should beconsidered prior to an investment. The options primarily depend on whether or not the

investor is resident in Germany:

(a) Non-resident aircraft lessors

Non-resident aircraft lessors can broadly choose between (i) a direct cross-borderleasing investment and (ii) a concentration of the lessor’s activity through a permanent

establishment, a partnership or a company.

(i) Direct cross-border leasing

A direct cross-border lease of the aircraft to a German resident lessee is the easiestoption to conduct business in Germany. The foreign investor engages in an ongoing

lease relationship without having a xed place of business such as a permanent

establishment, a commercial partnership or a company in Germany.

This form of investment is cost saving and is obviously attractive for short-terminvestors.

(ii) German resident permanent establishment or German partnership

Often, a stronger presence will be required in Germany for the fullment of German

market expectations and administrative requirements. In many cases, fulllingthese requirements is only possible by establishing a permanent establishment,

a partnership or a company in Germany. All forms give rise to a German taxationlink and require tax registration in Germany and the fullment of German taxduties such as the ling of annual tax declarations. Therefore, these forms are only

recommendable if the investment in Germany is medium to long-term and exceeds aminimal business in Germany.

(A) German permanent establishment

Establishing and liquidating a permanent establishment is easier than setting

up or liquidating a partnership or company. However, the economic risk will beassumed solely by the foreign head oce because a permanent establishment has

no legal personality from a German law perspective.

(B) German partnership

A typical feature of partnerships such as a general partnership (ofene Handelsgesellschaft – OHG) or a limited partnership (Kommanditgesellschaft – KG)

is that one or more of the partners are general partners with unlimited liability.

Therefore, there will always be one partner – which can be a company – whosebusiness risk is not fully limited.

Partnerships are treated as transparent for income tax purposes. Therefore,

income tax is levied at the level of the partners. Special tax rules for partnerships

(e.g. for loss utilisation or the recognition of contractual relationships betweenpartner and partnership) which implement the transparency principle can bring

an additional complexity to the taxation of partnerships. The transparencyprinciple is not applicable for German trade tax purposes and does not release the

partnership from tax registration and compliance duties.





(C) German company Companies such as a limited liability company (Gesellschaft mit beschränkter

Haftung – GmbH) or a stock corporation (Aktiengesellschaft – AG) are separate

legal entities. This gives investors the opportunity to limit liability to the registeredshare capital in order to limit their business risk. Furthermore, contractual

relationships between shareholder and company are generally recognized for tax

purposes provided they are at arm’s length.

Companies are also separate entities for tax purposes. Therefore, companies with aregistered oce or management in Germany have to register for tax purposes and

are subject to corporate income tax (plus solidarity surcharge) and trade tax.

(b) Resident aircraft lessors

Resident aircraft lessors can elect to operate through (i) a German company or (ii) aGerman partnership.

(i) German company

The comments on German companies for non-resident lessors in Section 3.1 a (ii) (C)

apply mutatis mutandis. The main disadvantage of the establishment of a Germancompany is the potential German trade tax liability of the German company.

(ii) German partnership

As set out in Section 3.1 a (ii) (B) German tax law has special tax rules for the taxation

of partnerships which can make handling of German partnerships complex.

However, limited partnerships are often used as an investment vehicle for Germanretail investors (i.e. individuals invest jointly in an aircraft) as under certaincircumstances German trade tax liability can be avoided. Furthermore, the partners

can benet from a special taxation regime for capital gains which exempts capitalgains from German income taxation if the aircraft is held for at least 10 years.

For the purposes of this overview, we will focus in what follows on direct cross-border leasingof non-German resident companies and investments structured via German companies as the

most frequent forms of aircraft investments in Germany.

3.2 Corporate income tax – general aspectsGerman resident companies are subject to German corporate income tax on their worldwide

income (unlimited tax liability, unbeschränkte Steuerpicht ).

Prots of the company are subject to corporate income tax at a rate of 15% plus a solidarity

surcharge (Solidaritätszuschlag ) of 5.5% of the assessed amount of corporate income tax(yielding a compound corporate income tax rate of 15.825%).

3.3 General determination of income baseBasically, there are seven classes of income to which German tax residents are subject. In the

case of a company, this is broadly irrelevant because as a matter of statutory law, all incomegenerated by a company is deemed to be trade income.





