53 ways to structure a deal — private, hybrid and government

Owner grants development rights (JDA + limited power of attorney) but keeps title until handover. Developer builds entirely at own cost; the finished built-up area is split by an agreed ratio and each party sells or keeps its own units.

Owner share of built area

30–50

Common markets

IN · PK · EG · AE · SA

Same grant of development rights, but the owner takes a percentage of gross sales revenue instead of units. Developer controls pricing and sales; escrow and audit rights are standard protections.

Owner share of gross revenue

20–40

Common markets

IN · EG · SA · AE · PK

Owner conveys land into a new project company at an agreed value; that value becomes the owner's equity stake. Developer and investors contribute cash and expertise; profits distribute through a waterfall (capital back → preferred return → promote).

Owner equity of project

20–50

Common markets

US · GB · DE · AE · SA · ES

Owner keeps the freehold and grants a 49–99 year lease. Developer builds and owns the improvements for the term, paying ground rent (often ~4–6% of land value, with resets). Land and buildings revert to the owner at expiry.

Ground rent (of land value, p.a.)

4–6

Common markets

US · GB · DE · FR · PT · AE

A registrable in-rem right (up to 50 years, renewable) letting the developer build and own buildings on the owner's land — mortgageable and sellable. Buildings revert at expiry per contract. The Sharia-compliant workhorse of UAE/GCC land partnerships.

Annual musataha rent (of land value)

3–6

Common markets

AE · SA

German registered, inheritable, mortgageable right to own a building on another's land for 60–99 years. Owner receives indexed ground rent (Erbbauzins, ~1.5–4% of land value p.a.); at expiry the building is compensated (statutory minimum 2/3 of value for housing).

Erbbauzins (of land value, p.a.)

1.5–4

Common markets

DE

Owner transfers the plot and is paid in finished units of the future building (typically 25–35% of buildable area), transferred at completion. Spain and Portugal's classic owner-friendly structure; taxed on both legs — structure with advice.

Owner share of built area

25–35

Common markets

ES · PT

French sibling of the permuta: the landowner is paid partly or wholly in finished premises. Often paired with a VEFA forward-sale of the remainder to institutions.

Owner consideration (of revenue)

20–40

Common markets

FR

A promoter funds the planning application at its own risk. On consent, the land is sold on the open market; the promoter recovers costs plus a fee (~15–30% of net proceeds) and the owner keeps the rest. Aligns both parties to maximise price.

Owner share of net proceeds

70–85

Common markets

GB

Developer pays a small option fee for the exclusive right (3–10 years) to buy the land after securing planning, at market value minus an agreed discount (typically 10–25%).

Purchase price (of market value)

75–90

Common markets

GB · US

An institution buys the land day one and funds construction in draws (forward funding), or contracts to buy the completed building at a fixed price (forward sale). The developer earns a development margin; the owner usually exits cleanly at the land sale.

Investor discount to end value

5–15

Common markets

GB · DE · FR · ES · PT · US

Owner keeps ownership and funds the project; the developer acts as development manager for a base fee (2–5% of cost) plus a promote (10–30% of profit above a hurdle). Effectively a JV without a land transfer.

Developer promote (of profit above hurdle)

10–30

Common markets

GB · US · AE · SA · CN · DE

Owner sells to the developer's SPV but leaves 30–70% of the price in as a loan (second charge behind the senior lender) or as deferred payments tied to sales milestones — the owner becomes the project's mezzanine lender at ~8–15%.

Deferred portion interest (p.a.)

8–15

Common markets

GB · US · AE

Mostly for public or institutional land: the developer designs, builds, finances and operates for 20–50 years, paying an upfront premium and/or revenue share, then transfers the asset back.

Grantor revenue share

2–15

Common markets

IN · EG · CN · SA · PK

Parties define allowable costs, the developer builds and sells, and net profit (after defined costs, fees, finance and a profit waterfall) is split by agreed percentages, often with a preferred return and minimum guarantee.

Owner share of net profit

20–50

Common markets

AE · SA · IN · EG · GB · US

Owner takes a percentage of gross sales/rental/operating revenue, escrow-controlled, often tiered by threshold with a minimum guaranteed payment.

