Commercial Property Purchase Price Allocations
The purchase price is only the starting point.
Commercial property transactions frequently involve multiple classes of assets with different tax treatments.
The purchase price allocation rules under sections GC 20 and GC 21 of the Income Tax Act 2007 introduce important considerations for both purchasers and vendors.
Establishing an appropriate allocation requires identifying the assets transferred and supporting the values attributed to them.
This is particularly relevant where a transaction includes land, buildings, separately depreciable fit-out, plant and machinery, and other property assets.
Where Valuit adds value
Valuit provides specialist asset identification and valuation assessments to support commercial property purchase price allocations.
Our work may include:
Asset identification
Identifying relevant assets and components within the property.
Ownership considerations
Reviewing available information, including leases, to help establish whether relevant fit-out belongs to the landlord or tenant.
Asset valuation
Establishing supportable values for identified assets using appropriate valuation methodology.
Classification considerations
Assessing asset characteristics relevant to determining whether items are separately depreciable or form part of the building.
Documented reporting
Providing valuation information to support the proposed allocation and subsequent tax analysis.
Why does the allocation matter?
For purchasers, the allocation may establish the tax cost of qualifying depreciable assets.
For vendors, it can affect depreciation recovery income and other tax consequences.
Where the parties agree on an allocation, the relevant PPA rules can restrict their ability to subsequently adopt different values.
A valuation completed before the allocation is finalised can provide important supporting information.