The new UK GAAP The Financial Reporting Standard Volume 1

ICAEW
The new UK GAAP
Exploring the challenges presented by FRS 102 The Financial Reporting Standard
applicable in the UK and Republic of Ireland.
Volume 1
BUSINESS WITH CONFIDENCEicaew.com
Author biographies
Dr Nigel Sleigh-Johnson FCA
Nigel is Head of the Financial Reporting Faculty (FRF). He has responsibility for overseeing
the development of ICAEW policy on financial and non-financial reporting issues. He
was a major contributor to ICAEW’s 2007 study for the EU, EU Implementation of IFRS and
co-author of ICAEW’s publications The Future of IFRS (2012) and Moving to IFRS reporting;
Seven lessons learned from the European experience (2015). Since 2014 Nigel has been a
member of the Department for Business Innovation & Skills’ expert working group on UK
company law, the Accounting Directive Stakeholder Group.
Sarah Dunn ACA
Sarah is a technical manager in the FRF. Her responsibilities include preparing ICAEW
responses to consultations on financial reporting matters. Prior to joining ICAEW in 2013
Sarah worked within the quality assurance and technical team at Baker Tilly International,
conducting quality assurance reviews across the globe and providing technical support to
member firms.
Stephanie Henshaw FCA
Stephanie is Technical Standards Partner for Francis Clark LLP and chair of the FRF. She
is an experienced CPD presenter having presented a variety of audit and accountancy
courses to the profession over the last 20 years. She also provides financial reporting
based training to many major law firms.
Eddy James FCA
Eddy is a technical manager in the FRF. He qualified with KPMG and has extensive
experience of writing and presenting professional development courses on a wide range
of subjects including IFRS, UK GAAP and US GAAP. Eddy is a member of the Financial
Reporting Council’s UK GAAP Technical Advisory Group. He is the co-author of ICAEW’s
publications The Future of IFRS (2012) and Moving to IFRS reporting; Seven lessons learned
from the European experience (2015).
Marianne Mau FCA
Marianne is a technical manager in the FRF. Her responsibilities include keeping members
up to date on changes in financial reporting. Marianne qualified with BDO and prior
to joining ICAEW she was a presenter at BPP Professional Education, developing and
delivering training in IFRS and UK GAAP.
02
THE NEW UK GAAP
Introduction
UK GAAP IS CHANGING
FRS 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland is
the cornerstone of a new financial reporting regime that represents the most significant
change to UK GAAP in a generation and will see all extant FRSs, SSAPs and UITF Abstracts
withdrawn.
The new standard is effective from 1 January 2015 and will ultimately be used by the
majority of UK entities, with the exception of micro-entities. It differs in many ways from
current UK GAAP. Each reporting entity will need to assess these differences carefully and
determine their impact.
In a series of short articles first published in 2014 in Practicewire, ICAEW’s electronic
news bulletin for sole and small practitioners, the Financial Reporting Faculty outlined
some of the initial challenges reporting entities face when seeking to apply FRS 102 for
the first time. These articles are reproduced below, as originally published. They were
written primarily with practitioners in mind, although many of the issues raised will be of
common concern.
A second volume of articles published in 2015 will follow.
THE FINANCIAL REPORTING FACULTY
The Financial Reporting Faculty is committed to providing high quality, practical help to
ICAEW members and others navigating today’s complex world of financial reporting.
The faculty provides a range of resources on UK GAAP and IFRS reporting, including
practical factsheets, FAQs and webinars. All the resources can be found on the dedicated
section of ICAEW’s website at icaew.com/newukgaap. The faculty is also working with
ICAEW’s Technical Enquiries Services to expand the range of TES helpsheets available on
the new UK GAAP.
We hope that you find this compendium useful. It is available online and, on request, in
hardcopy (from [email protected]).
Dr Nigel Sleigh-Johnson
Head of Faculty
April 2015
THE NEW UK GAAP
03
Contents
Financial instruments – part 1
05
Financial instruments – part 2
06
Has deferred tax just got bigger?
07
Changes to goodwill
08
Investment properties: all change under FRS 102?
09
Why lease incentives will be spread more thinly under the new regime
10
04
THE NEW UK GAAP
Financial instruments – part 1
Eddy James explains that those who think that their clients won’t be affected by the new
UK GAAP’s requirements on financial instruments may need to think again.
