BBCWatcher
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My impression is global REIT also heavily taxed. Ultimately because we care only about after tax returns, and SREIT give higher return than global REIT. Higher tax is inconsequential. Do you prefer an investment that tax you 35% & still give you 10% return or tax you 10% but only give you 5% return?
Really ? I thought we need to pay 15% withholding tax for dividends of Irish domiciled LSE listed entity. Interesting.
Let's see if we can start looking into this beyond the superficial, but I'll say up front that this particular analysis is really hard....since there is withholding tax on LSE-listed REITs, it would be interesting to find out how the tax issue is dealt with for LSE-listed ETFs that hold such REITs.
DPYA looks like a promising candidate, Irish domiciled and London traded. It's an accumulating fund (which offers some inherent cost efficiencies), and non-U.S. persons resident in Singapore pay no individual taxes -- no dividend tax, no capital gains tax. Total expense ratio is 0.59%, which is pretty reasonable by Singapore standards. OK, so what does the fund manager pay (Blackrock iShares), and what do the underlying REITs pay?
If the REIT is U.S. domiciled, then the fund manager pays the 15% Irish treaty rate on dividends. (REITs domiciled in other countries will be subject to whatever the rate applicable to Irish domiciled funds is with that country.) DPYA's biggest holding is Simon Property Group REIT, symbol SPG on the New York Stock Exchange. Let's see what SPG pays.... OK, according to Simon's 2018 annual report, they pay zero in U.S. income tax because they've structured their affairs as a U.S. qualified REIT. They do pay some other taxes, notably property taxes and a little bit of foreign tax (they're U.S. domiciled but operate in more than one country), but unfortunately I don't see any total effective tax rate figures. (They say there was US$5 billion paid in property and sales taxes, but their tenants -- retailers, notably -- paid the vast bulk of the sales taxes, not SPG. So that's just a marketing number, not even in their financial statement -- it's just in the throwaway introductory text. And I'm highly confident they rolled up their tenants' total sales tax figure precisely because that number forms the vast bulk of the US$5 billion marketing number.) Anyway, to the level of investigation we can perform thus far, DPYA is subject to a 15% tax rate on the dividends associated with U.S. domiciled REITs, paid solely by the fund manager (and assuming DYPA is held by a non-U.S. person). The individual DYPA shareholder pays nothing.
Interestingly, if you were to hold SPG as an individual resident of Ireland, and assuming your ownership is not a big percentage (which it wouldn't be since SPG is huge), you'd enjoy a super preferential 5% treaty rate. You'd then presumably pay some more tax to your local tax authority in Ireland.
What about Singapore? Well, there's the Lion-Phillip SREIT ETF, symbol CLR on the SGX. CLR doesn't publish a total expense ratio, but they list a management fee of 0.50% and a trustee fee of 0.04%. So let's call that one even. Mapletree Commercial Trust is its biggest holding, or at least it was not too long ago. IRAS has granted a tax transparency concession (recently extended, but still with an expiration date) to CLR and other funds like it, so for non-U.S. individuals there's ordinarily no tax on dividends. Same thing for income from Mapletree.
....Consequently it seems there's a 15% dividend tax "gap" between distributions of U.S. domiciled REITs and Singapore domiciled REITs. But is that the end of the story? No, of course not. Real estate in Singapore is comparatively heavily taxed, and the REITs do pay taxes. (So do REITs elsewhere -- they all pay some tax, such as property tax. Well, OK, in other jurisdictions in some contexts some REITs have negative effective tax rates. Yes, that can happen.) And it's harder to find that data since we really need to see the total effective tax rates that these REITs pay, then roll that up to the fund level. Is the 15% "headwind" dispositive? No, not yet.
Mapletree does list its total property tax payments in its fiscal 2018, in its annual report. That figure is S$36,598,000. It distributed S$259,703,000 to shareholders in the same period, so its total effective property tax rate appears to be 12.4% (total property tax paid divided by the sum of property tax paid and total distributions). But their annual report also refers to a stamp duty bill of S$53,395,000, and it's hard to figure out how to allocate that....
....This is not easy! I don't think we have enough data to figure out whether S-REITs face more, less, or about the same total tax burden (in the whole "tax pipeline" to the end investor) than other REITs around the world. And how should we treat IRAS's expiration date on the fund transparency concession? I don't have a good answer to that question.
Fortunately, as I mentioned, the IRS makes my personal decision easy. For non-U.S. persons resident in Singapore, you'll have to take a guesstimate whether you think S-REITs enjoy a tax burden advantage, whether any such advantage (if it exists) is impactful enough, how you want to handle fund versus non-fund S-REIT investing, other investment costs, what overall exposure you want to real estate, and how concerned you are about local and regional risk concentration (and particular REIT concentrations if you choose individual REITs) within your portfolio. These issues are not easy to decide.
