Tax Rates on P2P Lending – Low versus High

One important aspect for p2p lending investors is tax. In this blog whenever I talked about yields achieved, it is usually pre-tax yield. That is because taxation varies significantly from country to country. In most cases the place of residency of the investor determines the tax regime applicable. There are a few exceptions, e.g. on very few marketplaces withholding taxes are applied.

But I wanted to give a viusal overview on how different tax rates are for p2p lending investors, depending on where they live in Europe. Therefore I created for following map.


For overview purposes only. Source: own research – may contain errors or be outdated. Please note that this is a simplification and will not cover many cases. Do not make any decisions based on this, but rather consult a qualified tax advisor

In the countries colored in black the income tax rate is applied on interest earned on p2p lending investments. That means the individual rate of taxation depends on the other and overall income of the investor. For example in the UK the tax bands are 20%, 40% and 45% dependent on overall income. In Ireland tax bands are 20% and 40%.

But in most other countries there is a fixed rate applicable for interest earned on p2p lending. Tax free allowance up to a certain amount may apply. For example in Germany taxation (Kapitalertragssteuer)  is 26.375% (a little higher if church tax applies).

Taxation is complex. Futher important points are whether defaults and fees can be offseted against interests earned. Also capital gains (e.g. from selling loans with a premium on a secondary market) may be taxed different than income.

Advantageous tax rules

There are many special tax rules and tax breaks. Consult a qualified tax advisor for information on your situation. Here are just some interesting examples.

UK: UK residents can invest through so called ISA products. There is a special IFISA (Innovate Finance ISA) which can be used to invest up to 20,000 GBP tax-free on peer to peer marketplaces. More information and an IFISA comparison is here. The interesting point is that the allowance is available per year. That means an investor using it in 10 consecutive years can invest 200,000 GBP tax-free into p2p lending.

Estonia: Many Estonians lend through a limited company (OÜ) they have set up. The advantage there is , that as long as the earnings stay in the company they are not taxed. Only at the time the profits are paid out from the company to the investor they are taxed at 20%. This allows investors to postpone the taxation for a long time.

Netherlands: The Netherlands are the only country in Europe where the tax is not based on actual p2p lending earnings, but rather fictual earnings. Wait. What? The tax system is actually a wealth tax, and the tax declaration is not based on income but wealth. The tax authority then assumes you earned a fictual income of 4% on your wealth. Tax rates used to be 30% on that (so 1.2% on your wealth; since 2017 it is now 0.581 to 1.68% dependant on amount of wealth). Now if you actually earned 10% ROI with your p2p lending your effective tax rate calculated on that would be 12% (30%*4%/10%). That’s what I used for simplification purposes in the map.

Portugal: In Portugal the rate is 28%. But if a foreign resident moves to Portugal and earns interest only from p2p lending market places abroad, he can profit from a 0% tax rate on these (providing the originating country does not tax the interest) for 10 years. Mark explains his personal experiences with this on obviousinvestor.com. There are non-resident/non-domiciled rules in other Euopean countries but they usually sound more complicated/restrictive.

Hint to platforms: It may be efficient to target countries in your marketing that have a high GDP but also a low or medium tax rate on p2p earnings.

This article does not provide tax advice

Collateral Case the Next Step: BDO’s Joint Administrators’ Proposals

BDO has prepared and emailed the Joint Adminstrators’ Proposal to investors and creditors of the Collateral Companies last night. The report is also available publicly on the BDO website. I have read the whole report. I will not attempt to summarize it, but point out some findings that I find personally really surprising given that Collateral was an operation that managed millions of pounds of client money.

From the outset of the Administrations, we identified that securing the Companies’ electronic records would be critical. Following our initial meeting, the directors advised that all of the Companies’ IT functions and services were outsourced to an IT consultant. Both the directors and … advised that they had no access to the electronic platform, nor any back-up of the data contained within it, and they advised that the electronic platform had been decommissioned during March 2018 due to non-payment of outstanding bills; they did not therefore consider that the Joint Administrators would be able to recover the platform or the underlying data

The company outsourced IT operations, but kept no copies or backups of the data stored. Wow.

BDO did not give up on this, but located the servers and data forensics are working on recovering (part) of the data.

We have since made contact with the third party company holding the servers. Again, following protracted correspondence and with the assistance of our lawyers and my firm’s Forensic Technology team, we have located and secured the actual servers previously used by the Companies. There appears to be a significant volume of data still held on those servers and, as at the date of these proposals, we have taken steps to consolidate the contents of the different servers containing the Companies’ data into a single location (whilst preserving the originals intact). We shortly expect to receive a copy of the data, which we will then interrogate and review to better understand the nature of the data that has been recovered.
Whilst it is not yet clear whether we have retrieved all of the Companies’ electronic data, nor whether it will be possible to restore the electronic platform, the Joint Administrators consider that this represents positive progress.

