Негативное кредитование: Сравнение подходов в Австралии, Великобритании и Новой Зеландии.

Negative gearing is a form of financial leverage whereby an investor borrows money to acquire an income producing investment and the gross income generated by the investment (at least in the short term) is less than the cost of owning and managing the investment, including depreciation and interest charged on the loan (but excluding capital repayments). The investor may enter into a negatively geared investment expecting tax benefits or the capital gain on the investment after it is sold to exceed the accumulated losses of holding the investment. The investor would take into account the tax treatment of negative gearing, which may generate additional benefits to the investor in the form of tax benefits if the loss on a negatively geared investment is tax deductible against the investor's other taxable income and if the capital gain on the sale is given a favourable tax treatment.

Negative gearing can be a tax effective strategy in Australia, because the tax system has a single income tax schedule for income from all sources. This means that for taxation purposes net investment income losses can be offset against other types of income, such as wage or business income, with only a few limits or restrictions. Analysis found that negative gearing in Australia provides a greater benefit to wealthier Australians than the less wealthy. Federal Treasurer at the time, Scott Morrison, in defence of negative gearing, cited tax data that showed that numerous middle income groups (he mentioned teachers, nurses, and electricians) benefit in larger numbers from negative gearing than finance managers.

While allowing for negative gearing in its basic form, the United Kingdom does not allow the transfer of one type of income (or loss) to another type of income. This is due to its schedular system of taxation. In this type of taxation system, the tax paid is dependent on income source. Therefore, an individual who received an income from labour and from land would pay two separate tax rates for the two relevant income sources. Between 1997 and 2007, the Tax Law Rewrite Project changed this system by simplifying the schedules. As with the previous system, people would not be allowed to transfer incomes (or losses). A UK government online resource on renting out property in England and Wales outlines how to offset losses. It states that losses can be offset against "future profits by carrying it forward to a later year" or against "profits from other properties (if you have them)".

New Zealand abolished negative gearing in March 2021 and it will be fully phased out by April 2025. The Rental Income Guide states a loss can only be deducted against other incomes if the rental income is at market rate. The Opposition Labour Party attempted to raise negative gearing in the 2011 election, but after their failure to win government the issue reduced in significance. New Zealand now has ring fencing rules, abolishing negative gearing in the residential property market. Residential property deductions can only be made against residential property income and cannot be deducted from income from other sources, e. g. wages.

Canada allows the transfer of income streams in some situations. Personal business expenses may always be deducted from personal business income. If those expenses exceed business incomes (i. e., the business is losing money for tax purposes), the resulting "non capital loss" may be deducted from other personal incomes, so long as the Canada Revenue Agency (CRA) believes that it is a genuine business (and not a personal activity being used to generate tax losses). This loss may also be carried back up to 3 years, or carried forward up to 20 years, to offset income earned in those years. Interest paid on a loan can be treated as a business expense, so long as the money was borrowed to generate income. Claim the following carrying charges and interest you paid to earn income from investments: [ ] Most interest you pay on money you borrow for investment purposes, but generally only if you use it to try to earn investment income, including interest and dividends. However, if the only earnings your investment can produce are capital gains, you cannot claim the interest you paid.

In principle, the US federal tax does not allow the transfer of income streams. In general, taxpayers can only deduct expenses of renting property from their rental income, as renting property out is usually considered a passive activity. However, if renters are considered to have actively participated in the activities, they can claim deductions from rental losses against their other "nonpassive income". You actively participated in a rental real estate activity if you (and your spouse) owned at least 10% of the rental property and you made management decisions or arranged for others to provide services (such as repairs) in a significant and bona fide sense. Management decisions that may count as active participation include approving new tenants, deciding on rental terms, approving expenditures, and other similar decisions. It is possible to deduct any loss against other incomes, depending on a range of factors.

Japan allows tax payers to offset rental losses against other income. Individuals can claim losses against rental loss with minimal restrictions, but if the property was owned through a partnership or trust there are restrictions. There are a number of additional rules, such as restricting claims of losses due to Bad Debt. Additional information can be found in the Japan Tax Site.