Summary.pdf
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
Financing of housing (section A 5) is one of the most
important areas in housing policy. Long-term fi-
nancing for developers and investors or for buyers
The present study consists of four parts. Part A
of (owner-occupied) housing is dominated by
contains a compact theory of housing markets and
mortgage loans. The interdependent and combined
housing policy. The more voluminous Part B com-
effects of loan type, maturity, interest rates, risk and
prises 15 monographs on all current EU countries.
inflation on annuities are discussed and compo-
Part C presents condensed reviews of the same
nents of nominal gross active interest rates are ana-
countries and some comments on EU activity in the
field of housing. Part D includes some suggestions
Housing stock structures (section A 6) comprise a
on housing policy instruments and, finally, this
variety of tenures. Each tenure represents a specific
bundle of rights and duties which can be greatly
modified by housing policy. Parallel to groups of
Initially, the theoretical
Part A deals with housing
developers, tenure structure can be broken down
terminology (section A 1). Among others, the term
into public rental housing, limited-profit rental
„social housing" is analysed and because of its im-
housing, co-operative housing, private rental hous-
precise usage discarded as a viable housing policy
ing and owner-occupied housing. In addition to the
term. Similarly, the term „sub-standard housing" is
regularly used housing stock, there are consider-
only meaningful with reference to a generally
able shares of secondary residences etc. in some
achieved standard.
Section A 2 presents housing forms and tenures
Current
housing expenditure (section A 7) results
which normally appear in housing markets, par-
from capital cost and operating cost. Manifold
ticularly tracing the varying rights and duties
combinations of capital from various sources and
linked with specific tenures in different countries.
different loan types lead to complex user payment
When comparing housing sectors, housing forms
flows. Regarding equity to be provided by buyers
and different tenures must be kept apart. Aspects of
of owner-occupied housing, national regulations
housing markets such as supply, demand, vacancy
and customs vary greatly. In countries with tradi-
and price are briefly dealt with.
tionally high inflation and high interest rates, bor-
rowers try to keep debt low and to repay quickly.
In the following sections, housing markets are de-
The influence of loan maturity on total real financ-
scribed in greater detail according to areas of possi-
ing cost is presented in graphs and tables. This sec-
ble market intervention by housing policy.
tion also evaluates the relative importance of differ-
Any production of dwellings requires
land for build-
ent operating cost elements and shows that market
ing (section A 3). In urban areas, because of concen-
rent for a totally capital-market financed dwelling
trated demand and inelastic supply, the share of
would often not cover capital cost.
land may reach half of the total production cost of a
Taxation of housing (section A 8) is partly moti-
dwelling. Additional problems occur when land-
vated by a need for revenue and partly by housing
owners refuse to sell, speculating on rising prices. If
policy objectives. Acquisition, ownership and use of
land ownership is scattered, this may obstruct ra-
dwellings are all taxed. Because of the „visibility"
tional development of human settlements. Finally,
of real property, it is often taxed without proper
the contradictory aims of mobilising land, keeping
justification while capital gains are taxed only
land prices low and reducing land consumption are
lightly, although they should be taxed. An issue
often discussed is classification of housing as in-
In section A 4 agents in the
housing construction
vestment or consumption good. In reality, the two
market are described according to their interests.
variants are frequently mixed, leading to substan-
Among them, there are developers (public authori-
tial foregone tax revenue if deductibility of expen-
ties, limited-profit housing associations, housing co-
diture is not compensated by imputed rent at mar-
operatives, private landlords and owner-occupiers)
as well as planners and builders. Diverging inter-
ests of landlords and tenants often lead to conflict-
ing behaviour. Aspects of housing construction
quantity and quality are also commented on briefly.
