An interesting webinar organized by FAITA-Federcamping, the Italian association of campsites, addressed the issue of the revaluation of business assets. The special regulations issued by the Italian government to help companies cope with the difficulties caused by the pandemic offer, among other things, this possibility, which allows them to increase capitalization and improve incomes. Obviously, the instrument, which has been designed in different ways depending on whether you operate in the “hotel and spa sector” or not, must be handled with care, bearing in mind all the consequences that too unscrupulous use can bring with it.
The event was attended by Alain Devalle, professor of business economics at the University of Turin, as well as accountant and statutory auditor at ODCEC in Turin, and Gianluca Odetto, accountant and statutory auditor as keynote speakers.
“This is the best revaluation of the last 20 years and it would be a shame if those who can benefit from it didn’t,” said Devalle. In fact, among the possibilities available to companies there are theoretically three tools. The first one, the “extension” revaluation provided for by art. 12-ter of Legislative Decree 23/2020, is essentially useless, as there is a substitute tax of 10 or 12% which makes it less convenient than the two alternatives. The only element to consider is that it can also be applied to the next two financial statements.
Revaluations at no cost
The legislator also provided for the hotel sector, in the same decree (art.6-bis), the possibility of carrying out revaluations at no cost on the 2020 budget, on that of 2021 or in a mix of these two. Finally, there is the possibility for all companies to resort to the general revaluation provided for by art. 110 of Legislative Decree 104/2020, which can only be carried out on the 2020 business budget and with a substitute tax of 3% to be paid only if one intends to also resort to the “fiscal” revaluation and not just the civil one. Wanting to compare the rules on the revaluation reserved for the hotel sector with that intended for all entrepreneurs, it must be said that while in the first case the operation must concern the assets collected in homogeneous categories, in the second it is possible to reassess the desired assets freely and individually.
Wanting to choose which standard to refer to, it must also be said that for campsites and tourist villages the situation is not clear. The decree in fact refers to “companies operating in the hotel and spa sector”, but a similar definition, as confirmed by Gianluca Odetto, does not exist. One hypothesis is to consider the ATECO codes, obviously starting from 55.1, which includes hotels and similar structures. Looking at the “ratio” of the law, it would be natural to also include codes 55.2 (holiday accommodation, refuges, landlords and so on) and 55.3 for campsites. At the moment, however, there is no interpretative confirmation, and we will therefore have to wait to be sure to be able to activate this tool also for open-air accommodation facilities. The rule, however, speaks of companies “operating in the sector”, so it can also be applied to those who work under a company rental regime.
What to consider carefully
But when it comes to the revaluation of business assets, what are the main things to keep in mind? First, the value of the asset must never exceed the recoverable value, that is the greater one deriving from a possible sale (net of sales costs) or that obtainable from its value in use. Usually the first is used, but it is also possible to evaluate the asset for its use by calculating its value in terms of revenues. Although not mandatory, it is always preferable to have a professional perform an appraisal to avoid open disputes with the supervisory bodies, and in any case, once the value has been defined, it is not advisable to carry out a 100% revaluation: it is better to maintain a prudence threshold useful for avoiding disputes and dealing with any write-downs in subsequent years.
While recovering capitalization can be relatively easy, however, attention must be paid to profitability, wondering if the income statement for subsequent years can afford the higher amortization. For example, if you revalue an asset to €1 million and have 10 years of residual useful life, you need to calculate €100,000 per year of depreciation. Is the income statement able to absorb them? If it were difficult, you can try to understand if the useful life of the asset can be extended, thus spreading the depreciation over a higher number of years. If you decide for this solution, obviously an objective analysis is needed to support it and in any case the operation will be recorded in the following financial statements.
Another element to evaluate is what to do with the reserve thus created. If you want to use it freely, you must pay the substitute tax of 10%. Otherwise, the deferred tax must be entered in the balance sheet, thus reducing the value of the revaluation. If you want to distribute this reserve to the shareholders, it is essential to follow the first route, using the so-called “liberation”. The opportunity of such a choice is to be seen, given that it can reduce business resilience in the event of a continuing crisis.
Which assets are revaluable
If it is clear enough who can proceed with this operation (essentially all subjects except those who adhere to the International Accounting Standards, IAS), we must instead talk about which assets are subject to revaluation: tangible and intangible fixed assets, equity investments and leased assets. In any case, everything must already be present in the financial statements as at 31/12/2019 and the leased asset must therefore have been redeemed by that date. Goodwill, goods to be sold and monetary assets cannot be revalued.
A hot topic is that of intangible assets, such as brands and know-how. Here there was a great debate, because the Italian Accounting Organization (OIC) has released its interpretative document number 7 on this topic only a few days ago. The essence is that if you have a registered trademark, and therefore legally protected, there are no problems, but doubts arise when there are brands whose costs have never been written to the income statement.
The OIC eventually ruled that these too can be subject to revaluation because it would be discrimination to allow it only in some cases. In the reasons, however, it is argued that the revaluation can be made for civil law purposes: this wording has been inserted because for trademarks not registered in the balance sheet, the tax legislator would have in mind to change the rule to reduce the possibility of fiscally revaluating these assets. For now, therefore, revaluation for tax purposes is also possible, but the rules could change.
The right motivation and the other tools
In all cases, the revaluation carried out must be highlighted and justified in the explanatory notes and in the management report, which must also be communicated to any auditors or boards of statutory auditors. An important thing to know is that all assets undergoing revaluation cannot be sold before January 1, 2024.
As we have seen, the revaluation of company assets is an interesting way to go, even if it must be evaluated with great attention. It should be emphasized that there are also some other tools designed to mitigate the effects of the crisis at the disposal of entrepreneurs. The first one is the suspension of the recapitalization, which has been postponed to 2025. Furthermore, loan payments can be suspended. These moratoriums provide financial, but not budgetary, support. The derogation, in fact, did not provide for shifts of responsibilities.
Finally, for 2020 there is also the derogation from the registration of depreciation. Can assets be revalued and suspended? The answer is yes: the two derogations proceed in parallel and are aimed at mitigating the effects of the pandemic. The OIC interpretative document no. 9 concerning the suspension of depreciation was published just yesterday.
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