Owner share of gross revenue

20–40

Common markets

IN · EG · SA · AE

Approved GFA is allocated between parties as building/floor/unit entitlements, with value-equalisation and conversion from GFA to NSA/NFA at an agreed efficiency ratio.

Owner share of GFA

30–50

Common markets

IN · AE · SA · EG

Split defined on net saleable/leasable area by use (residential/retail/office/hotel) rather than gross GFA, isolating the owner from efficiency risk.

Owner share of NSA

25–45

Common markets

IN · AE · GB

Owner receives completed, income-ready assets (villas, apartments, offices, hotel rooms, warehouses, parking) of defined type/size/floor/view/value at a handover date, value-equalised against the land contribution.

Owner share as finished units

25–45

Common markets

AE · SA · IN · EG

Land bought at a fixed price, paid upfront, deferred, by milestone, from project sales/finance, in annual instalments or a cash-and-units mix, secured by escrow and (if deferred) a profit/interest rate.

Deferred-portion rate (p.a.)

0–12

Common markets

AE · SA · IN · GB · US · EG

Owner receives an agreed multiple of the initial land value (e.g. 1.25×, 1.5×, 2×) as final entitlement, split cash/units on a payment schedule with a security package; implies a target annualised return.

Land-value multiple

1.25–2

Common markets

AE · SA · IN

Any combination of cash, annual rent, upfront premium, GFA/NSA/ready-stock, net-profit or gross-revenue share, equity, preferred return, minimum guarantee and public-service/infrastructure obligations tuned to both parties.

Blended — components vary

Varies by deal

Common markets

AE · SA · IN · EG · GB · US

Fixed/escalating/indexed/turnover rent (or base + turnover) with an upfront premium, rent-free development period, renewal, assignment, sublease and financing rights, and development/handover/reinstatement obligations.

Base rent (of land value, p.a.)

4–8

Common markets

AE · SA · GB · US · DE · IN

Occupier/operator leases land, buildings or assets with rent partly crediting toward an eventual purchase at a pre-agreed price, transferring ownership once conditions are met.

Rent (of asset value, p.a.)

5–10

Common markets

AE · SA · EG · US

Operator manages the asset/business for a base management fee plus an incentive fee tied to performance, with the owner retaining ownership and most operating risk.

Base fee (of revenue) + incentive

2–8

Common markets

AE · SA · EG · US · GB

Owner sells the asset to an investor and immediately leases it back on a long lease, freeing capital while retaining use; rent, term, buyback options and repair obligations are the key terms.

Lease yield (of asset value)

5–9

Common markets

US · GB · DE · AE · SA

Contractor is reimbursed actual costs plus an agreed fee/margin; suits uncertain scope but shifts cost risk to the client, often capped or converted to GMP.

Contractor fee (of cost)

5–12

Common markets

US · GB · AE · SA

Contractor guarantees a ceiling price; costs below the cap are shared (pain/gain), costs above are borne by the contractor — blending cost-plus transparency with price certainty.

Savings share to owner

50–80

Common markets

US · GB · AE · SA

Contractor manages engineering, procurement and construction as the client's agent for a fee, with the client holding the works contracts and cost risk directly.

EPCM fee (of cost)

3–8

Common markets

AE · SA · US · GB · IN

Private party finances, builds, temporarily owns and operates the asset, then transfers ownership to the authority at concession end; lenders and grantor hold step-in rights and residual-value/handback terms are defined.

Grantor revenue/premium share

2–15

Common markets

IN · EG · SA · PK · CN

Private party builds, permanently owns and operates under licence/regulation with no transfer; land rights, tariffs, service standards and government oversight are set by contract/regulation.

Regulated return / tariff basis

6–15

Common markets

US · GB · SA · AE

Private party builds and immediately transfers ownership to the authority on completion, then operates under an operating agreement for a fee against performance standards.

Operating payment / fee

2–8

Common markets

CN · IN · SA

A single contractor takes design and construction under one contract — fixed-price, cost-plus, GMP, two-stage, fast-track or contractor-led — with optional consultant novation and early-contractor involvement.

Contractor margin (of cost)

5–15

Common markets

AE · SA · US · GB · IN · EG

Contractor designs, builds and finances construction, with the authority repaying via deferred/milestone payments at an agreed financing rate against a completion certificate.

Financing rate (p.a.)