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
Section A 9 contains some considerations regarding
Urban renewal policy is mainly concerned with the
statistical data on housing. The most useful indica-
eradication of slums and the elimination of sub-
tors seem to be the ratio of floor area in new hous-
standard housing, as well as with improving the
ing compared with total floor area in the housing
local environment. Specifically, preventive and
stock and net floor area per person discounting a
corrective measures against the decay of large
„core area" (kitchen, bathroom, entrance) as well as
housing estates built in the 1960s and 1970s are
variations of those indicators over time. Regarding
required. These measures also have important so-
housing price/expenditure, the ratio of purchase
cial implications. Especially in inner city areas, the
price or annual basic rent to per-capita GDP allows
implementation of revaluation strategies may have
cross-national comparisons. Finally, difficulties
negative effects and lead to social segregation.
encountered in determining housing policy expen-
Housing construction policy (section A 13) has widely
diture are explained.
been identified with housing policy and is often
Section A 10 discusses possible
housing policy goals.
substituted for it. For lengthy periods, production
The primary goal of socially-oriented coverage of
of the largest possible number of new dwellings
housing needs is distinguished from secondary
was taken for the prime aim of housing policy.
aims like increasing the share of owner-occupation
Since on-site labour represents an important cost
or of local authority housing, reduction of housing
element, the pre-fabrication of standardised build-
expenditure etc. as well as supplementary aims
ing components was thought to be a way of increas-
such as policies influencing the distribution of
ing productivity. In addition, costs were to be cut
wealth or income, and labour market policy. Within
by high-density layout, compact dwelling design
current housing policy, some problem household
and inexpensive appliances. An important role was
groups emerge, sometimes identified as elderly or
assigned to limited-profit housing providers which
unemployed persons, single parents, alcohol or
came to dominate subsidised production of multi-
drug addicts, foreign nationals and socially disrup-
storey housing in several countries.
tive persons. Regarding urban development, deg-
In view of the magnitude of production costs,
hous-
radation of the local environment will impair the
ing financing policy (section A 14) played a leading
housing situation of residents while revitalisation
role in housing policy. Most frequently applied
strategies (active gentrification) may lead to their
forms of supply-side subsidisation were public
subsidised loans, grants towards construction cost
Section 11 analyses and evaluates various forms of
and interest or annuity subsidies.
housing policy market intervention. Basically, the pub-
Regarding subsidised loans, relative or absolute
lic sector may employ legal regulations, provide
subsidisation may be distinguished depending on
information, participate directly in housing markets
the interest rate being higher or lower than the in-
and/or provide subsidies. Particularly this last
flation rate. If the two rates are equal, the real value
policy instrument tends to heavily burden public
of the capital provided is preserved. If the subsidi-
sector budgets. As subsidies aim at bridging the
sation benefit is defined as partial saving of financ-
gap between (high) housing cost and (low) house-
ing cost compared with capital market loans, and
hold income, the advantages and disadvantages of
subsidisation cost is defined as loss in the real value
supply-side and demand-side subsidies are com-
of public funds, then an efficiency factor based on
pared. In addition, direct and indirect forms of
cost-benefit-analysis can be computed for different
housing policy market intervention are grouped
subsidy schemes.
according to the different housing market agents
Premiums for deposits in special financing circuits
(e.g.
Bausparkassen) and tax allowances for refinanc-
The following sections treat specific areas of active
ing instruments would be considered indirect sup-
housing policy in greater depth.
ply-side subsidies.
Land and urban development policy (section A 12)
Housing stock policy (section A 15) has a strong in-
describes the creation of urban land supply by
fluence on actual housing consumption by house-
planning and zoning and by definition of permitted
holds. Various forms of housing deficit (cramped
use and density etc. Besides direct instruments of
living, under-utilisation, misallocation, sub-
market intervention like expropriation and pre-
standard and vacancy) all call for housing policy
emptive purchase rights, some measures to restrict
action. Specific market intervention then takes on
hoarding of legally available land are discussed.
different forms according to the particular deficit
Leasing of land by local authorities allows greater
flexibility and furthers rational urban development.
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
Public rental housing is provided at rents (far) be-
benefit is a socially targeted housing policy instru-
low market level, but access is usually restricted
ment, deductibility of mortgage interest and re-
because of insufficient supply. Nevertheless, in
payment at the individual marginal income tax rate
some countries, public rental housing is later sold
is a regressive instrument.
to sitting tenants. In this situation, heavily subsi-
Limitation of entitlement to and quantification of
dised purchase prices act as a strong incentive.
housing benefit is still subject to intense discussion.
