Finansal kiralama şirketlerinden teşvikli finansal kiralama uygulaması
The Application of incentive financial leasing in leasing firms
- Tez No: 75607
- Danışmanlar: YRD. DOÇ. DR. CEMİL ALBAYRAK
- Tez Türü: Yüksek Lisans
- Konular: Mühendislik Bilimleri, İşletme, Engineering Sciences, Business Administration
- Anahtar Kelimeler: Belirtilmemiş.
- Yıl: 1998
- Dil: Türkçe
- Üniversite: İstanbul Teknik Üniversitesi
- Enstitü: Fen Bilimleri Enstitüsü
- Ana Bilim Dalı: İşletme Ana Bilim Dalı
- Bilim Dalı: İşletme Mühendisliği Bilim Dalı
- Sayfa Sayısı: 121
Özet
ÖZET Ülkelerin refah düzeylerinin artırılması, üretimin arttırılmasına bağlıdır. Üretim artışı ise hem mevcut üretim kapasite kullanım oranlarının yükseltilmesi, hem de yeni kurulacak tesislerle mümkün görünmektedir. Bu şekilde yapılacak yatırımlar, çoğaltan ve hızlandıran etkileriyle istihdamı arttıracak, bölgeler arası dengesizlikleri giderecek, sermayenin tabana yayılmasını temin edecektir. Bu ilkeler ışığında yatırımların, kamu otoritesi tarafından belli bir disiplin dahilinde teşvik edilmesi doğal ve gereklidir. Ülkemizde Hazine Müsteşarlığı tarafından uygulaması yapılan teşvik mevzuatı, esas olarak yapılmakta olan yatırımlara dolaylı destekler vermektedir. Verilen teşvikler, yatırımın aşamalarına göre bazı istisnalar dışında gayrinakdi bir özellik göstermekte ve yatırımcının nefes alması sağlanmaktadır. Yatırım teşvikleri, proje bazında verildiği için bunların finansmanında fınansal kiralama yöntemini kullanmak mümkündür. Öte yandan teşvik belgesi kapsamında verilen yatırım indirimi desteği, vergi otofınansman etkisi sağladığı için özellikle yeni yatırımlarda olmak üzere, çoğu zaman yatırımcılar tarafından etkin bir şekilde kullanılamaz iken, gelişmekte olan ülkemiz için çok önemli olan bu yatırımları fonlayan finansal kiralama şirketleri için aynı ifadeyi kullanmak mümkün değildir. Finansal kiralama şirketleri, özkaynaklan ile birlikte yurt içi ve yurt dışında bulunan banka ve finans kuruluşlarından edindikleri fonları, finansal kiralama işlemleriyle plase etmektedirler. Özkaynak yoğun plasmanlar yapan bir finansal kiralama şirketi enflasyonist bir ekonomi ve yüksek vergi oranlan sebebiyle sermayesini tahrip etmektedir. Dış kaynak yoğun plasmanlar yapması durumunda ise yüksek vergi oranlan, enflasyon, fon ve işletme maliyetleri ile piyasa riski, faaliyetleri üzerinde büyük bir baskı oluşturmaktadır. Tüm bu sebeplerden dolayı finansal kiralama şirketleri çok önemli bir vergi kalkanı olan yatırım teşvik belgelerine ihtiyaç duymaktadırlar. Finansal kiralama şirketlerinin teşvikli yatırımları fonlaması durumunda, yatırım indirimi oranının %100, yatırımın/finansal kiralama işleminin yapıldığı tarih ve finansal kiralama şirketinin halka açık olup olmaması temel değişkenler olması koşullarıyla, halka açık finansal kiralama şirketlerinde; Ocak ayında yapılan işlemlerde, yatırımın %7,45 kadarı; Aralık aynda yapılan işlemlerde, yatırımın % 15.67 kadar, halka açık olmayan finansal kiralama şirketinde ise işlemin aynı aylarda yapılması durumunda, sırasıyla yatınmın %8,25 ila 17,.36 kadarı vergi anlamında tasarruf etkisi doğurmakta, başka bir deyişle, finansal kiralama şirketine ek/gizli bir karlılık sağlamaktadır.
