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Increasing the share capital does not necessarily mean greater financial strength

If it is a loan for the purchase of a property that will be used to recapitalize the company, it should be noted that the mortgage can significantly reduce or completely negate the value being contributed to the company.

Some well-known companies with significant financial strength have never opted to increase their share capital above the initial minimum, while bankruptcy has been opened for some with million kuna share capital, in which creditors will receive almost nothing.

Written by: Prof. Dr. Hrvoje Kačer

The share capital is the property of the company at the time of its establishment and at that moment is equal to the property of the company. However, over time this relationship changes, so the share capital usually remains the same, for a limited liability company 20,000 kuna, and for a joint-stock company 200,000 kuna (for joint-stock companies, the minimum amount in Austria is 70,000 euros, in Switzerland 100,000 Swiss francs, in Germany 50,000 euros, etc.), while the property of the company changes. However, the share capital changes only if there is an increase or recapitalization, or in cases of reduction. When it comes to the property of the company, it potentially changes constantly, with each payment and/or receipt of another’s payment, but also with the acquisition or disposal of non-cash assets. In the case of disposal, it does not have to be a permanent disposal, such as in the case of a sale, but also, for example, the encumbrance of a property of the company with a mortgage.

The fact is that Croatian law imposes no restrictions on the disposal of what constitutes share capital, which means it can be disposed of immediately after establishment – this will lead to the situation where, despite the formally existing share capital, what was paid in as share capital no longer exists, even if there is some debt, which means that the share or stake of that company can be worth zero kuna. This is not the case in all foreign laws, as there are solutions whereby share capital or part of it serves as a guarantee for payment to creditors if and when problems such as bankruptcy arise.

Reducing capital is not a weakness

Unlike the widespread misconception that share capital serves only to demonstrate the financial strength of the company, its primary role is for members to fulfill their obligations to the company by payment (and/or contribution of other assets of that value) and for their relationship in managing the company to be completely clear. The consequence of recapitalization does not necessarily have to be an increase in the financial strength of the company. Just as recapitalization is possible by payment into the company’s current account (which increases the financial strength of the company), it is also possible for the company to be recapitalized with used buses that still need to be paid off for some time, which means an increase in the company’s financial obligations. The share capital can be reduced for various reasons, for example, when the company has too much capital (which is rare), when dividends cannot be paid due to significant losses, when there is a withdrawal of a business share because a member has been excluded or has exited (in the case of a limited liability company)… Although this may not correspond to the actual state, the public will most often perceive a reduction in share capital as a weakness of the company, just as an increase in share capital will most often be understood and perceived as a sign of the company’s strength.
Regulation for evasion

Until now, there has been a very specific case of recapitalization in practice, solely due to a very awkward provision of the Companies Act (Article 390) which states that if the initial contribution in a limited liability company is made in cash and assets, the cash part cannot be less than 50 percent. This has led to an absurd situation that only benefits public notaries (they have double the work), although they are not at all to blame for it. Namely, a limited liability company is established with a cash payment of 20,000 kuna, so whoever wants to contribute some property to the share capital, due to Article 390, will not do so at the moment of the company’s establishment because in that case they would have to pay a much larger amount than 20,000 kuna, but will do it only two days after registration because then, in fact, the mentioned provision no longer applies. It is unfortunate that the legislator and relevant authorities do not react to this, which is a public secret, which is certainly the worst solution; anyone can make a mistake, including the legislator, and that is not too big of a problem, but if the survival of a legal norm that everyone (and legally) avoids is allowed, then there is a very simple choice: either change the provision or accept the infliction of damage to legal certainty and the rule of law. In Croatian law, this is neither the only nor an isolated case (one only needs to recall the avoidance of restrictions for foreigners when acquiring ownership rights over real estate), but this does not diminish the negativity of the phenomenon as a whole, nor of this case as part of that whole.

Recapitalization can also be done with a loan

It is often questioned whether a company can be recapitalized with loan money. Not only can it be done, or is it allowed, but it is also quite a common case. The only possible obstacle is the creditor’s policy, because if it is a purpose loan, the creditor is authorized to condition and control the intended use of the loan funds. Beyond that, there are no restrictions. However, if it is a loan for the purchase of a property that will be contributed to the company, it should be noted that the mortgage (if there is one on the property) can significantly reduce or completely negate the value being contributed to the company. It is quite strange that financial institutions often attach great importance to the amount of share capital, although in practice there are large and well-known companies with significant financial strength that have never opted to increase their share capital above the initial minimum, just as there are those with million kuna share capital over which bankruptcy has been opened, in which it is expected that bankruptcy creditors will receive almost nothing.

Recapitalization as a means of changing power in the company
A significant part of the negative associations that the public has about recapitalization is also due to the fact that, more or less covertly, under the guise of recapitalization, a change in the power relations in the company is actually hidden, in such a way that someone increases their share or number of shares. This phenomenon is not new, and it was introduced into Croatian legal practice by (then Croatian) banks, with full support from Croatian authorities. During the war, loans (where the borrower did not take into account the loan conditions, nor the interest rates) were granted generously, although it was known that they would not be repaid and that they would be converted into shares in the process of increasing share capital. To make the picture completely clear, the modus operandi previously was the recognition of foreign currency clauses in loans that were not even contracted, even in fully paid loans, which immediately allowed banks a significant ‘ownership’ position in numerous hotel companies.
Tax on the contribution of one’s own property
According to the opinion of the Tax Administration issued in September last year, any contribution of one’s own property as share capital in a company is taxed as income tax, thus from 25 to 45 percent. Although there were probably hidden reasons that may be supported (for example, preventing manipulation in the acquisition of real estate by foreigners who not only avoid obtaining consent but also paying real estate transfer tax), it is still a fact that such a stance was not applied until recently, which today means inequality before the law or the taxation of all contributions within the statute of limitations, which would be an even worse solution. It is clear that after this opinion, many will refrain from contributing to the share capital to avoid paying tax. It is a small consolation that this only applies to properties acquired within three years prior to the contribution to the company. According to this opinion, it seems that it is not in the general interest for each individual company to be financially as strong as possible, to respond better to creditors in that sense, and to abuse as little as possible the fact that founders are not liable for the company’s obligations.
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