CG malls europe - Commerz Real
CG malls europe - Commerz Real
CG malls europe - Commerz Real
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26<br />
6.2.1 Service and Management Charges<br />
Service and management charges paid by the tenants include revenues on the one hand,<br />
and expsenses on the other hand. In most cases, these charges are posted in the financial<br />
accounts of the property companies. In some cases, the tenants pay these charges<br />
into a separate account of the centre management companies where these charges are<br />
cleared. In these cases, the charges are not covered by the accounting of the property<br />
companies. To ensure the comparability of all assets, charges are not reflected in the<br />
adjusted return figures.<br />
6.2.2 Intra-Group Loan<br />
The loan over EUR 90.7 million that was taken out by Montijo Lda. has in part<br />
(EUR 42.7 million) been passed on to Almada Lda. in the form of a so-called intra-group<br />
loan. The interest expenditures shouldered by Montijo Lda. are offset by the interest income<br />
for the intragroup loan as component of the gross income. On the Almada Lda. side,<br />
the interest payments are posted as loan expenditures under expenses. The Fund’s GAAP<br />
figures have been deconsolidated to exclude the interest income in the case of Montijo<br />
Lda. and to exclude the interest expenses of Almada Lda. To ensure comparability, the<br />
deconsolidated interest expense was posted as interest expense for Almada Lda. again,<br />
while the interest income was posted as “negative” loan expenditure for Montijo Lda.<br />
6.2.3 Withholding Tax on Interets for Shareholder Loan in Portugal<br />
The Portuguese inland revenue service retained 15% – or 5% as at 01 July 2009 – in<br />
withholding tax on the shareholder loan interest that Almada Lda and Montijo Lda pay to<br />
<strong>CG</strong>M Lux 2 and <strong>CG</strong>M Lux 3. The payors of the withholding tax are <strong>CG</strong>M Lux 2 and <strong>CG</strong>M<br />
Lux 3, respectively. In 2007 and 2008, these payments were posted in the performance<br />
account as tax debt of the fund companies (<strong>CG</strong>M Lux 2 and <strong>CG</strong>M Lux 3). In order to trace<br />
the expenditures connected to the ownership of property interests with more precision,<br />
the Fund Management decided to attribute the withholding tax dues to the respective<br />
property interest whose structure or activities incurred them. In 2009, withholding taxes<br />
on shareholder loan interest amounted to EUR 355,935.58 in the case of Almada and to<br />
EUR 255,339.48 in the case of Montijo.<br />
6.2.4 Income Tax on the Income Distribution of Almada Cda.<br />
<strong>CG</strong>M Lux 3 in Portugal will have to remit 26.5% in income tax on the income distribution<br />
that Almada Cda. pays out to <strong>CG</strong>M Lux 3 because of the 30% interest held by the<br />
latter. Payor of this income tax is <strong>CG</strong>M Lux 3. In 2007 and 2008, these payments were<br />
posted in the performance account as tax debt of the <strong>CG</strong>M Lux 3 fund company. In order<br />
to trace the expenditures connected to the ownership of property interests with more<br />
precision, the Fund Management decided to attribute the income tax dues to the respective<br />
property interest whose structure or activities incurred them. In 2009, an income<br />
tax debt totalling EUR 255,709.02 was due for the distribution of Almada Cda.