I’d be a wealthy man if I had a pound for every time I’d heard somebody say since the launch of the new UK GAAP that they
don’t need to worry about accounting for financial instruments as their clients don’t get involved in anything like that. It’s a
perfectly understandable reaction. The trouble is, I beg to differ. The new regime’s requirements in this area are not only very
different from previous GAAP, they will also affect more businesses than you may think.
Foreign currencies
Many relatively small businesses will be involved in buying or selling overseas. They will often manage their exposure to
exchange rate movements by entering into forward contracts to eliminate uncertainty. Doing so effectively allows them to buy
or sell at a fixed exchange rate.
Under existing UK GAAP, accounting for such transactions is straightforward as SSAP 20 Foreign Currency Translation allows you
to book them using the forward exchange rate. In many ways this makes a lot of sense, as you know from the outset exactly
what you are going to pay or receive in sterling terms, so why not just record the debtor or creditor at that amount? But the
new regime doesn’t see it that way. It requires you to account for the sale or purchase and the derivative (ie, the forward
contract) used to hedge your exposure to exchange rate movements as two separate transactions.
So, the debtor or creditor would be recorded at the spot rate rather than the forward rate agreed with the bank, with any
gains or losses arising from exchange rate movements between initial recognition and settlement being recognised in profit
or loss. The derivative would also be recognised separately at fair value. This will typically be zero on initial recognition but will
change as exchange rates move up and down. Again any gains or losses will be recognised in profit or loss. Moreover, you’d
also need to revalue any such items outstanding at the balance sheet date.
If this sounds a bit convoluted, that’s probably because it is – especially as the overall impact on profits will be the same
as under the old regime. However, you need to be careful as gains and losses may well end up being recorded in different
accounting periods and this could affect your client’s bottom line. There are also potential tax implications.
Interest rate swaps
The recent scandal around the mis-selling of interest rate swaps shows that lots of smaller entities are also – perhaps
unwittingly – dabbling in other types of derivatives. And if they are, the new regime will require them to be recognised on
balance sheet at fair value with gains and losses going to profit or loss. In other words, just like the forward contracts discussed
above.
In most cases entities will be using the swaps to manage risk exposures rather than as a way of speculating on the markets. If
they are, they may well be able to reduce this volatility by applying the special hedge accounting rules. But doing so is easier
said than done as it involves jumping through a number of hoops before a hedge is eligible. In such circumstances, clients will
no doubt look to you for help so it is important that you are reasonably familiar with the ins and outs of this complex area.
Fair values
As we have seen, you’ll need to measure these derivatives at fair value whenever they are recognised on-balance sheet. In
most cases, you’ll need to ask your client’s bank – who will typically be the counterparty to any forward contracts or swaps –
to provide the year-end value of them. Doing so on a timely basis is advisable.
And there’s more ...
You may quite possibly think that actually none of the above applies to your clients. But don’t relax quite yet as there’s much
more to financial instruments accounting than derivatives and hedging. For example, bank loans are financial instruments and
in some cases they may need to be measured at fair value. The second part in this series will contain further explanations.
THE NEW UK GAAP
05
Financial instruments – part 2
Eddy James explains that, under the new regime, not all loans are created equal.
In my previous article, I explained that the new UK GAAP’s requirements in relation to financial instruments were very
different from the current regime and that these differences would affect more businesses than you may think.
That first part focused on derivatives, such as forward contracts and interest rates swaps. While hopefully you found it an
interesting read, it may have been a little bit exotic for some of you, who may have concluded, understandably, that this
financial instruments malarkey really isn’t an issue for your clients after all, despite my protestations to the contrary. But don’t
give up on me just yet, as there’s much more to financial instruments accounting than derivatives and hedging.
Bank loans
Take bank loans, for example.
You might not normally think of them as financial instruments, but that is what they are under the new regime. This means
that you’ll need to look at all existing loans closely to determine whether they qualify as ‘basic’ or ‘other’ instruments. The
distinction is an important one. If they are ‘basic’ instruments, they can be measured at amortised cost. This means that you
can carry on treating them in the same way as you do at the moment. On the other hand, if they are classified as ‘other’
instruments, you’ll need to measure them at fair value each year, which will result in potentially significant gains and losses
being recorded in profit or loss.
Determining whether something is or isn’t basic is no easy task. You’ll need to look carefully at the terms of the loan and
compare them to the relevant section of the standard to make sure that there’s nothing troublesome in there. Seemingly
innocuous terms – including repayments that are linked to inflation or certain prepayment features – could result in a loan
failing to qualify as basic. So it’s advisable to proceed with caution.
