Advocacy

• Capital market depth.
• Greater investment choice, diversity and versatility.
• The ability to toggle between public and private markets.
• Easier cross-border investment.
• More market players.
• More certain rules and lower taxes.

The bottom line should be a larger and deeper real estate investment which should generate more investment opportunities.

In addition to REIT advocacy, APREA also engages governments in relation to:

• tax liberalisation – rationalising the number and impact of taxes that apply to real estate investment
• cross border investment – streamlining the process for international allocation and repatriating returns and capital  
• assisting governments develop innovative funding and financing mechanisms in relation to nation building programs, including infrastructure and affordable housing
• helping shape ‘fit for purpose’ international frameworks relevant to accounting standards, good governance, stewardship and ESG protocols, as well as voluntary industry standards.
• promote other ‘inclusive growth’ programs that support nation building.
• regtech solutions that will build certainty around property rights in emerging countries.

1. REITs and InvITs: Ongoing advocacy for calibrating the regulations to get the depth of the market and to make it successful for all stakeholders.
2. FPIs, Insurance Companies and Pension Funds: Allowing FPIs, insurance companies and pension funds to invest in debt securities of REITs and InvITs and to allow bank lending to REITs.
3. Making a case for treating REITs and InvITs at par with listed companies.
4. India Infrastructure and InvITs: A local committee was formed to take forward the agenda of infrastructure investments into India as the government has ambitious plans for the National Infrastructure Pipeline.
5. Submissions were made on indirect tax GST for real estate, infra and warehousing especially for input tax credit, JDA and TDR. A meeting is being sought with the Prime Minister's Office to step on the gas.
6. Best Practices for REITs and InvITs.
7. GST Critical matters to Infrastructure, Warehousing and Real Estate
     *   GST on development rights transferred pursuant to joint development agreements ("JDA") for commercial real estate projects;
     *   GST on transferable development rights ("TDR");
     *   Restriction on availment of input tax credit for developers engaged in renting or leasing of commercial spaces;
     *   Payment of GST on receipt basis (as opposed to accrual basis) or adjustment on account of subsequent bad debts;
     *   GST rates and exemption in case of residential projects; and
     *   GST exemption on long term lease of land for commercial and residential (Post OC sale) projects
8. Other FPI matters

Housing and Infrastructure
Propose innovative funding and financing mechanism (including securitisation)

Shenzhen - Hong Kong connect mechanism
Remove barriers to the inclusion of real estate in the “connect” mechanisms.

Shanghai - Hong Kong connect mechanism
Remove barriers to the inclusion of real estate in the “connect” mechanisms.

Mandatory Provident Authority
Liberalise the rules that currently limit a Hong Kong citizen’s ability to allocate, more real estate to their mandatory pension account

Automatic Exchange of Information (AEOI)
Propose a more efficient compliance system for REITs that aligns to international practice.

Insurance companies and real estate
Remove barriers to insurance companies investing in eligible the real estate (in particular, REITs and InvITs)

Foreign investment rules
Streamline cross border and repatriation rules for real estate – remove cash traps

Foreign Property Investors (FPI) regime
Enable efficient access to corporate bonds for real estate purpose

Property rights
Work with governments and other stakeholders to fast-track a trusted land rights and title registration system, utilising innovative regtech strategies where viable.

In addition to REIT advocacy, APREA also engages governments in relation to:

• Re-boot REITs to turbocharge economic growth
• Commit to a new deal to revitalise cities in the Philippines
• Connect the Philippines with smart infrastructure
• Introduce a plan for sustainable and resilient
• Launch national housing solutions that delivers affordability and choice
• Promote the Philippines as a business investment hub
• Unlock the archipelago’s tourism opportunities
• Cut red tape and increase contractual certainty

Fund structures (and tax efficiency)
APREA promotes tax efficient fund structures for real estate investment holdings.

This includes incorporating real estate in such legislation as the Asia Region Funds Passport and Singapore Variable Capital Company (S-VACC) regimes.

In all cases, we aim to ensure an even playing field between different types of managers across different jurisdictions.

REIT regulations
The Singapore Government and stock exchange regularly seek APREA’s views on the nation’s evolving REIT regime.

Recent discussions relate to internal-external management, income support, valuation methodologies, etc.

Our approach is to maximise the long-term potential of the Singapore REIT market and to ensure all key stakeholders are appropriately incentivised. ​

Singapore Stewardship Principles (SSP)
APREA supports the Singapore Stewardship Principles (SSP) as a fundamental leap forward in fostering a healthy, efficient and trusted capital marketplace.

The SSPs set out seven voluntary guiding principles which address clarity of investment intentions, enhanced engagement and collaboration between asset owners and managers, transparency, conflict resolution and corporate citizenship.

The SSP was developed by a high-powered group of prominent stakeholders, including APREA, and is supported by the Monetary Authority of Singapore and the Singapore Stock Exchange.

International accounting standards

• APREA works with REESA – the Real Estate Equity Securitisation Alliance – on the following projects
• FFO/AFFO/ACFO reporting conventions
• EBITDA conventions
• Business combinations project
• Primary Financial Statements project
• Sustainability Accounting Standards Board/Real Estate Sustainability Council ‘code’

International real estate measurement standards

• APREA supports the development of international standards via the International Property Measurement Standard Coalition, which is actively developing global measurement conventions

International real estate ethics principles

• APREA is a member of the International Ethics Standard Coalition, which is developing the first set of globally recognised ethics standards for property and related professional services.

  www.ies-coalition.org