Özet (Çeviri)
SUMMARY THE APPLICATION OF INCENTIVE FINANCIAL LEASING IN LEASING FIRMS Every investment -in line with a coefficient- increases the national output and decreases unemployment. The effect of investment purchases is called as“Multiplier Effect”. In most cases, investments not only increase the incomes and purchasing power of consumers, but also they encourage the new investments. Thus, with the increase in national output, new investments lead a variety of operations. This is called as“Acceleration Effect”. Because of these two effects mentioned above, investments have a great importance in both developing and developed countries. Because expected economic growth to be realized and decreasing unemployment rate to lower levels are tied to the volume and the distribution of investments. The investments in various areas in private sector of Turkey are supported by subsidies. The principal aims of these subsidies are as follows: 1. Distribution of capital among general public: In line with this aim, related to finance of small and medium sized companies, various communiques are published and taken into operation. 2. Overcoming to inequalities in different regions: For this aim, in 1998, a communique is presented related with the assignment of treasury areas for industrial production in east and south east region of Turkey. For these type of companies, government subsidies are 50% of electric energy they consumed. 3. High tech: for the efficient use of resources in Turkey, and for producing high-tech goods, the target is to update the production technologies of companies. 4. Increasing the foreign exchange reserves: Investments lead to increase in production. Thus there is an opportunity of providing import substitution and by exporting to foreign countries, the foreign exchange reserves of Turkey increase. 5. Creating employment: Investments by the new and capacity raising affects encourage employment directly whereas by the goods circulation, they encourage employment indirectly.Incentive Certificate is one that includes characteristic features of investment, in the case of realization it gives the opportunity of providing the written supports to the entrepreneur. Incentive Certificate form is in line with development plan and is accepted by undersecretary of treasury. For the preparation of Incentive Certificate the minimum amount of fixed investment must be 25 billion Turkish Liras in the regions given priority for industrialization and 50 billion Turkish Liras in other regions. Benefiting from supports and subsidies are evaluated in three categories: 1. Developed areas: The incentive certificate is not given for the cities like Istanbul, Kocaeli, Ankara, İzmir, Bursa, Adana and Antalya. 2. The regions given priority for industrialization: The regions are indicated by council of ministers. 3. Normal regions: Regions other than developed and priority regions. The tools of incentive named by public authority are as follows: ? Customs duty exempted and exemption from collective housing fund ? The discount in investment ? Postponement in value added tax in import ? VAT support in domestic machines and equipment ? Exempted tax, customs duties ? Energy support ? Land assignment ? The assignment of credit from fund The well-being of a company in long term and adaptation of company to the changes in technology, economy and social factors depend on its planned investments. The selection of the subject and technology of investment, finding out the land for the company or company's extension and determining on the capacity of production are the restrictions for the firm. For this reason, the realization of investments in companies as planned has great importance. Investment project can be named as an entrepreneurship aiming at producing a good or service. The types of investment projects are categorized as indicated below: I. NEW INVESTMENTS: The most important characteristic of a new investment is that a company enters into a new area of operation at the first time. The biggest problems in new investments are the difficulty in finance of investments and production, finding out technical personnel and adaptation to the market structure. The most common reality with which Turkish entrepreneurs can face with is the lack of fixed capital and in later stages of production, the lack of capital in order to run the business.2. WIDENING INVESTMENTS: Within the production technology and market structure, companies, in order to evaluate their value added and increasing demand, go into an increase in capacity to maintain quality and quantity of their product. In this perspective, expanding investments include the capacity increasing investments. 3. FINISHING AND EXTENSIONARY INVESTMENTS: Finishing and extensionary investments which are not realized as new production or capacity increasing type of investment, state overcoming bottlenecks, quality improvement, modernization and renovation investments. In this point, it must be stated that there are transparent lines between the extension investments and the others. Overcoming bottleneck investments are explained in a way that they remove the inequalities between machine capacities and waiting time of machines in stations. Increasing or improving the quality of goods produced and services is called quality improvement investment. The investment decisions regarding to changing of machines and equipment that loss the characteristic of being economic and profitable because of the technological changes are called modernization investments. In Turkey, it is a reality that the firms in crisis are financed by wrong Asset-Liability Management and short term debts. In this situation, it is convenient to use the sources with appropriate cost and appropriate time-schedule and assets must be mostly used in liquidated assets. From this point of view, the ways of finance of investment goods are as follows: STOCKHOLDERS' EQUITY: Finance of investments from Stockholders' equity means that there is no obligation of repayment of debts and there is no cost item. Although finance from stockholders' equity has no cost item, because of the two factors mentioned below, finance from Stockholders' equity may be irrational. 1. The insufficiency of Stockholders' equity in order to match the current capital of the firm. 2. The possibility of higher auto-finance of tax in other ways of finance. There are two effects of investment from stockholders' equity in terms of tax auto- finance: Depreciation and investment discount. BANK CREDIT: The most important foreign source is bank debts in terms of liabilities. If the short term bank credits are used in investment finance, then the firm will go into a financial crisis. In this case, the principle of matching asset finance with the same length of time in liability is not neglected.Investing by bank credits with incentive certificate, there will be three variables creating tax auto-finance effect: Depreciation, investment discount and interest rate of bank credits. TIME DOCUMENTARY CREDITS: The assets obtained from export insurance companies such as Hermes in Germany, Sace in Italy, Coface in France Serg in Switzerland, NCM in Holland are used in imports of investment goods. There are three variables creating the possibility of auto-finance in the time documentary credits: Depreciation, investment discount and interest rate expenses. It is not so much different from the use of bank credits, but it is