The taxable income of a company is based on the commercial prot or loss shown in itsGerman GAAP nancial statements albeit with certain adjustments for corporate incometax and trade tax purposes. The company is not required to physically set up a specic tax

balance sheet; it must, however, prepare a reconciliation of taxable income which reects taxadjustments. In broad terms, items which are deducted in the nancial statements (salaries,

oce rents, other business expenses) are also deductible for tax purposes. The following

adjustments are particularly noteworthy:

• Dividends received by a German corporate shareholder are generally 95% corporateincome tax and trade tax exempt, if the shareholder holds shares in the distributing

company of at least 10% as of the beginning of its scal year.

• Capital gains derived from the sale of shares are basically also 95% tax exempt.

• Interest deductions are subject to the applicable interest ceiling rules.

• The use of losses is subject to certain restrictions.

(a) Depreciation of aircraft

From a German tax perspective, only the economic owner of the aircraft is entitled to

depreciate the aircraft over its expected useful economic life. The German tax authorities

issue depreciation tables for the expected tax life of movable assets and assume a usefuleconomic life of 14 years for aircraft with a maximum ight weight up to 20 tons and 12

years for aircraft with a maximum ight weight above 20 tons.

Depreciation of movable assets must use the straight-line depreciation method. Witheect from 1 January 2011, the declining balance method is no longer available for thedepreciation of movable assets.

(b) Interest ceiling rules

Generally, under the interest ceiling net interest expenses, i.e. interest charges in excess

of interest earned are deductible only up to 30 percent of EBITDA (i.e. earnings beforeinterest expenses, regular depreciation and amortization less any interest income

generated) in an assessment period. If the interest earnings of the business exceedthe interest expenses, the interest ceiling does not apply. By contrast, remaining non-

deductible interest can be carried forward to the following year and then be deducted.

There are three exemptions from the deduction restrictions provided by the interest

ceiling (it is sucient if one of the following conditions is fullled):

• Exemption limit of €3 million: The interest ceiling is not applicable if the total

net debt interest (i.e. interest expenses less interest income) of the business in theassessment period amounts to less than €3 million.

• Stand-alone clause: The interest deduction restrictions do not apply to stand-alone

businesses (i.e. businesses which do not belong to a “group” or only partly belong

to a “group”). The term “group” is dened very broadly in sec. 4 h para. 3 GermanIncome Tax Code (Einkommensteuergesetz – EStG). A business belongs to a group

if it can be consolidated with one or several other businesses in accordance withthe applicable reporting standards – usually the International Financial Reporting

Standards (IFRS) – or if its nancial and business policies are governed by another

entity (corresponding to IAS 27, which, however requires a legal agreement).





For companies the stand-alone clause applies only where the company establishesthat remuneration on the shareholder debt accounts for no more than 10 percent ofits net expenses. Shareholder debt is assumed where the company is nanced via a

loan granted by (i) a substantial shareholder (shareholding of more than 25 percent),(ii) an aliated person or (iii) a third party having recourse against a substantial

shareholder or an aliated person.

• Equity ratio comparison: In relation to businesses belonging to a group, the interest

ceiling is not applicable if it can be shown on the basis of the nancial statementsfor the preceding year that the equity ratio of the business according to its individual

nancial statements is the same or higher than the equity ratio of the group in the

consolidated nancial statements (so called “escape clause”). In principle, the equityratio has to be determined in accordance with IFRS, alternatively, the commercial law

of a Member State of the European Union or (with certain restrictions) in accordancewith US-GAAP. The equity ratio is generally dened as the ratio of equity to balance

sheet total and may be subject to certain adjustments for goodwill, tax reserves, book

values of shares in subsidiaries, etc.

The escape clause for businesses forming part of a controlled group applies only if theremuneration on shareholder debt accounts for no more than 10 percent of the net

interest expense. Interest expense on loans received from substantial shareholders

and aliated persons are only counted for this purpose to the extent they are shownas liabilities in the fully consolidated accounts of the relevant corporate group. In

addition, secured bank loans do not count towards the 10 percent threshold wherethe security is provided solely by a member of the controlled group.

(c) Loss utilisation restriction

(i) Treatment of tax losses

Tax losses which cannot be set o in the current year may be carried back one year upto an amount of €1 million.

To the extent losses exceed €1 million or cannot be fully set o against the previousyear’s income, they can be carried forward. Losses carried forward can be set o

without restriction against prots only up to an amount of €1 million per year. Lossesin excess of this amount may be set o only to the extent of 60 % of taxable income in

the current period.