As noted above, if a loan is classified as other, the business will need to establish the loan’s fair value each year. This can
sometimes be a complex, time-consuming and expensive process. It may even be worth considering whether the terms of
loan agreements that will fail to be classified as basic could be amended to bring them onto the other side of the line. Doing
so may save time and money in the longer term.
Intercompany loans
The treatment of intercompany loans at zero or below market interest rates will also need to be looked at carefully. Under the
new regime, such loans will typically be measured at amortised cost, which will involve discounting the loan back to present
value using a market rate of interest.
This is further complicated, however, if the loan does not have a fixed term. There is some uncertainty about how such
arrangements should be treated as the standard is not clear. My view is that such loans should be treated as repayable on
demand and measured at nominal value unless there are contractual terms that indicate otherwise. Others, however, believe
that such loans should be discounted, though how exactly this would be done in the absence of a repayment date is not
entirely clear.
Conclusion
This is undoubtedly an area that will affect many small businesses, so it would be advisable to begin discussing it with your
clients as soon as possible. Doing so should help avoid any nasty surprises later on.
06
THE NEW UK GAAP
Has deferred tax just got bigger?
Marianne Mau considers whether the ‘timing difference plus’ approach in FRS 102 will
increase the amount recognised for deferred tax under UK GAAP.
The bugbear of the financial reporting world used to be deferred tax. More recently it’s been knocked off its perch by financial
instruments, but that doesn’t mean that the concepts underlying the provision for deferred tax have become any easier or, for
that matter, any less controversial.
Timing difference vs timing difference plus
The basic premise for providing deferred tax has not altered under the new UK GAAP. If there is a difference in the timing
of when a transaction is recognised for financial reporting and for tax purposes, for example capital allowances versus
depreciation charges, then a provision for deferred tax is required. This is simply an application of the accruals concept. When
the difference is considered permanent, then no deferred tax is recognised.
However, FRS 19 Deferred Tax does not require deferred tax to be provided on all timing differences. There are numerous
exceptions to the rule. For example, deferred tax is generally not provided on revalued assets, rolled-over gains or on
unremitted earnings from associates or subsidiaries. These exceptions reflect the ‘incremental liability approach’ adopted by
current UK GAAP ie, deferred tax is recognised only when it meets the criteria for recognition in its own right.
FRS 102 does not have the same exceptions as FRS 19 and, as a result, is sometimes referred to as having a ‘timing difference
plus’ approach. The lack of these exceptions means the provision for deferred tax could end up being higher in some cases.
What should you watch out for?
• FRS 102 requires deferred tax to be recognised on all revaluation gains rather than only when there is an agreement to sell a
revalued asset.
• FRS 102 requires deferred tax to be recognised on fair value adjustments when consolidating a subsidiary for the first time.
The deferred tax asset or liability adjusts the amount of goodwill recognised (though for subsidiaries acquired prior to
transition the adjustment to deferred tax will generally be against equity, not goodwill).
• FRS 102 requires, unless certain criteria have been met, deferred tax to be recognised on the unremitted earnings of
subsidiaries, associates and joint ventures rather than only to the extent that the distribution of earnings has been agreed.
• In some cases, FRS 102 requires measurement at fair value where cost may have been used previously eg, investments in
equity shares. The use of additional fair values may result in additional provisions for deferred tax.
• The transitional provisions in FRS 102 permit certain types of assets to be measured at ‘deemed cost’. The deemed cost is
generally based on the fair value of the asset or a previous revalued amount and may trigger further provisions for deferred
tax.
• The presentation of the deferred tax expense (or income) will follow the presentation of the related transaction (as is the
case under FRS 19). Therefore, the movement in deferred tax arising from the revaluation of investment properties will
be included as part of the tax charge for the year, whereas the deferred tax arising on the revaluation of properties will
generally be included in other comprehensive income.
Measurement of the deferred tax balance
As is the case under current UK GAAP, the tax asset or liability should generally be measured using the tax rates and laws that
have been enacted (or substantively enacted) by the reporting date that are expected to apply when the timing differences
reverse. Unlike current UK GAAP, however, FRS 102 does not permit deferred tax assets or liabilities to be discounted. Although
the discounting of deferred tax is not common, its prohibition could lead to further increases in deferred tax balances.
Why worry before preparing the first set of FRS 102 accounts?
Deferred tax is often dealt with as an adjustment after the year-end accounts have been prepared, so why worry about it now?
