Accountingdevelopments seminar
Building relationships,creating value
www.pwc.co.uk
November 2014
PwC
Agenda
The accountingregulator
3
New UK GAAP
5
Tax debate
6
Slide 2November 2014Accounting developments seminar
IFRS: What’s newfor 2014/15 andbeyond? 4
Telling the story –Corporatereporting 2
What’s happeningin the economy?
1
PwC
PwC
What’s happening in theeconomy?
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PwC
What’s happening in the economy?
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What’s happening in the economy?
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Telling the story –Corporate reporting
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Summary of 2013 reporting changes
Key areasof change
BIS narrativereporting
regulations
BISremuneration
reportingregulations
FRC UKCorporate
governancecode
FRC auditreports – ISA(UK&I) 700
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BIS narrative reporting regulations – Key themes
Slide 8November 2014Accounting developments seminar
Reportingresponse to
changes
Strategy andbusiness models
Non-financialreporting
Some instancesof non-
compliance
Standalonestrategic reports
PwC
BIS narrative reporting regulationsFindings from review of FTSE 100*
Materiality, strategic focus and linkage
*Findings based on 85 FTSE 100 reports released September 2013 to March 2014
22%: Identify whatthey see as theirmaterial issues
22% 25% 53%41%
25%: Use strategyto underpinthe report
53%: Align strategywith KPIs
41%: Businessmodel disclosures
sit in isolation
Slide 9November 2014Accounting developments seminar
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BIS narrative reporting regulationsKey themes from final guidance from FRC issued June 2014
Spirit of thelegislation
Slide 10November 2014Accounting developments seminar
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FRC UK Corporate Governance CodeMain changes – Years beginning 1 Oct 2014 onwards
Going concern
Risk management and internal control
Remuneration arrangements
• Clawback and deferral
Response to votes against at AGM
• Explain how companies plan to engage
Slide 11November 2014Accounting developments seminar
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FRC UK Corporate governance codeStatements relating to going concern, viability and risk
• C.1.3 – Expanded version of going concern confirmation
• C.2.2 – Longer term ‘viability’ statement – ‘reasonable expectation’
• C.2.1 – ‘Robust’ assessment statement for principal risks and how managed/mitigated
Slide 12November 2014Accounting developments seminar
FRC focus onformal statementsand related auditorreporting
Compare with fair,balanced andunderstandablestatement
New processesand information
PwC
More transparent tax reporting: Country-by-country reporting
• Fiscal deficits, campaigns from civil society organisations and public interest have ledto increased stakeholder scrutiny over tax
• Governments and regulators have responded by introducing country-by-countryreporting
- A number of different regimes in place
- Banks and extractive industries already affected – Public disclosure
- All MNCs – Private disclosure to tax authorities
- Reporting of profits/turnover/tax/employee information/payments to governments
• Companies have responded by increasing voluntary disclosures e.g. over their taxstrategy and Total Tax Contribution
November 2014Accounting developments seminarSlide 13
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Accounting regulatoractivity
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Spotlight on the accounting regulator – CRRT
Key messages – Quality ofcorporate reporting
• FTSE 350 – Complex or unusualtransactions
• Objective to look at all FTSE 350every 3-4 years
• Smaller listed and AIM quotedcompanies 3-year project
• Making annual reports andaccounts more concise and relevant
Process
• Timetable
• Discussion with auditors
• Liaison with Audit Quality Review
• First letter – Well-reasoned,high quality
• Requests for information
• Changes to CRRT operatingprocedures
• Transparency and panel references
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2014 Annual report – Published 14 October 2014
Panel activity 2014 2013 2012
Accounts reviewed 271 264 326
Companies written to 100 91 130
Complaints and referrals 16 8 9
Review groups - 4 5
Press notices 2 1 –
Committee references 9 10 6
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Priority sectors for March 13 to March 15
Priority sectors2013/2014
Construction
Natural resourcesRetail
Business support
Priority sectors2014/2015
IT (includingsoftware companies)
Support services
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Key areas of questioning – Important disclosureconsiderations
Businessreviews/strategic reports
Clear & concise
Principalrisks anduncertainties
Accountingpolicies(particularlyrevenue)
Significantjudgementsand estimates –includingconsolidation/associates
Classificationof cash flows
Impairmentof assets
Pensions
Tax
Exceptional andother similarterms
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Alternative performance measures
2005
CESR recommendationon alternativeperformance measures
January 2014
FRC statement onnon-GAAP measures
February 2014
ESMA consultation
Key principles
• Even-handed
• Gains and losses should not be netted off
• Consideration of recurring amounts
• Track items across periods
• Explain tax effects
• Material cash amounts clearly explained
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Investor views on APMs
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IFRS: What’s new for2014/15 and beyond?
