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How tax policies create unexpected results when interest rates are low: A case study of Finnish housing company debt and private investor return1

By:
Open Access
|Jul 2022

Figures & Tables

Different ways of handling charges_

Funding chargesRecognising charges
In accountingTreated as capital.Treated as income.
In LLHC taxationNo effect until the funding is ended, and then all funded charges are taxed.Treated as taxable income.
Can be used to cover costs or loan paybacksNot without ending the funding.Yes. The only way to do so if the LLHC does not have other income sources.
For an LLHC shareholder who lives in the flatMonthly fee, not tax-deductible.Monthly fee, not tax-deductible.
For an LLHC shareholder that lets the flat forward (investor)Monthly fee, not tax-deductible.Monthly fee, tax-deductible.
The tax effect for LLHC shareholder that lives in the flat when the flat is soldFunded charges are added to the acquisition cost of the flat, therefore decreasing taxable profit.No effect.
The tax effect for the investor when the flat is soldFunded charges are added to the acquisition cost of the flat, therefore decreasing taxable profit.No effect.

Application of different tax laws in Finland_

Income tax lawBusiness taxation law
The legal form of entity Incomes taxedPrivate and legal entities.Natural and legal persons.
All incomes that are not taxed according to other business laws.Business income.
Applicable to undertakings (see, for example, Kukkonen and Walden 2015, chapter 5)Yes, if they have other than business income, ie income from owning shares of a listed company and if they are not an investment company.Yes.
Applicable to private personsYes.Yes, if their way of earning is closer to active business than earning a wage or investing their savings.
Applicable to housing investmentsIn most cases, yes.In cases where owning flats and property is actually an active business, which requires a significant number of flats (Ossa, 2013).
Treats legal entities and private persons differentlyYes, some tax advantages are only applicable to private persons.No.

Different options_

OptionFunding or recognitionPresumed acquisition costSale profits equationLetting profits equationRequirement
1RecognitionYes264OT × (FTFI) ≥ 1.5 × A
2RecognitionNo244OT × (FTFI) ≤ 1.5 × A
3FundedYes266OT × (FTFI) ≥ 1.5 × A
4FundedNo246OT × (FTFI) ≤ 1.5 × A
Language: English
Page range: 45 - 57
Submitted on: Feb 10, 2021
Accepted on: Nov 8, 2021
Published on: Jul 13, 2022
Published by: DJØF Publishing, Nordic Tax Research Council
In partnership with: Paradigm Publishing Services
Publication frequency: 1 times per year

© 2022 Eelis Paukku, published by DJØF Publishing, Nordic Tax Research Council
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 License.