Limited-profit housing companies occupy a some-
A balance has to be struck between a socially moti-
what diffuse position which also changes over time.
vated expansion of housing benefit payments, and
The power of public authorities to control and in-
the ever rising public expenditure required by this
fluence the activities of those housing developers
system. At the same time, sufficient incentive must
and providers varies among different countries. In
be preserved for households receiving housing
recent years, a trend towards increasing economic
benefit to take up (paid) work instead of immobilis-
independence can be observed raising the question
ing them through a „poverty trap".
of actual ownership of the accumulated (real prop-
Tax policy (section A 17) is often not clearly embed-
ded in housing policy. Tax revenue is usually more
Rent in the limited-profit sector is either deter-
important than social housing policy aims. On the
mined according to household income or is a func-
other hand, vaguely justified tax allowance schemes
tion of cost. However, „cost rent" often includes a
cause important foregone tax revenue. Also, taxa-
number of elements (potentially) exceeding actual
tion of land hardly corresponds to the proclaimed
cost. In any case, cost rents would not assure access
goal of furthering a more flexible land market.
to adequate housing for low-income households.
Capital gains are inadequately taxed. By contrast,
Affordability of limited-profit housing is funda-
real property transfers are often taxed quite heav-
mentally obtained by subsidies which usually were
allocated to the limited-profit sector on an preferen-
Finally, section A 18 describes various forms of
provision of
housing policy funds such as general and
Housing co-operatives vary greatly in character
housing-specific taxes, repayment of previous pub-
depending on the possibility of later commodifica-
lic loans, capital market credit, securitisation and
tion. Therefore, co-op housing may appear similar
sales from the public rental housing stock.
to rental housing or also become practically equiva-
lent to owner-occupied housing.
The private rental housing sector experienced far-
reaching market intervention by governments,
mainly related to rent control or rent regulation, to
Each one of the 15 monographs on EU countries
security of tenure and to transfer rights. While justi-
presented in
Part B is based on the same structure
fied during crisis periods, these housing policy
to facilitate use by readers interested in specific
instruments proved to be counter-productive when
issues or periods. In view of the wealth of material
they continued for prolonged periods and pre-
presented, numerous references give guidance for
vented adequate private housing investment. As
further reading. Countries are arranged in alpha-
most of those market interventions have been re-
betical order according to their abbreviations.
duced or abolished, private rental housing is cur-
rently closer to free market conditions in many
As a background to housing-specific topics, some
basic information on the geography, demography,
administration, politics and national economies is
The relationship between housing expenditure un-
presented in section 1 of each monograph. Section 2
der free market conditions and partly insufficient
describes developments in housing policy from
household income was at the origin of modern
1945 to 1990, arranged by policy area like in Part A.
housing policy. Therefore, many forms of
housing
The same structure applies to section 3, with infor-
expenditure policy and
income policy developed (sec-
mation on housing policy during the most recent
tion A 16). Apart from many attempts at reducing
decade 1990-2000. The outcome of endogenous
housing cost and hence lowering housing expendi-
housing market developments and housing policy
ture directly, mostly demand-side subsidies were
influence is outlined in section 4. Finally, section 5
implemented in order to assure access to adequate
attempts to evaluate the individual countries' hous-
housing. In this sense, direct income support by
ing policy on the basis of the theoretical analyses
housing benefit is to be distinguished from indirect
undertaken in Part A.
income support by tax allowances. While housing
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
AT / Austria
DE / Germany
Austrian housing policy has predominantly been
German housing policy is based on legislative co-
supply-side policy. Until now, housing policy funds
operation between the state and the
Länder and on
have mainly been provided by setting aside fixed
federalist implementation. Post-war housing sub-
percentages of certain kinds of tax revenue and by
sidy schemes initially concentrated on rental hous-
collecting housing-specific levies. Traditional sup-
ing, were later extended to owner-occupied hous-
ply-side subsidies are combined with generous
ing and have more recently been complemented by
income ceilings. Housing benefit is less significant
more flexible subsidisation arrangements.
and generally linked to supply-side subsidisation.
