Group 1 - The enthusiasm for REITs products among fund companies has significantly increased this year, with a notable acceleration in the launch of public REITs products, as many new products have recently been approved for issuance [1][2] - As of June 25, 2023, a total of 10 new REITs products have been launched this year, with a combined issuance scale exceeding 13 billion yuan, and the total market value of listed REITs products has surpassed 200 billion yuan [2][4] - The number of public institutions participating in the REITs market has grown, with 24 public institutions (including securities asset management) involved in the layout of REITs products [2][3] Group 2 - Leading public fund companies, such as Huaxia Fund and Zhongjin Fund, have been actively launching REITs products, with Huaxia Fund having the highest number of listed products at 14 [3][4] - Various listed companies are increasingly using their assets as underlying projects for issuing REITs products, indicating a diversification of market participants [3][4] - The REITs market is seen as a vital tool for empowering the real economy, with the scope of REITs products expanding to include various sectors such as shopping malls, agricultural product trading centers, and cultural tourism projects [4][6] Group 3 - The issuance of REITs products is providing new exit strategies for early-stage investments by venture capital institutions and local governments, helping to alleviate fiscal pressures [4][6] - The funds raised from REITs issuance are being utilized for various purposes, including debt repayment, asset-light transformation, and promoting new project development [6] - The secondary market performance of REITs products has been strong, with only one out of 66 listed funds declining in value this year, and half of the funds showing an increase of over 20% [6]

Core Viewpoint - The public REITs market in China has surpassed 150 billion yuan in issuance, evolving into a dual-driven model of "initial issuance + expansion" and becoming a crucial financial tool for revitalizing existing assets and supporting the real economy [1] Group 1: Business Background - The public REITs market has expanded to over 10 asset types, with a significant focus on infrastructure projects [1] - The issuance of public REITs has entered a normalization phase following the release of government notifications aimed at promoting regular issuance [1] - Infrastructure public REITs typically adopt a "debt structure" to establish cash flow, ensuring regular distribution of distributable amounts to investors [2] Group 2: Tax Observations - Current regulations regarding corporate income tax interest expense deductions are influenced by the commercial rationale and the interest rate levels of the debt structure [3] - Tax authorities may question the commercial rationale of interest expenses and their relevance to the company's operations [2] - There is a lack of uniformity among tax authorities regarding the recognition of "financial enterprises' same-type loan rates," leading to potential disputes over interest expense deductions [2] Group 3: VAT and Property Tax - The new VAT law will take effect on January 1, 2026, but there is uncertainty regarding the tax rate for "old projects" and the transition from existing VAT regulations [4] - The public REITs market is experiencing downward trends in rental income due to economic fluctuations, which may impact property tax calculations and actual tax burdens [5][6] - Changes in property tax calculation methods could introduce compliance risks and affect cash flow distributions for project companies [8] Group 4: Income Tax Considerations - Public funds and special plans are not subject to corporate income tax, but income distributed to investors is subject to taxation based on their legal status [9] - Different tax regulations apply to corporate and individual investors regarding dividend income and capital gains from fund share transfers [10] - Continuous monitoring of tax policy changes is essential for managing tax risks associated with public REITs and their multi-layered structures [10]

Group 1 - The development of C-REITs has progressed through three phases: exploration and cultivation (2004-2019), pilot phase (2020-2024 H1), and normalization phase (2024 H2 onwards) [1][9] - The C-REITs market has seen a total of 65 listed REITs with a total market value of 190.9 billion as of April 21, 2025, with the top three asset types being transportation infrastructure (32%), park infrastructure (16%), and consumer infrastructure (16%) [9][14] - The regulatory framework for C-REITs has evolved to include a multi-department collaboration model, with the National Development and Reform Commission (NDRC) overseeing project compliance, the China Securities Regulatory Commission (CSRC) managing product registration, and exchanges ensuring listing and information disclosure [2][20] Group 2 - The issuance process for C-REITs consists of four main stages: preparation, application and review, registration and issuance, and listing management, with a focus on improving efficiency and ensuring investor protection [3][19] - The normalization phase aims to shift from "scale expansion" to "quality improvement," optimizing the market ecosystem and promoting a multi-tiered REITs market system [4][22] - The NDRC has expanded the asset scope for C-REITs to include 12 categories, enhancing the flexibility of fund usage while prohibiting the use of recovered funds for residential development projects [4][24]