Given that the allocation of client money to loans and the bookkeeping is a primary tasks of a p2p lending marketplace I am appalled when I read this finding:

… also provided certain key information in relation to the investors and loan book, in the form of two spreadsheets (which I refer to below) and copies of email correspondence between his office and various stakeholders during the period in which he purported to act as administrator. …advised that he held no other books or records, and neither did he have any access to the Companies’ electronic platform, or the data contained within it.

Really? The data was held in two spreadsheets? Excel, maybe?

A last quote (highlighting is mine)

Members of the Joint Administrators’ team attended the Companies’ trading address in Manchester on the afternoon of their appointment. The address is a serviced office space, and the office provider advised that the Companies had vacated the office several months prior to the Joint Administrators’ appointment. There were no assets or books and records remaining at the premises.

Now to the good news. BDO confirmed there is money in the client and office accounts. And the report shows the directors are cooperating with the administrator. The report seems to classify investor’s money as trust assets which would, as I understand it, leave investors in a much better position, than the outcome would have been, if they would have been qualified as pure unsecured creditors.

BDO says it is too early to give a forecast to the outcome, given the circumstances, but asseses:

We would, however, note that, as summarised on the statement of estimated financial position attached at Appendix 2, the estimated claims of creditors exceed the book value of the assets held by the Companies (including trust assets). Therefore, even before taking account of any potential asset write-downs and the costs of the Administrations, it appears likely that not all investors and creditors will recover their entire exposure to the Companies and the Collateral lending platform.

A lot will depend on how much can be retrieved from the outstanding property loans, which will fall due by mid-November 2018 at latest.

There is a lot of investor discussion regarding the report on the P2pindependentforum.

Trying to look at this from a high vantage point:

  • In my opinion a lot of the work, time and fees of BDO would have been saved, if the data would have been stored more persistently by Collateral in the first place
  • Investors should try to keep some form of offline records. I know depending on platform and number of loans that might be hard and laborous to do, but look at what position the Collateral investors are in now.  It is uncertain though if those investors that do have precise records on their loan allocation will be in any way better off than those that do not in the Collateral case
  • Investors trust regarding operations stability and bookkeeping of smaller UK platforms (Collateral had 5 employees) may be dealt a blow. It might become more important for smaller UK marketplaces to demonstrate robustness and durability of operations (e.g. through a detailed and transparent documentation of the living will, which is required for fully authorised platforms anyway)

The next steps in the Collateral case are described in the proposals in 15.1. and 15.2 of the report (page 20).

 

Banco BNI Europe Starts to Lend on Multiple P2P Lending Platforms

Banco BNI Europa was launched in July 2014 as a digital-only bank in Portugal. Banco BNI Europa says it aims to challenge the traditional banking sector through strategic partnerships with fast-moving fintech businesses to launch new products allowing the use of the most advanced technology in terms of risk analysis, consumer experience and rapid entry into the market.

Today Banco BNI Europe announced it will start lending on Fellow Finance.

‘Modern banks expand and grow by partnerships. Fellow Finance enables and offers an easy access to invest and lend in Nordic and Central European consumer and SME loans through its platform. Through their investment account at Fellow Finance, Banco BNI Europa is able to diversify their balance sheet investment into Finnish and German loans easily and cost-effectively. This is an example that banks don’t need to set up their own expensive operations on ground but can effectively enter markets through marketplace lending platforms. It is also an example how banks can also utilize the presence of FinTech among their core business’ says Jouni Hintikka, the CEO of Fellow Finance.

‘Investing via Fellow Finance in consumer and SME loans offers us a great opportunity to easily expand our operations and we are very satisfied with the analytical and professional approach of Fellow Finance in credit intermediation’ echoes Pedro Pinto Coelho, Executive Chairman of Banco BNI Europa.

Last week BNI Europe announced it will fund German SME loans through Funding Circle. According to Pedro Pinto Coelho, Executive Chairman of Banco BNI Europa, ‘an investment in German SME – the staple of European economic stability – is a highly attractive asset class. And Funding Circle is the professional partner that convinced us with their risk assessment and credit analysis. …’.

To date Banco BNI Europa has struck fourteen fintech partnerships with European fintech leaders across the continent. The bank had 141 per cent growth by the end of 2017 taking its total assets above €500m, and cited its focus on ‘innovative products’ as an explanation for the improved performance.

Growth of Investor Numbers on P2P Lending Platforms

Today I take a look at how investor numbers are developing at several platforms. I chart relative numbers with the index set to 100 for October 1st, 2017. The advantage of using indexed numbers for this comparison is that platforms use very different definitions for their investor base size. Some count registered investors, some count investors with deposits, some count active investors, some count recently active investors, … .