In contrast to other countries, subsidies for rental
Tax allowances play a minor role.
housing were not only available for limited-profit
The sizeable public rental housing sector, especially
but also for private developers. Original indefinite
in Vienna, and the still larger limited-profit sector
control of limited-profit housing was abolished in
provide a viable alternative to private renting.
1990 through repeal of the Limited-profit Housing
Long-term regulation of private rental housing has
Act. In addition to controlling some (previously
reduced the share of this sector. Privately devel-
limited-profit) housing companies, the local autho-
oped housing mainly consists of owner-occupied
rities also procure allocation rights in the private
single-family homes.
rental sector. In some
Länder, tenants of subsidised
For several decades, Austrian housing policy was
housing whose income exceeds current income
based on corporatist „social partnership". Since the
ceilings are obliged to pay supplementary rent.
1980s, it has progressively been regionalised. Only
In the private rental sector the „comparable rent
in recent years has housing policy become more
system" works quite well. However, regionally
market-oriented.
differentiated housing benefit has become an indis-
pensable element of housing policy.
In the owner-occupation sector, tax allowances
BE / Belgium
were based on degressive depreciation, originally
balanced by imputed rent, which was later abol-
During the 1980s, most aspects of Belgian housing
ished, when housing was reclassified as a consump-
policy were decentralised to the three regions of
tion good. Some years ago, this regressive tax bene-
Flanders, Wallonia and Brussels. The only respon-
fit was replaced by a non-income-related owner-
sibilities remaining with the national parliament are
occupation subsidy.
rent and tax legislation.
Integration of the former GDR into the Federal Re-
Belgian housing policy focuses on owner-
public brought far-reaching difficulties. Because of
occupation. Because of generous income limits,
fundamental differences between the GDR and the
relatively small subsidies for owner-occupiers are
FRG regarding their legal systems and their hous-
widely available. Limited-profit rental housing is of
ing economy, but also because of severe deficits in
little importance, also because limited-profit dwell-
the eastern housing stock, expensive and extensive
ings were often sold to sitting tenants. Refinancing
transition schemes had to be devised. Large num-
of housing policy funds on the capital market re-
bers of still undecided restitution claims for prop-
quired extensive operating subsidies. Income-
erty continue to affect the validity of property
related rents in the limited-profit sector partly act
as a substitute for a general housing benefit system.
The private rental sector provides accommodation
for many low-income households, some of it even
in furnished rooms. Tenure security in the private
DK / Denmark
rental sector is limited. Several social service groups
As part of wider welfare policy, Denmark gave
are active in the housing sector. They provide assis-
strong impulses to limited-profit housing compa-
tance and act as intermediaries between private
nies controlled by local authorities. Large and
landlords and tenants in unstable conditions.
partly pre-fabricated housing estates of high stan-
Annuities for mortgage loans in the owner-
dard were complemented with comprehensive
occupied sector are deductible within limits. Im-
social infrastructure. Later, based on (negative)
puted rent is fairly low. However, transaction costs
experience, high-density low-rise estates were pre-
for owner-occupied housing are quite high, except
ferred. Limited-profit housing is open to all strata
for low-priced or limited-profit housing.
of society. A distinct feature of Danish limited-
profit housing is well-developed tenant participa-
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
tion in the operation of housing estates. As rent in
Owner-occupation is, by far, the dominant tenure.
high-standard limited-profit housing is relatively
It was favoured by tax allowances and first-time
high and housing demand is largely satisfied, some
buyers were granted special relief. However, subsi-
estates register recurrent prolonged vacancy. In the
dies dedicated to owner-occupied housing were
private rental sector dwellings are generally older
largely absorbed by the land market.
and of lower, yet adequate, standard. Most of the
private rental stock is still subject to rent regulation.
