Exploring the different approaches to taxing PPP and PFI vehicles

Paul Bartlett
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Abstract

The focus of public–private partnerships (PPPs) and private finance initiatives (PFIs) remains, as it has from their inception in 1992, firmly on the provision and maintenance of public sector property assets such as schools, hospitals, social housing and civil engineering projects including ‘Design, Build, Finance and Operate’ roads. Many of the techniques used in financing PPP and PFI transactions are common to real estate projects. It is likely therefore that the tax issues and consequent solutions developed for PPP and PFI transactions will have increasing relevance to the property investment industry, particularly as the principles of PFI become more common in the private sector. The purpose of this paper is to explore the different approaches to taxing PPP and PFI project vehicles and provide an update on the latest developments in their taxation. This is a topic which has been brought into focus by the high tax rate suffered by early PFI projects which are now reaching maturity and the consequent effect this has on shareholder returns. In response, the industry has, in partnership with the Inland Revenue, sought greater certainty over the tax treatment of PPP and PFI projects. Changes to key parts of PFI contracts and the way in which services are delivered can result in a much lower effective rate of tax for PPP and PFI projects. Copyright © 2004 Henry Stewart Publications

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探索对PPP和PFI车辆征税的不同方法
公私伙伴关系(ppp)和私人融资倡议(pfi)的重点仍然是提供和维护公共部门的财产资产,如学校、医院、社会住房和包括“设计、建造、融资和运营”道路在内的土木工程项目。许多用于PPP和PFI交易融资的技术在房地产项目中很常见。因此,为PPP和PFI交易制定的税收问题和随之而来的解决方案很可能与房地产投资行业越来越相关,尤其是在PFI原则在私营部门越来越普遍的情况下。本文的目的是探讨对PPP和PFI项目工具征税的不同方法,并提供其税收的最新发展。早期PFI项目所遭受的高税率现已达到成熟,这对股东回报产生了随之而来的影响,这一主题已成为人们关注的焦点。作为回应,该行业与税务局合作,寻求对PPP和PFI项目的税收待遇有更大的确定性。改变PFI合同的关键部分和提供服务的方式可能会导致PPP和PFI项目的有效税率大大降低。版权所有©2004 Henry Stewart Publications
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