Well, aside from the unfamiliarity aspect, the key reason is the potential knock on commercial impact. The additional deferred
tax recognised under FRS 102 will reduce net assets, making the balance sheet look weaker. Banks and other users might judge
the company more harshly as a result. While some deferred tax adjustments will hit the revaluation reserve, others reduce
retained profit and so might impact on dividend decisions. Those are the sort of practical consequences that clients are likely
to want to know about sooner rather than later.
THE NEW UK GAAP
07
Changes to goodwill
Sarah Dunn highlights some key differences for goodwill under the new regime.
When it comes to goodwill, the new UK GAAP differs from current standards in two key areas. Firstly, the estimated useful
economic life (‘useful life’) of goodwill may need to change. And secondly, the fact that more intangible assets may need to
be recognised separately on a business combination may mean that less goodwill is recognised than is currently the case.
The extent to which these changes impact on your clients will, of course, depend on their individual circumstances. However,
at the very least careful consideration and a certain amount of planning will be required and they may well look to you for
advice.
Useful economic life
Under existing UK GAAP, reporting entities are required to estimate and justify the useful life of goodwill and amortise the
goodwill over this life. There is, however, a rebuttable presumption that goodwill has a maximum useful life of 20 years or less,
although it allows for longer or indefinite lives in some circumstances.
So what has changed? The new regime still requires that entities estimate and justify the useful life of goodwill. However,
goodwill is considered to have a finite useful life and therefore all goodwill needs to be amortised. Also, if an entity is unable to
make a reliable estimate of the useful life, it must not exceed five years*. These same changes also apply to intangible assets.
Entities therefore need to ensure that they obtain reliable evidence to support their estimates for the useful life of intangibles
as well as goodwill.
The impact of these changes on transition will differ between entities. For example, an entity which previously estimated the
total useful life of goodwill to be finite – say 20 years – may continue to do so provided that the estimate can be supported by
reliable evidence. In other words, there is no need to accelerate the period over which goodwill is written off provided that the
directors can justify the current useful life.
However, an entity which previously estimated goodwill to have an indefinite useful life will be required to prepare estimates
of the remaining useful life at transition and amortise goodwill over this life. If, exceptionally, the entity is unable to now
reliably measure the useful life then it cannot exceed five years.
Identification of intangibles in a business combination
Existing UK GAAP requires that identifiable intangible assets acquired in a business combination be included in the
consolidated financial statements of the acquirer at fair value when such assets are capable of being disposed of or settled
separately. Otherwise, they are subsumed into goodwill.
Under the new regime an entity will separately recognise identifiable intangible assets acquired in a business combination
when their fair value can be measured reliably. Importantly, an intangible asset is deemed ‘identifiable’ when it is either
separable from the entity or arises from contractual or other legal rights, regardless of whether those rights are transferable or
separable. As a result, more intangible assets (and related deferred tax) may be recognised separately than is the case under
current UK GAAP, resulting in a smaller goodwill balance.
The new approach will at the very least need to be applied to all acquisitions that occur after the date of transition. Your
clients will need to be prepared as valuations are often easier to obtain at the time of acquisition than in retrospect.
As a final point, it is worth bearing in mind that unless an entity chooses to restate its previous business combinations before
the date of transition, it is not required on transition to restate the carrying amount of goodwill or recognise separately any
intangibles previously subsumed into goodwill.
* Recent changes to company law will increase the maximum estimated useful economic life of intangibles, including goodwill, from five years to ten years when
there is no reliable evidence, with effect from 1 January 2016. The FRC is proposing to amend FRS 102 accordingly.
08
THE NEW UK GAAP
Investment properties: all change under
FRS 102?
Nigel Sleigh-Johnson considers some of the changes ahead when businesses holding
investment properties move to FRS 102.
While practitioners familiar with SSAP 19 Accounting for investment properties will find some of the corresponding requirements
of FRS 102 familiar, the new standard heralds some major accounting changes for businesses holding investment properties
(IPs).
Cost or fair value?
Where the fair value of an IP can be measured reliably without ‘undue cost or effort’, the IP must be measured at fair value at
each reporting date. As the UK has a well-established valuation profession, it should normally be possible to obtain a reliable
valuation without undue cost or effort. However, in rare circumstances this might not be the case, for example due to the
nature and location of the property. In such circumstances, an IP will be accounted for as property, plant and equipment, and
duly depreciated.