different from bank credits that it provides the volatility in time and possibility of owing with appropriate costs. LEASING: In case an investment has been realized with financial leasing method, it is obtained leasing expenses including tax auto-finance source financial costs. As a definition of word, leasing is to rent. This is a transaction that a lessor purchase a good fitting the requirements of a company in a lessee position and allocate it to the use of the lessee for a certain period. It can be seen that it has been defined financial leasing with a restricted meaning by the Turkish law when compared to the concept leasing in the finance literature. In compliance with the Financial Leasing Law No: 3226, a financial leasing agreement is defined as a contract that a lessor leaves the possession of the property to the lessee that he obtained by purchasing from a third party or in any other way upon the choice and application of the lessee as to supply every kinds of utility and not to abolish for a certain period. There are four sides in a leasing transaction: The supplier, leasing company, lessee and the public authority. On the other hand, the benefits obtained by the lessee due to a financial leasing transaction is as follows: The Preservation of Working Capital: An increment in utilization of labor and power will occur besides additional input necessity, in case of using new, expanding or any other kinds of investment. In this case, the finance of these inputs is possible in the most suitable way of using leasing method in financing of the investment. Maturity Advantage: As leasing is used in financing investment goods, it is mid-term financial instrument as a result of its nature. VAT Advantage: The“VAT for fixed assets dependent on depreciation”paid in purchasing investment goods is 1 5% except certain exceptions. However, The VAT for the same fixed asset is 1% when it is purchased by a leasing company. This situation can be commented as the government incites leasing.The Effect of Recording as an Expenditure: The most important advantage of leasing for to lessee is expense effect. Because of this reason, most of the time it is the most rational decision to prefer leasing rather than purchasing of a fixed asset for the company's working with high value added without finance necessity. The Variation of Leasing Payments: Financial leasing contracts frozen with a fixed monthly interest rate. However, because the interest rate of bank credits are variable this causes to uncertainty in the cash projects of the companies. Balance Sheet effect: Because the transactions of financial leasing are off-recorded, this causes the company's financial ratios seem better than they are. The Quantity to be Leased: The investor may wish to make an advance payment by regarding the tax saving effect. However, although it doesn't exist a generalized application decision, the Ministry of Finance has an opinion that leasing transactions with very high advance payments is concerned with tax smuggling rather than leasing request. Guarantee: In leasing transactions, leasing company generally doesn't ask for an additional guarantee from the lessor. Besides, the leased equipment is recorded in the assets of the leasing company, in case of sequestration to the lessor for any reason, leased equipment cannot be confiscated. The company can continue to production under these circumstances. In a leasing transaction the benefits obtained by the lessor are as follows: 1. The lessor can completely benefit from the depreciation, revaluation, investment reduction, reduction of VAT which came out by purchasing a fixed asset for leasing purpose. 2. The lessor can place the fund he obtained with low cost by crystallizing with fixed asset basis by adding a profit. That is the reason why leasing companies are financial institutions in principle. 3. As the assigned credit limits are used in compliance with their purposes the default risk has been minimized. By this means, unless it's a wrong machinery choice in question, the investment increases the existing capacity and helps the increment of value added that the company constitutes. Operationally, leasing companies purchase and lease the capital goods. While, on the one hand lease payments made on leasing arrangements are considered taxable income for the lessor, on the other hand lessor can reflect the financial cost expenses to their financial statement and put depreciation expense on the capital equipment and machinery leased by themselves. As could be clearly seen, although they are financial companies in nature, leasing companies are different from the industrial companies from the perspective of financial statements. As a matter of fact this practice has been affected negatively, the profitability of leasing companies and so it has been imposing tax on their shareholders capital, Therefore, leasing companies need some expense items to be able to conserve themselves against taxes as a result of unreal revenues. XIVOn this occasion, the most important item is investment discount exemption. Because profit is positive difference between sale and purchase, it has to be difference between placement profit and financial cost. Article 1.7 of the Communique on the application of resolution on“State support for investment and investment incentive funds”states that:“Machine and equipment subject to financial leasing contract can be leased to anther lessee who has incentive certificate in case primary lessee does not make rental payments”In this case Undersecretary could make necessary modification on the Certificate. This Article has filled a big gap practice. Leasing companies prefer to make placements to projects having investment incentive because these projects provide tax minimization facility for. It is essentially important to know that how much tax redemption is provided by a project with incentive certificate. It is envisaged that leasing company utilizes its funds with a 7% return, under this condition the tax benefit and disguised profits to the leasing company are calculated. Corporate tax is paid with 3 equal installments after giving a declaration following the end of the year in April. Payments of the installments are done in April, July and October. Corporate tax is 25% of the profits base regardless of the company being open to public or not. Income withdrawal tax rate is 10% for open-to-public companies and 20% for others. On the other hand investment incentive income tax withdrawal rate is 10% for open-to-public companies and 15% for others. It is evident that being open-to-public is encouraged by low tax rates. The tax reductions which are used by leasing company are brought to the net value at the date of investment and deducted from the invested amount. Hence, by way of dividing the visible investment amount by real placement we obtain disguised profitability ratio. Depending on the timing of leasing investment throughout the year disguised profitability change between 7,45 (In January) and 1 5,7 (in December). In the non-open-to-public companies the rate of disguised profitability is between 8,25 and 17,36. Thus, in the implementation of investment incentive, non-open-to-public companies gain more because of their not being able to benefit from investment-tax- reductions. These results in a greater auto-finance effect for the non-open-to public leasing companies. XV
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