The two-tier housing benefit system is limited to
FI / Finland
A Danish speciality are long-term mortgage loans
Post-war Finnish housing policy had to react to
refinanced with long-term fixed-interest bonds. In
several large migration movements. In addition, in
view of traditionally high marginal income tax
1990, the economy suffered a severe recession
rates, tax allowance for mortgage interest was an
which could only be overcome by drastic budget
important incentive in favour of owner-occupation.
cuts and by anti-cyclical subsidisation. The Housing
However, instead of previous deductibility at the
Fund of Finland / ARAVA is the official agency
individual marginal rate, in more recent years a -
implementing housing policy.
decreasing - flat rate has been applied. Another
Subsidies for new housing are available for all
important feature of Danish housing policy is the
types of developers. With the aim of reducing pub-
relatively high land tax which largely prevents
lic debt, outstanding ARAVA loans were sold on
speculation with vacant land.
the international capital market to procure funds
for new ARAVA loans.
Except for the city of Helsinki, municipal housing
ES / Spain
stocks are rather small. A Finnish speciality are the
so-called housing companies which play an active
After Franco's death, the Spanish constitution was
role as developers of owner-occupied flats. Any
reformulated and many responsibilities, among
physical or legal person may purchase shares in
them housing policy, were transferred to the new
these companies representing indirect ownership of
Autonomous Regions. Only general funding re-
a specific dwelling. In view of limited tenure secu-
mained under the authority of central government.
rity in the private rental sector, „right-of-occu-
In the absence of a welfare state structure, housing
pancy" dwellings have become quite popular since
policy apparently reflects traditional strong family
the early 1990s. They require a tenant contribution
ties which still provide most support in the case of
but offer unlimited tenancy.
personal difficulties. Therefore, up to the present,
there is no general housing benefit system in Spain.
Owner-occupation traditionally enjoyed income tax
deductibility of mortgage interest at the individual
Massive post-war migration from the countryside
marginal rate. In view of economic crisis, a flat tax
into the cities required large-scale housing produc-
rate was introduced instead, but the former im-
tion in spite of initially very limited public funds.
puted rent was abolished. Rapid financial sector
New housing was mainly provided in the form of
deregulation led to an unprecedented availability of
small simple flats making up the major share of
mortgages, to a speculative increase in house prices
high-density residential developments. However,
and, after 1990, to a severe drop in housing prices
parting with early public housing construction pro-
that caused bankruptcies in the construction sector
grammes, private development subsequently took
and destabilised several banks.
over housing production. Subsidisation mostly
consisted of interest subsidies towards capital mar-
ket loans. Public rental housing represents a very small share
of all primary residences. Not least because of seri-
ous operating difficulties, many dwellings were
sold to sitting tenants. On the other hand, the pri-
vate rental sector was tightly regulated for several
decades. Tenants not only benefited from low rents
but also from excessive transfer rights. From the
1980s onwards, deregulation took place. The Span-
ish capital market developed in a similar way.
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
FR / France
above the rapidly increasing stock of primary resi-
In connection with forced industrialisation after the
dences, Greece also has one of the largest shares of
second world war, French housing policy designed
not permanently occupied housing, partly due to
ambitious housing construction programmes which
massive internal migration.
required a modern and high-capacity construction
Greek housing policy is limited in scope and effect.
sector. Numerous large and rather monotonous
Subsidised loans are available for specific groups of
housing estates were built with pre-fab technology
employees but limited funding requires rationing.
during the early post-war years. Because of their
Housing benefit is not very common yet. The most
limited attractiveness, they currently represent one
important form of support for owner-occupation is
of the most intractable problems of French housing
unlimited deductibility of mortgage interest. Theo-
policy, aggravated by local concentrations of immi-
retically, imputed rent must be added to income,
grants. Therefore, HLM companies charged with
but generous exemptions apply. Transaction costs
the production of subsidised housing face relatively
in the owner-occupied sector are fairly high.
high vacancy rates, especially in smaller cities
where cost rent often exceeds market rents. In some
cases, partial demolition of stock seems the only
solution. On the other hand, demand for HLM
IE / Ireland
housing in the capital region by far exceeds avail-
The Irish economy developed extremely fast in the
able supply because of below-market rents.
