Interest Deductibility for Purpose-Built Rentals: Budget 2024 Update for Canadian Businesses
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03 Jun 2024
Interest Deductibility for Purpose-Built Rentals: Budget 2024 Update for Canadian Businesses
Is your business dealing with rental housing? If that’s the case, then Canada Budget 2024 has good news for you – There is an expansion to the EIFEL rules (Excessive Interest and Financing Expense Limitation). What does this mean? It implies that there will be an elective exemption for the interest that is incurred on financing, which is used for building or acquiring eligible rental properties. The team of Real estate Accountants at CJCPA decided to break down the latest changes for its readers who have a rental property business in their province. Below, you’ll find the details of the new benefit, and how it may or may not benefit your business. Let’s explore the application details, and how it may potentially increase your tax savings. Let’s get started!What are the EIFEL rules?
Introduced in 2021, EIFEL rules target “earnings stripping”. It aims to prevent the use of this tax avoidance tactic, where companies often use excess debt, and shift profits to low-tax jurisdictions. Here’s how “earnings-stripping” works – Companies can borrow heavily from their subsidiaries in low-tax countries. This, when done, can effectively shift profits out of high tax jurisdictions by paying only the interest expenses. Due to this, the taxable income of these companies is reduced in high-tax countries. This rule particularly limits the amount of interest and financing expenses businesses deduct from their taxable income. Budget 2024 has made some changes. It recognizes that affordable housing is crucial and, thus, offers an exemption for certain types of financing. Consult with real estate tax services Canada to find out if EIFEL rules impact your business exemptions or not.What’s the exemption for purpose-built rentals?
With the budget 2024, the exemption range for businesses has expanded. Now, they can elect to exempt some interest and financing expenses that are related to arm’s length financing. Arm’s length financing – it means financing a business gets from a lender who is independent of the business, and there is no preferential treatment, or special relationship between the two. Note that this exemption is applicable for interest incurred before January 1, 2036. It is available only for two financing options:- Building new purpose-built rental properties
- Acquiring existing purpose-built rental properties
What’s the eligibility criteria for rental properties?
If you are thinking about claiming this exemption, it is better to first review the qualifications for it. Consult your accounting services provider regarding the same. The rental property of the business must meet the specific criteria that are aligned with both the “temporary GST New Residential Rental Property Rebate” and the “Accelerated Capital Cost Allowance”. Check below:- Minimum Unit Count: The property must have either:
- At least four private apartment units (with private kitchen, bathroom, and living areas)
- Or, at least 10 private rooms or suites
- Long-Term Rental Focus: At least 90% of the residential units must be held for long-term rentals (excluding short-term stays like vacation rentals).
What are some benefits and considerations related to this exemption?
With this exemption, businesses investing in purpose-built rentals can save money on taxes. Of course, they can reduce a larger portion of their financing interest, ultimately reducing their taxable income and lowering the tax burden. However, consider the following:- Elective Exemption: Given it is an elective exemption, businesses have to choose and use it while thinking of the impact on tax filing strategy.
- Recordkeeping: The business must also keep proper documents of their financing details and property use. It is an essential requirement for claiming the exemption when tax audits happen.