The disadvantage of showing indexed numbers for growth is that it gives smaller, younger an advantage as their percentage increase of investor base is likely still higher because they come from smaller absolut numbers.

Investor numbers by P2P-Banking
Indexed investor numbers (with Oct 1st, 2017 = 100).
Reading example: On Dec 1st the index value for Mintos was 117, meaning Mintos had 17% more investors than on Oct. 1st

My Lendit Europe Recap 2017

Lendit Europe time of the year again. My fourth time as a particpant of the London conference. It is now marketed as an ‘Event for Innovation in Financial Services’ and that means a wider scope of topics – and presenting companies – than in earlier years, when it had a single focus on p2p lending / marketplace lending. I truly enjoyed the conference, it had quality sessions and its high level attendants (more than 1100) allow great networking and making interesting contacts.

In writing this recap I find it much harder than in previous years to identify the main trends/topic that were discussed. There has been no single big announcement or issue happening that dominated the talks. So I’ll start with 3 predictions Renaud Laplanche, CEO Upgrade made in his motivating outlook on Online Lending 2.0:

  • Prediction 1: ‘The growth of online lending will accelerate in the next 15 months’
  • Prediction 2: ‘An organized secondary market for online loans will emerge in the next 15 months’
  • Prediction 3: ‘Continued re-bundling will give birth to at least one major consumer product innovation in the next 15 months’

From my viewpoint the first prediction is the one with the highest probability to come true, the second one is mainly important for the US market and it is actually the third one that is most interesting (but also most open).

Laplanche on Rebundling
His slide on rebundling examples

There are connections to another development that goes into the same direction and surfaced in several other sessions: More and more fintechs in this space are cooperating to better serve the customer and integrate multiple products into one user experience.

Furthermore there were several sessions around machine learning, artifical intelligence and automated underwriting with a wide range of opinions to what extend processes will be fully automated or whether human intervention or oversight is stll desireable for some specific decisions.

Looking at the scene from a geograhical perspective, many panelists emphasized that there are still a lot of difference between regions. The Americas, Asia or Europe (or even areas inside Europe) show a lot of differences no matter if the specific panel discussed funding, risk, investor yield, regulation or banking. So while many (especially VCs) would love to see fintech innovations that work globally and (if they are consumer faced) reach billions – that is extremly hard to achieve and therefore probably not going to happen in the near future.

This touches several speakers commenting and speculating whether the big tech giants like Amazon, Facebook, Google or Apple have ambitions and plans to offer financial services as they cater to a global audience, and what impact that would have on banks and fintechs. I found some aspects of this interesting, but mostly those discussions are futile because I feel there is such a lot of speculation involved and no real indicators that any of these companies are making steps in that direction. (sorry if there were any hard facts presented, I might have missed them as I did not see all the sessions).

I enjoyed Pitchit, where 8 startups battled for the vote of the jury and the audience. Swiss Sonect won both by hoping to replace ATMs by a platform approach where merchants can become the point where cash is dispensed (this is actually in collaboration with banks as they want to reduce the costs for maintaing ATM infrastructure and not anti-bank as it might sound on first impression).

All sessions at Lendit were recorded and will be made available over the next days here.

Seems like next year Lendit might come to a different location. The exit survey asked attendees to rate how they would like Frankfurt, Berlin, Barcelona vs London again.

 

Meeting of Government Pension Fund Managers Considers P2P Lending Allocation

This article was published on April, 1st

At an informal meeting of 21 government pensions funds in Geneva, Switzerland, the topic of alternative lending was for the first time on the agenda. The funds discussed the risks and merits of allocating a small percentage of their investments in this asset class in the future. P2P-Banking learned that the managers of the Statens pensjonsfond Utland, the Norwegian Government Pension Fund,  are considering to propose to call for an adaption of their investment rules to allow the investment of up to 0.3% of the funds money in innovative finance. A representative of the Australian Future Fund said, that investing to p2p lending marketplaces might be an interesting strategy in order to reduce the systemic risks that banks pose. However it would be much to all early to take this step now.

Unconfirmed rumours say that even the very conservative management of the German Rentenversicherung is analysing the opportunity due to very low yield of other asset classes. A spokesman of a German opposition party stated ‘This is all fake news. There is no way that pension money will be put in this unstable investment. We will not allow it’.

It would not be possible at the current size of the industry to allocate even a tiny fraction of the funds of these sovereign wealth funds, due to their sheer size.

Demonstrants from the Swiss communist party were protesting loudly outside the conference hotel, claiming this is just a plot of banks to divert attention from their wrongdoings and scams.