last few decades. Reflecting this trend, the general
Subsidisation instruments and schemes were fre-
housing situation has also greatly improved, espe-
quently modified giving observers a bewildering
cially compared with the relatively low standard of
overall impression. Alternating combinations of
1945. However, unbridled production of single-
subsidised loans, construction cost grants and in-
family homes grouped by social class was largely
terest subsidies have been available. However, pre-
unplanned and caused a wasteful use of land. Sub-
vious tax allowances for mortgage loans were
sidies went into owner-occupation almost exclu-
gradually reduced in the 1990s. Refinancing of
sively. Only a small sector of terraced council hous-
housing policy expenditure is based on housing-
ing was provided for low-income households. Rent
specific levies, on low-interest but tax-exempt sav-
for council housing is determined according to in-
ings deposits and on budget appropriations.
come. Therefore, large operating deficits must be
balanced by additional subsidies. Consequently, the
As a result of long-lasting regulation, the private
maintenance of local authority housing is not up-to-
rental housing stock is currently of below-average
date. In principle, council tenants may buy their
standard and partly needs renovation. This sector
respective dwelling.
mainly accommodates lower-income households.
The private rental sector used to be strictly regu-
The French housing benefit system is well devel-
lated but was deregulated in the 1980s. However,
oped but housing benefit payments are considered
security of tenure is far from adequate. Most pri-
as a reduction of housing expenditure and therefore
vate rental housing is let as furnished dwellings.
are directly transferred to the respective landlord.
Therefore, it must be considered as a largely tem-
This practice has negative consequences.
In view of strongly rooted private property rights,
Irish legislators were not able to introduce a per-
GR / Greece
manent general property taxation system. At least,
Rapid population growth during the early post-war
former unlimited deductibility of mortgage interest
decades was mainly concentrated in the capital
for the acquisition of owner-occupied housing has
region which now accommodates almost one-third
been restricted in recent years.
of the entire population. The development of Greek
settlements was based on small-scale land owner-
ship and loose, if any, planning. Because of gener-
ally low incomes, many households were often
obliged to cover their housing needs by illegal self-
help building. The main characteristic of Greek
housing is a high percentage of owner-occupied
housing, usually acquired with a large share of
savings and financial help by the family. Over and
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
IT / Italy
In the private rental sector official rent guidelines
Italy is marked by large regional differences. Mas-
apply but are not always respected. In any case,
sive migration from the
mezzogiorno to the north
there are no general demand-side subsidies. Only
caused additional housing demand. As a comple-
beneficiaries of the guaranteed minimum income
ment to insufficient official housing production,
are also entitled to a rent supplement.
large numbers of illegal self-developed homes were
initially tolerated and later often sanctioned by the
authorities. However, the enormous scope of ir-
regular self-help housing was fraught with severe
NL / Netherlands
ecological consequences. On the other hand, innu-
After 1945, the Netherlands experienced strong
merable legal requirements make it extremely diffi-
population growth. Housing policy therefore aimed
cult for Italians to stick to the rules.
at providing a maximum number of new dwellings
through rationalised construction as well as eco-
Ambitious multi-year official housing construction
nomical design and equipment. Provision of land is
programmes distinguished between fully subsi-
the task of local authorities which thereby largely
dised rental housing, partially subsidised owner-
control local land markets. By prescribing certain
occupied housing and flexible subsidisation
construction densities and cost-covering land
schemes for private developers. Public rental hous-
prices, speculation with land was largely avoided
ing is produced and operated by limited-profit
while, at the same time, land was used sparingly.
housing companies. Rents in this sector are income-
related and far too low to cover operating expendi-
Moving from one community to another was dis-
ture. Because of frequent sales of dwellings to sit-
couraged by the requirement that one had first to
ting tenants, this sector is too limited in size to in-
obtain a local residence permit.
fluence the housing market. The low rent level also
Rental housing was originally subsidised by public
restricts household mobility and reduces fluctua-
loans and later by interest subsidies towards capital
tion. Apart from those income-related rents, there is
market loans. Actual housing production was the
no general housing benefit system yet.
task of limited-profit housing associations and of
Because of long-term market intervention, the pri-
larger local authorities. In 1990, the subsidised
vate rental sector has lost importance. However,
housing stock represented over 40 % of all dwell-
many restrictions were circumvented by illegal
ings. Both in the subsidised rental sector and in the
private sector rents were determined according to a
utility-value system whose basic point price was
The dominant owner-occupied sector benefits from
adjusted every year.
deductibility of mortgage interest and from gener-
ally low taxation.