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‘Pack of 5’ consolidation standards
• IFRS 10 Consolidated financial statements
• IFRS 11 Joint arrangements
• IFRS 12 Disclosure of interests in other entities
• IAS 27 Separate financial statements (revised 2011)
• IAS 28 Investments in associates and joint ventures (revised 2011)
Endorsed for EU entities for annual periodsstarting on, or after, 1 January 2014
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IFRS 10 – Consolidatedfinancial statements
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IFRS 10 – What is control?
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PowerVariablereturns
Ability to use power to affect returns
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Potential impact of IFRS 10
New consolidationrequirements?
More or lessconsolidation?
Who will be mostimpacted?
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Potential impact of IFRS 10
New consolidationrequirements?
More or lessconsolidation?
Who will be mostimpacted?
• Builds on existingcontrol guidance
• Additional contextand applicationguidance
• IFRS 10 will changethe way control isassessed – Focus onall three elementsof control
• Most consolidationdecisions should beunaffected
• May result in moreconsolidation orde-consolidationdepending on brightlines applied underIAS 27/SIC 12
• Entities with minorityvoting rights but withcontrol
• Banks and financialinstitutions withstructured entities
• Entities with potentialvoting rights
• Fund or assetmanagers with agencyrelationships
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Potential impact of IFRS 10
New consolidationrequirements?
More or lessconsolidation?
Who will be mostimpacted?
• Builds on existingcontrol guidance
• Additional contextand applicationguidance
• IFRS 10 will changethe way control isassessed – Focus onall three elementsof control
• Most consolidationdecisions should beunaffected
• May result in moreconsolidation orde-consolidationdepending on brightlines applied underIAS 27/SIC 12
• Entities with minorityvoting rights but withcontrol
• Banks and financialinstitutions withstructured entities
• Entities with potentialvoting rights
• Fund or assetmanagers with agencyrelationships
Slide 27November 2014Accounting developments seminar
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Potential impact of IFRS 10
New consolidationrequirements?
More or lessconsolidation?
Who will be mostimpacted?
• Builds on existingcontrol guidance
• Additional contextand applicationguidance
• IFRS 10 will changethe way control isassessed – Focus onall three elementsof control
• Most consolidationdecisions should beunaffected
• May result in moreconsolidation orde-consolidationdepending on brightlines applied underIAS 27/SIC 12
• Entities with minorityvoting rights but withcontrol
• Banks and financialinstitutions withstructured entities
• Entities with potentialvoting rights
• Fund or assetmanagers with agencyrelationships
Slide 28November 2014Accounting developments seminar
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IFRS 11 – Jointarrangements
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Accounting implications on transition to IFRS 11
Joint control
• Contractually agreed sharing of control
• Unanimous consent over ‘relevant activities’
Jointly-controlledassets
Jointly-controlledoperations
Own/Share of assets, liabilities,revenue, expenses
• Equity accounting
• Proportionateconsolidation
Joint operations
Own/share of assets,liabilities, revenue,
expenses
Equity accounting(proportionate
consolidation notallowed)
IAS 31
IFRS 11
Slide 30November 2014Accounting developments seminar
Jointly-controlledentities
Joint ventures
PwC
IFRS 11 – Transition from proportionateconsolidation to equity accounting
Balance sheet Before
PP&E 10,000
Trade receivablesInventoryBank
2,0001,500
500
4,000
Trade payables (1,000) 3,000
Deferred tax (2,500)
Borrowings (5,000)
Net assets 5,500
Income statement
Revenue 15,000
Cost of sales (10,000)
Gross profit 5,500
Balance sheet After
PP&EInvestment in joint venture
5004,725
Trade receivablesInventoryBank
--
500
500
Trade payables (100) 400
Deferred tax (125)
Borrowings -
Net assets 5,500
Income statement
Revenue -
Cost of sales -
Gross profit -
Share of profit of joint ventures 5,000
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IFRS 12 – Disclosure
Slide 32November 2014Accounting developments seminar
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IFRS 12 – Objective and things to consider
Why needed?
• Allow a user to evaluate the risksassociated with and the effect ofan entity’s interests in otherentities on financial position andcash flows
What do reporters need tothink about?
• Is the reporting entity exposed toinvestments that are not on thebalance sheet?
• What unusual arrangements arethere that users might beinterested in?
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IFRS 12 – Practical concerns
Do I need new processes to compile the information?