There are no time limitations on the use of loss carry forwards.

(ii) Rules regarding forfeiture of tax losses carry forward

A direct or indirect change of control in a company can trigger a partial or full

forfeiture of tax losses carried forward. If more than 25% of the shares in a companyare (directly or indirectly) transferred to a purchaser or group of related purchasers,

the tax losses carried forward by the company will be partially forfeited. If more than50% of the shares are (directly or indirectly) transferred to a purchaser or group of

related purchasers, the tax losses carried forward will be fully forfeited. The forfeiture

will not be triggered to the extent the company has sucient hidden reserves(dierence between the tax book values of the assets of the company and the fair

market value of the shares/assets). These principles also apply for trade tax purposes.





3.4 Cross-border-issues(a) German sourced income

If a company is not resident in Germany, it is subject to limited tax liability (beschränkte

Steuerpicht ), if and to the extent that it realises income from German sources specied inthe German Income Tax Act.

As long as the lessor maintains no German xed place of business or provides any otherservices in connection with aircraft leasing, the mere lease of aircraft does not create a

permanent establishment of the lessor in Germany.

Lease rentals derived from an aircraft lease by a non German resident company are only

subject to German corporation tax if (i) the lessor operates through a German permanentestablishment or (ii) the aircraft is registered in the German Aircraft Register or (iii) if and

to the extent that the aircraft is used in Germany and economic ownership resides withthe lessor.

(b) Capital gains

Capital gains resulting from the sale of an aircraft are treated as income in the ordinary

course of business. In the case of non-German resident companies the capital gainsare subject to German corporation tax if (i) the lease is carried out through a German

permanent establishment or (ii) the aircraft is registered in the German Aircraft Register.

(c) Withholding taxes

Lease payments made by a resident German lessee to a non-resident lessor are not subjectto German withholding tax. Former provisions that imposed German withholding tax on

lease rentals were repealed with eect from 1 January 2009.

Please note that in the case of cross-border leases a double taxation treaty betweenthe lessor’s state of residency and Germany may provide distinct taxation rules for

German-sourced income. Thus, one should always check in these cases (i) whethera double taxation treaty is applicable and (ii) what the specic implications for

German-sourced income are.

3.5 Trade taxTrade tax is generally imposed on all business activity exercised in Germany. Irrespective of

their specic activities, companies are deemed to generate business income.

(a) Determination of trade income

Trade income tax base is broadly the same as for corporate income tax purposes.However, it is modied by certain add-backs and deductions. As far as leasing is

concerned, the most important issues in this connection are:

• Add-back regarding costs for long-term debt; and

• Add-back regarding lease and rent payments.

To the extent add-backs are made in this respect, they increase the trade tax base and

are therefore subject to trade tax. It is therefore crucial that the eects of both issues are

addressed.

The add-backs include inter alia 25% of the sum of (i) loan remuneration (e.g. interest

expenses paid by the lessee) and (ii) 20% of lease expense in connection with an aircraftlease.





The add-back only applies to the extent payments exceed an exemption amount of€100,000.

(b) Treatment of trade tax losses

No loss carry back is available for trade tax purposes.

Trade tax losses (Gewerbeverlust ) can be carried forward and deducted from future tradeincome. The restrictions for corporate income tax also apply to trade tax. Up to a limit of

€1 million, losses carried forward may be fully set o against earnings trade tax income.Beyond this limit, losses carried forward may be set o against no more than 60% of the

trade income in the current period.

There is no time limit for the use of losses carried forward.

(c) Determination of applicable tax rate

The trade income tax base is multiplied by a basic tax rate (Steuermesszahl) of 3.5%,

resulting in the so called base amount (Steuermessbetrag ). The relevant multiplier( Hebesatz ) for each local municipality is applied to the base amount. These multipliers

typically range between 200 to 490%, i.e. a factor of 2.0 to 4.9, yielding a tax rate of 7.0to 17.15%.

(d) Cross-border-issues

As a German trade tax liability requires a trade business in Germany, the income of a

non-resident lessor is only subject to German trade tax, if the lessor maintains a Germanpermanent establishment and the aircraft is allocated to such German permanent

establishment.

3.6 Formal proceedingAny income derived from a lease in Germany must be declared in an annual income/corporation tax declaration of the lessor and in an annual trade tax declaration if the lessor

is subject to German trade tax. In principle, this applies also to a non-resident lessor whorealises income from German sources.

