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A lack of harmony in European regulations

A LACK OF HARMONY IN EUROPEAN REGULATIONS

The legal, fiscal and accounting differences that exist from one country to another in the European Union represent a real obstacle to generalizing cross-border financing.

EXAMPLES OF LOCAL SPECIFICS(1)

  • France is one of the few countries to distinguish between financial and operating leases. In most European countries, lease-financing solutions are grouped under one single heading, leasing.
  • In Belgium, the term “leasing” is reserved for companies, whereas the term “crédit bail” (financial lease) is used for lease-financing solutions for individual consumers.
  • Only Sweden, Portugal, Spain, Romania, Italy and France provide credit body status for a company engaged in regular leasing activity.
  • In the United Kingdom, the assets held under a leasing contract are assimilated to the “economic property” of the lessee. This leads to them being entered on the lessee company’s balance sheet. In France, meanwhile, the assets held under a lease-financing contract are considered as the property of the lessor, and therefore appear among the assets of the lessor’s balance sheet.
(1) Except incidence IFR
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