Necessitated by rapidly rising operating subsidies,
Dutch housing policy was thoroughly reformed in
the 1990s. Limited-profit housing associations be-
came largely independent, credit had to be ob-
LU / Luxembourg
tained on the capital market and rents had to cover
The country's small size and its large share of for-
costs. On the other hand, part of existing housing
eign residents make Luxembourg a special case.
stock could be sold. Owner-occupation still enjoys
More than half of all employed persons are foreign
unlimited deductibility of mortgage interest.
nationals. Financial services take up a higher than
The housing benefit system is an important element
average share in the national economy.
in Dutch housing policy. It is available for all ten-
Luxembourg has kept its housing policy instru-
ants. During the late 1990s, more than half of all
ments almost unchanged over the last 20 years.
direct housing policy expenditure went into hous-
Widely preferred owner-occupation benefits from
construction grants, interest subsidies and savings
contract premiums. More importantly, generous
refunding of value-added tax for new owner-
occupied housing provides a strong incentive to
acquire one's dwelling. On the other hand, de-
ductibility of mortgage interest is limited. Supply of subsidised rental housing is restricted.
On the other hand, rents in this sector depend on
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
PT / Portugal
New housing was largely developed by municipal
Strong fluctuations characterised Portuguese
housing companies which up to this day are impor-
demographic development. Outward migration of
tant providers of housing. Municipal dwellings are
„guest workers", Portuguese citizens returning
open to all households and are therefore not con-
from the former colonies and internal migration
sidered to be „social housing". Rents are deter-
from eastern to western regions all caused shifts in
mined by corporate negotiation and serve as a basis
housing demand. Household incomes being low, a
for rents in the private rental sector, too. Tenants
large share of new housing was produced by self-
enjoy far-reaching participation rights. Due to cur-
help in illegal settlements. Growing slums within
rent migration from smaller towns to the three met-
and around cities were at first ignored by the au-
ropolitan areas, many small municipal housing
thorities, but later eradication was attempted.
companies are faced with vacancy of new (and
It was not until the late 1990s that the mostly pri-
expensive !) municipal housing.
vate housing output reached a level resulting in a
Independently, the co-operative housing sector
general improvement of housing conditions. A
progressively became more market-oriented and
considerable share of all housing is only used tem-
today in effect is a substitute for condominiums of
porarily or not at all.
owner-occupied flats, which are not permitted in
Directly subsidised public housing production rep-
resents a small share of total output. Original inter-
Subsidisation of new housing production followed
est subsidies were later replaced by public loans
the principle of tenure neutrality and was originally
and low-cost land from municipal land reserves. As
implemented through subsidised loans and later by
public rental housing is often sold to sitting tenants,
interest subsidies for capital market loans. During
the total stock remains quite small. Therefore, pub-
the 1990s, the latter were reduced in amount and
lic rental housing is considered as a transitory ten-
finally abolished for owner-occupied housing.
ure before passing on to owner-occupation. Rents
However, owner-occupiers are still entitled to a
are determined according to income.
30 % flat rate deduction of mortgage interest. Im-
puted rent has been abolished.
Housing co-operatives have become more active in
If household income is insufficient, there is entitle-
recent years but are mostly founded by better-off
ment to housing benefit regardless of tenure.
households. As a rule, they dissolve after comple-
Municipal land policy instruments, although avail-
tion of the respective project.
able, were not widely employed and landowners
For a long time, the private rental sector was subject
were left with considerable freedom of action.
to strict legal regulation. This prevented any nota-
ble private investment in rental housing. Only since
1990 have rent contracts been decontrolled.