4–9

Common markets

SA · AE · EG · IN

Private party designs, builds, finances and operates for the concession, paid via availability payments, user charges or government payments, subject to performance deductions.

Equity IRR (target)

8–15

Common markets

GB · SA · AE · IN

Full-lifecycle PPP: private party designs, builds, finances, operates and maintains — including lifecycle replacement — under a performance regime with service KPIs and handback/residual-life obligations.

Equity IRR (target)

8–14

Common markets

GB · US · SA · AE

Private party designs, builds, operates and maintains, while the authority (or a third party) funds the capital — bundling delivery and operations without private finance.

O&M fee / margin

3–10

Common markets

US · SA · AE

Long-term contract where the private party delivers and/or operates a public asset/service under a payment mechanism (government-pay, user-pay or hybrid) with a defined risk-allocation matrix.

Equity IRR (target)

8–15

Common markets

GB · SA · AE · IN · EG · US

The authority grants a private party the right to operate (and often build/rehabilitate) an asset and collect user charges for a defined period, paying a concession fee/revenue share and transferring the asset back at expiry.

Concession fee / grantor share

2–20

Common markets

EG · IN · SA · AE · PK · CN

Private party leases an existing asset/land, develops or upgrades it, and operates it for the lease term, paying rent and often a revenue share; the asset stays with the authority.

Rent + revenue share

3–12

Common markets

IN · SA · AE

Like LDO but the developed asset transfers to the authority at the end of the lease rather than continuing to be operated by the private party.

Rent + capex recovery

3–10

Common markets

IN · SA

Private party rehabilitates an existing (often distressed) asset, operates it to recover investment plus return, then transfers it back to the authority.

Operating revenue share

5–20

Common markets

EG · IN · PK

Private party rehabilitates and then permanently owns and operates the asset under regulation — no transfer back.

Regulated return

6–15

Common markets

US · GB · SA

Private operator runs and maintains an asset for a fee (fixed and/or performance-based) against KPIs; no capital or ownership transfer.

O&M fee (of opex)

2–8

Common markets

AE · SA · US · GB · IN

Authority pays the private party a periodic availability payment provided the asset is available and meets performance standards, insulating the private side from demand risk; deductions apply for unavailability/underperformance.

Availability payment (equity IRR)

7–12

Common markets

GB · SA · AE · US

Authority guarantees a minimum revenue/traffic/occupancy/purchase level (with upside sharing above a band), de-risking demand for the private party; take-or-pay and capacity payments are cousins.

Guaranteed floor (of base case)

60–90

Common markets

IN · SA · EG · CN

A creditworthy offtaker (often government) commits to buy the project's output — power, water, treated waste, capacity — at an agreed tariff for a long term (power/water purchase or take-or-pay agreements), underpinning project finance.

Contracted tariff (equity IRR)

8–14

Common markets

SA · AE · EG · IN · PK

Authority leases or concessions a mature, income-producing public asset to private investors for an upfront capital sum, recycling the proceeds into new infrastructure while retaining ownership and reversion.

Investor yield

6–12

Common markets

US · AE · IN · SA

Contractor delivers a fully complete, ready-to-operate facility for a fixed price, handing over the 'key' — maximum single-point responsibility including commissioning.

Contractor margin (of cost)

8–18

Common markets

AE · SA · EG · IN · PK

Contractor delivers engineering, procurement and construction under a lump-sum turnkey contract with performance guarantees — the infrastructure/industrial delivery standard.

EPC margin (of cost)

8–15

Common markets

SA · AE · EG · IN · PK · CN

EPC contractor also arranges/provides construction finance, repaid by the client over time — combining lump-sum delivery with a financing package.

Blended EPC + finance rate

6–12

Common markets

EG · PK · SA · CN

A private party proposes a project the authority did not tender; the authority evaluates it and, if it proceeds, either negotiates directly (with protections) or takes it to competition — often via Swiss Challenge.

Proponent advantage / cost recovery

Varies by deal

Common markets

IN · EG · PK · SA · AE

After an unsolicited proposal, the authority publishes it and invites competing bids; the original proponent gets a right to match (or is compensated) if a better bid emerges — combining origination incentive with competitive tension.

Right-to-match threshold

Varies by deal

Common markets

IN · PK · EG · PH