Revaluations: to profit or loss
The reporting of gains and losses under old and new UK GAAP differs fundamentally.
Under FRS 102, annual changes in the fair value of IPs are taken to profit or loss, whereas under SSAP 19, equivalent gains
and losses were taken in most cases to the STRGL. This may have a significant impact on reported performance. The resultant
earnings volatility may need to be explained to lenders and other users of the accounts.
Group companies
Where one group company lets property to another, FRS 102 introduces some new complexity.
SSAP 19 excludes property let to and occupied by another group company from the definition of an IP. There is no similar
exclusion in FRS 102. Thus in the individual financial statements of the lessor company, such properties will now fall within the
definition of an IP and will therefore generally be carried at fair value. The property will not be shown as an IP in the group
accounts however – from a group perspective, the property is owner-occupied.
Deferred tax
FRS 102 removes some of FRS 19’s exemptions from recognising deferred tax. As a result, in contrast to current UK GAAP (that
is, FRS 19), companies will often need to recognise significant deferred tax liabilities on revaluation gains, as explained by
Marianne Mau in her earlier article on deferred tax under FRS 102.
Distributable profits
The FRS 102 approach to IPs may well result in the inclusion of unrealised profits on revaluations in profit or loss. Such profits
are not distributable. Care should be taken to ensure that the inclusion of such amounts in retained profits does not result
in the inadvertent payment of unlawful dividends. It might be worth considering the transfer of any unrealised profits into a
separate non-distributable reserve to prevent this happening.
These and other changes to IP accounting make this an area of major change for many companies moving to the new UK
GAAP. It’s important to start to get to grips with the practical consequences.
THE NEW UK GAAP
09
The new UK GAAP: why lease incentives will be
spread more thinly under the new regime
Stephanie Henshaw considers how FRS 102 will change the period over which lease
incentives are recognised by both landlords and tenants.
The term ‘lease incentives’ covers a variety of mechanisms to encourage a tenant to sign a lease, often where the rent charged
is regarded as slightly higher than the market rate. Typical incentives are rent holidays and reverse premiums. Another
example for incentives is contributions to the new tenant’s fitting out costs.
Currently, lease incentives are allocated over the period to which the rent is adjusted to market rate, typically the first rent
review. New rules in FRS 102 will impact on how profits are reported, with a consequential tax impact. There is also a choice
for entities transitioning to the new standard.
A longer allocation period
Under FRS 102, lease incentives have to be allocated over the entire lease period, not just the period to the first rent review.
This could be a significantly longer period than at present and so the profit and loss impact could be significantly different.
Unallocated incentives will be reflected as accruals or prepayments on the balance sheet.
For example, suppose a company with a 10 year lease and a rent review in year three is given an 18 month rent holiday at the
outset. Under FRS 102, the incentive will be spread over the full 10 years, not over three years as at present. If the entity is the
tenant, the annual P&L charge increases compared to the current rule, but the benefit of the incentive is felt for longer. For a
landlord, annual P&L income decreases but, again, the effect of the incentive is felt for longer.
How does the allocation work if there is a break clause?
The lease period is the non-cancellable period of the lease plus any extension at the lessee’s option where, at the start of the
lease, the lessee is likely to opt to extend. Therefore the period to the break clause would only be relevant if it represents the
non-cancellable period and the lessee is unlikely to extend.
Dealing with leases entered into after transition to FRS 102
The new lease incentive rules apply to any lease entered into after the entity’s transition date to FRS 102. So, for a reporting
entity with a 31 December year end, the new rules will have to be applied to any lease entered into after 1 January 2014. If the
lease is entered into in the year to 31 December 2014, the entity will initially account for it under the current rules in its 2014
accounts but will then have to restate the comparatives in its 2015 accounts to reflect the new rules.
Dealing with leases entered into before transition to FRS 102
Where a lease containing an incentive clause is already in place at the date of transition to FRS 102 the entity has a choice: it
can either retain its existing allocation over the period to the rent review or restate its figures to spread the incentive over the
entire lease period*.
Where the impact on profit of restating is significant companies will need to consider whether restatement is beneficial or not.
For example, directors should consider the impact on covenant compliance or distributable profit.
A taxing decision
The treatment of lease incentives is currently an area where the tax treatment follows the accounting treatment. Therefore any
decision to restate an incentive under FRS 102 will have a knock on effect on taxable profit.
* This choice is available on a lease by lease basis.
10
THE NEW UK GAAP
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THE NEW UK GAAP
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