UK / Great Britain
Buyers of owner-occupied housing are entitled to
During the early post-war decades, large accumu-
interest subsidies and first-time buyers additionally
lated housing deficits required substantial slum
enjoy tax allowances.
eradication programmes. In part, former residents
Only young households have access to a limited
moved to new satellite towns. Later, more conser-
housing benefit scheme.
vative urban renewal replaced large-scale slum
clearance. As of late, revitalisation of idle inner-city
land has become a priority.
SE / Sweden
Large-scale production of new housing was initially
a task assigned to local authorities, which thus built
Within the framework of general Swedish welfare
up large stocks of council housing, representing
policy, housing policy played an important role. Its
almost one-third of all housing in 1980. However,
aim was to provide every household with a mod-
inadequate management and considerable operat-
ern, comfortably equipped dwelling. With this in-
ing deficits caused by too low rent,
tention, housing output was to be boosted by the
inter alia moti-
vated the Thatcher government to restrict the hous-
„Million Programme" adopted in the early 1960s. It
ing role of local authorities drastically from 1979
materialised over a decade and consisted mainly of
onwards. In this vein, generous discounts were
large housing estates, often of a monotonous ap-
offered to sitting tenants who over time purchased
pearance. At the same time, many older residential
about two million former council dwellings. In ad-
buildings were demolished.
dition, a considerable share of local authority hous-
HOUSING POLICIES IN THE EUROPEAN UNION
Christian Donner / Vienna 2000
ing was transferred to limited-profit housing asso-
Part D presents a series of
suggestions by the author
ciations which were to assume the role of non-
(section D 1). They, too, follow the same subdivi-
market housing providers.
sion by policy areas used throughout the study.The
Rents in the private rental sector that had been
suggestions listed below may be considered as most
regulated for a long time were replaced by „fair
rents". Many private landlords therefore opted for
furnished or „holiday" letting which were not sub-
ject to any restrictions. In view of usually short
- general land tax
tenancy and limited tenure security, private rental
- effective capital gains tax
housing has essentially become a transitory tenure,
- general municipal pre-emptive purchase right
mostly for young households. Housing benefit is available for both rental sectors.
Housing construction
However, the design of the housing benefit
- acquisition of local authority housing stock
schemes implies a „poverty trap", i.e. households
often cannot obtain additional net income by taking
Housing finance
- establishment of a Housing Financing Fund (HFF)
Owner-occupation was traditionally favoured by
- refinancing by a pension fund
full deductibility of mortgage interest at the indi-
vidual marginal tax rate. However, deductibility
Housing stock
was reduced during the 1990s and finally abolished
- operation of local authority housing stock
in the year 2000.
- reduction of market intervention in the private
The low volume of housing completions in recent
years has lead to a further increase in the average
Housing expenditure and income
age of housing stock.
- general but limited housing benefit
- abolishment of real property transfer tax
Part C summarises the most important traits of
national housing policies and
housing markets. For
easy reading, there are no references and few fig-
ures (sections C 1 to C 15). All country reviews are
divided into the sections
development and
evaluation.
They should give a first impression of individual
In addition, section C 16 presents a comparative
synopsis of national housing policy
instruments and
some
statistical graphs for cross-national compari-
Finally, the European Union's possible role with
respect to housing policy is briefly discussed. Basi-
cally, official EU documents do not contain any
explicit reference to housing which, according to
the principle of subsidiarity, is left to national gov-
ernments. However, several EU directives concern
housing-related matters, such as competition, capi-
Dr. Christian Donner
tal markets, construction materials, etc. Further-
Schlimekgasse 15
more, the Maastricht criteria exert an indirect influ-
A - 1238 Vienna / Austria
ence on housing policies. Several subsidisation pro-
grammes concerning urban renewal and social
tel + fax (+43 1) 889 85 71
integration are simultaneously related to housing.
e-mail:
[email protected]
Finally, the European Parliament has passed a
web: www.donner.at/christian
number of resolutions on housing-related issues,
for example against social exclusion.
Source: http://www.donner.at/christian/downloads/EU%20English%20summary.pdf
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