Before making any argument, let's refer to the following numerical example for the illustration of financial projection of real estate project including calculation of IRR.
It was reasonable to presume readers to have basic accounting background and knowledge of all PRC taxation relevant to real estate project, such as Business Tax, Deed Tax, Land VAT, etc.
Again, please be reminded that all figures of sale and cost quoted below were for illustration purpose, of which the reasonableness should not be questioned.
Suppose that:
(1) one newly set up project company was 100% owned by one developer;
(2) the parent company can provide equity finance to the project company at any time, hence no external finance was required;
(3) the project company acquired land right from government at time 0 which was located in a city of PRC.
(4) the development period will last for 4 years.
(5) the development cost will be paid equally in each FY.
(6) the progress of cash sale will be equal in each FY.
(7) there is no prepayment from customers because of lack of decoration.
(8) Operating Data:
total revenue of project = 4 Bn (by assumption)
total development cost other than land cost = 0.5 Bn (by assumption)
total operating expense = 0 Bn (by assumption)
total Land Cost = 1.4 Bn (byassumption)
Then, the calculation of tax payable relevant to real estate project except for Stamp Duty (in Chinese"印花税") was shown as below:
(1) total Deed Tax (in Chinese"契税") of land acquired = 1.4 Bn*3% = 0.042Bn
(2) total Business Tax (in Chinese "营业税") = 4 Bn*5% = 0.2 Bn
(3) Sum of Tax for Maintaining and Building Cities (in Chinese "城市维护建设税"),Education Supplementary Tax (in Chinese "教育费附加") and Local Education Supplementary Tax (in Chinese "地方教育费附加")= 4 Bn*5%*10% = 0.02 Bn
(4) Computation of total Land VAT (in Chinese "土地增值税"):
(4.1) total Land Value Added = taxation income - recognized land cost -recognized development cost - recognized operating expense - recognized additional deductible - any taxes relevant to project
= 4 - (1.40+0.042) - (0.5) - (0)- (1.40+0.042+0.5)*20% - (0.2+0.02)
= 1.4496 Bn
(4.2) total deductible item's sum
= (1.40+0.042) + (0.5) + (0) +(1.40+0.042+0.5)*20% + (0.2+0.02)
= 2.5504 Bn
(4.3) total Land Value Added / total deductible items
= 1.4496 / 2.5504 = 57%
(4.4) total Land VAT payable
= 1.4496*40% - 2.5504*5% = 0.45232Bn
(5) Computation of total Corporate Income Tax (in Chinese "企业所得税"):
(5.1) Taxation Profit of each FY
= 4*25% - 1.442*25% - 0.5*25% -0.22*25% - 0.11308
=0.34642 Bn
(5.2) total Corporate Income Tax of each FY = 0.34642*25% = 0.086605 Bn
the Cashflow data of project:
at time 0: (1.442) Bn
at time 1: 0.620315 Bn (4*25% - 0.5*25% - 0.22*25% - 0.45232*25% - 0.086605)
at time 2: 0.620315 Bn
at time 3: 0.620315 Bn
at time 4: 0.620315 Bn
IRR = 25.89%
Besides, the assumptions adopted by previous example should be criticized by following reasons:
(1) most project companies are heavily leveraged of which the deductibility of finance cost depends on the form of financing, such as shareholder’s loan, loan borrowed from nature person, loan borrowed from FI,etc, as the corresponding tax treatment when calculating land VAT and Corporate Income Tax depends on form of financing in accordance with relevant PRC tax laws.
(2) project companies usually collect down-payment once the S&P agreement was signed, and rest of AR will be settled till developers deliver the sold apartments,so that settlement of sale receipt is not in line with accounting sale and taxation sale (also applicable in the case of prepayment).
(3) sometimes, some costs allocated to project cannot be deductible when calculating Land VAT and Corporate Income Tax, which make tax computation even more complicated.
(4) In practices, whenever project companies has taxation profit or loss, project companies must prepay Land VAT and Corporate Income Tax in each FY. Accordingly, the prepayment of Land VAT and Corporate Income Tax results impact on net cashflow pattern.
With reference to the example as said before, I hope that you can understand the complication of calculating IRR of real estate project, even if lots of assumptions being made in previous example, on which any proposed business decisions, including but not limited to decoration of apartment before sale, may have adverse or constructive effect.
Also, I am sure that readers can code up situations, by altering the assumptions and parameters, to support the claims that “if selling decorated dapartment, IRR of ONE specific real estate project will be enhanced”, and “if selling decorated apartment, IRR of ONE specific real estate project will not be enhanced”.
What I am trying to emphasize was that the financial projection must be revised for each proposed business decisions to determine whether IRR and net cashflow pattern is improved.
To me, the statement "精装修都会有助于IRR的",claimed by you, implies that “if selling decorated apartment, IRR of ANY real estate projects must be enhanced”. But, as discussed before, there is no causation relationship (in Chinese "因果关系") between selling decorated apartment and IRR of ANY projects since that business decision may have adverse or constructive effect on IRR.