193
TABLE 9.3
Comparison of four basic
sukuk
structures
Structure
Asset Type
Description
Benefi
ts
Considerations
Ijarah
Existing tangible assets such as plant, machinery, buildings, etc
Usufruct rights pertaining to tangible assets can be considered as well
Involves a sale and leaseback of tangible assets (or their usufruct rights)
Most commonly applied and accepted structure
Tradable on secondary market
Wide
Shari’ah
acceptability
(AAOIFI
compliant)
Relatively easy documentation process
Identifi
cation of assets
100% of assets have to be tangible
Assets remain in the ownership of investors till maturity
Assets should be unencumbered at time of sale
Head
lease
and sub
lease
Existing tangible assets
Involves long
- and
short
- term leases of
tangible assets
Tradable on secondary market
Shari’ah
acceptability
Template document available
Avoid sale of assets which can be sensitive in certain jurisdictions
Tangible assets required; with possibility of using suitable operating rights as underlying assets (subject to
Shari’ah
approval)
Long
- term lease has to be
for a period of more than 50 years (for
Shari’ah
structuring
purposes)
(Continued)