Differing legislation,
taxation and accounting practices in European Union
countries are a significant barrier to the development
of cross-border financing.
EXAMPLES OF LOCAL DIFFERENCES
- France is one of the few countries to distinguish
between operating leases and financial leases. In
most other European countries, the various solutions
come under the umbrella term "leasing".
- In Belgium, "leasing" is restricted to
companies, whereas "financial leasing" covers
solutions geared to individuals.
- Only Sweden, Portugal, Spain and France have a special
credit institution status for the provision of leasing
operations on a regular basis.
- In the United Kingdom, goods held under the terms
of a leasing contract are considered to be the lessee's
"economic property". This means that these
are listed on the lessee's books as assets. It is
quite the opposite in France, where goods held as
part of a leasing contract are considered to be the
lessor's property and, as such, are entered on the
lessor's books as assets.
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