4 VAT

4.1 GeneralAll entrepreneurs (individuals as well as companies and partnerships) who are

independently engaged in a trade business with the objective of earning income are subjectto German VAT. VAT liability arises irrespective of citizenship, residence, principal place of

management or place of invoicing or payment. Any person who leases an aircraft in Germanywould be considered as an entrepreneur for German VAT purposes.

The standard German VAT rate is 19%.

4.2 Registration requirementsAny entrepreneur making taxable supplies in Germany is obliged to register for VAT

purposes. This also applies if the entrepreneur is not resident in Germany.

A single tax reference number is usually ascribed to an entrepreneur for all taxes including

VAT. On application, a VAT identication number is issued for each registered entrepreneur.





4.3 VAT exemption for supplies of goods and services to international airlinesUnder the German VAT Act, supplies of goods and services to approved international airlinesare exempt from VAT. Airlines which are resident in Germany have to be included in a list

of approved international companies published by the German tax authorities. Accordingto the ocial guidelines to the German VAT Act, non-resident airlines are assumed to be

international airlines for German VAT purposes.

4.4 VAT treatment of acquisition of aircraftUnless the exemption under 4.3 is applicable, a transfer of the aircraft is subject to GermanVAT if the eective transfer takes place when the aircraft is on German soil. Whether or not

the aircraft is registered in the German Aircraft register, is not relevant.

VAT is levied on the purchase price at a rate of 19%.

4.5 VAT treatment of leasingFor the VAT treatment of leasing services, it is crucial whether or not economic ownershipis transferred by the lessor to the lessee at the beginning of the lease term. For the

determination whether or not economic ownership of the aircraft is transferred, income tax/

accounting principles are generally applicable.

(a) Economic ownership resides with the lessor

The place of supply for a lease by the lessor to the lessee is normally where the lessee is

resident. Where the lessee is resident in Germany, German VAT is charged in addition to

the net rentals during the lease term. The German VAT amount on an agreed single netlease rental normally becomes due on the 10th day of the month following the agreed

payment date of the corresponding lease rental by the lessee.

The lessee normally gets a tax credit for input VAT paid (unless he conducts a business

that is not eligible for full credit such as banking, insurance, etc.).

Where a non-German resident lessor leases aircraft to a German resident lessee and theexemption under 4.3 does not apply, the reverse charge mechanism would be triggered.

If the lessee is entitled to a refund of input VAT, his payment obligation under the reverse

charge mechanism can be set o against the refund claim.

(b) Lessor transfers the economic ownership to the lessee

The transfer of economic ownership at the beginning of the lease term is considered asa supply of the aircraft by the lessor to the lessee. According to the current view of the

tax authorities, the tax base for calculating VAT is equal to the aggregate amount of therent payable (including (i) rent for a renewal period in the case of a renewable option and

(ii) agreed purchase price in the case of a purchase). The entire German VAT amount is

triggered at the end of the month when the aircraft delivery takes place, if (i) the aircraftis located in Germany at the time of the delivery and (ii) the transaction is not subject to

a VAT exemption. The German VAT normally becomes due on the 10th day of the monthfollowing the aircraft delivery.

(c) Sale-and-lease-back transactions

Where economic ownership (i.e. all economic risks and rewards attached to an asset)

resides with the seller (and the lessee) throughout the sale-and-lease-back-transaction,a supply and repurchase of the aircraft eectively is seen to take place for German VAT

purposes so that the whole arrangement should normally qualify as mere nancing by

the buyer to the seller.

Financing is VAT exempt if certain formal requirements are fullled.





(d) Penalties Penalties payable for a breach of contract are normally not subject to VAT.

5 Customs duties and transfer taxes

5.1 Customs duties and import VATCustoms duties and import VAT are applicable in accordance with European Union

principles. The import of an aircraft by a lessor from a place outside the European Union intothe European Union can trigger customs duties and import VAT. Potential import taxes and

compliance with European Union importation requirements should therefore be reviewed

prior to importation of the aircraft.

5.2 Transfer taxesThere are no specic transfer taxes such as stamp duties, registration taxes etc in connection

with aircraft leasing in Germany.

However, costs (charges of the German Aircraft Register and legal fees for advisers) in

connection with the registration of the aircraft in the German Aircraft Register may arise.



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Munich

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NORTONROSE - Taxation of Airfin in D

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