Needinginformation fromthird parties
Judgementsmade
NCIconsiderations:
• Financialinformation
• Determiningmateriality
Unconsolidatedstructuredentities
Slide 34November 2014Accounting developments seminar
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IFRS, new UK GAAP (FRS 102) and currentUK GAAP
IFRS New UK GAAP(FRS 102)
UK GAAP
Power/ability to use/variable returns
Similar to old IAS 27
Retained interestremeasured at FV
No remeasurement
If control is retained – Equity Step up – Goodwilladjustment
Step down – Gain/loss in P&L
Not amortised Amortised
Subsidiaries
Control
Partial disposals(control lost)
Transactionswith NCI
Goodwill
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IFRS, new UK GAAP (FRS 102) and currentUK GAAP
Joint arrangements
Slide 36November 2014Accounting developments seminar
IFRS New UK GAAP(FRS 102)
UK GAAP
Joint ventures
Joint operations
Similar to old IAS 31
Equity method ‘Gross equity’method
Much moredetailed disclosurerequirements inIFRS 12
Types
Partial disposals(control lost)
Disclosures
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IFRS 9 – FinancialInstruments
Slide 37November 2014Accounting developments seminar
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IFRS 9 – Timeline and effective date
• IFRS 9 replaces IAS 39
• Effective for annual periods beginning onor after 1 January 2018
• Earlier application is permitted
IFRS 9 will apply to all entities butis still subject to EU endorsement
July 2014
Final standard
Oct 2011 – Nov 2013
Various phasesundertaken
Slide 38November 2014Accounting developments seminar
2018
Effective date
PwC
IFRS 9 key highlights
IFRS 9
Impairment‘Expectedcredit loss
model’
HedgingClassification
andmeasurement
Slide 39November 2014Accounting developments seminar
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IFRS 9 Impairment: Expected Credit Loss (ECL)model
• ‘Three-stage’ model
• For trade and lease receivables, a simplified option: lifetime ECL provision
Start to maintain data to support basis
• For financial institutions and other entities with large portfolios of financial assets,credit information systems will need updating
• Extensive disclosures will be required
Change in credit quality since initial recognition
12-month expectedcredit losses
Lifetime expectedcredit losses
Lifetime expectedcredit losses
1) Performing
Initial recognition*
2) Under-performing
Assets with significantincrease in credit risk since
initial recognition*
3) Non-performing
Credit impaired assets
*Except for purchased or originated credit impaired assets
Slide 40November 2014Accounting developments seminar
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IFRS 9 hedging introduces significant benefits
Benefits
• Accommodates typical riskmanagement strategies
• More hedging relationshipswill qualify
• Requires judgement/considerationof qualitative factors rather thanmathematical tests
• Now possible to hedge riskcomponents of non-financial items
• Less P&L volatility when hedgingwith forwards and options
Actions
• Determine whether more of yourrisk management strategies willqualify for hedge accounting
• For new hedges that expire after2018 ensure that both the IAS 39and IFRS 9 hedge accountingrequirements are met
Slide 41November 2014Accounting developments seminar
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IFRS 9 Classification and measurement
Slide 42November 2014Accounting developments seminar
What has changedunder IFRS 9?
Who/what will beimpacted?
Actions
• New basis forclassification
• Measurement at fairvalue through OCImore limited
• No splitting ofembedded derivatives
• Equities recognised atfair value
• Financial institutions
• Receivables heldas AFS
• Receivablescontaining embeddedderivatives
• Unquoted equitiesheld at cost
• Need to start trackinghistorical information
• Consider howmeasurement maychange – fair valuethrough P&L?
• Begin consideringprocess for obtainingvaluations
PwC
IFRS 15 – Revenue fromcontracts withcustomers
Slide 43November 2014Accounting developments seminar
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IFRS 15 – Project objective
Effective for annual periods beginning on or after 1 January 2017
One Model
A single, joint revenue standard to be applied across all industries and capital markets
Clearprinciples
Robustframework
Comparabilityacross
industries
Enhanceddisclosures
Simplifiedguidance
Slide 44November 2014Accounting developments seminar
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IFRS 15 – Revenue recognition model
IAS 18/11
Separate models for:
• Construction contracts
• Goods
• Services
Focus on risk and rewards
Limited guidance on:
• Multiple element arrangements
• Variable consideration
• Licences
IFRS 15
Single model for performanceobligations:
• Satisfied over time
• Satisfied at a point in time
Focus on control
More guidance:
Separating elements, allocating thetransaction price, variable consideration,licences, options, repurchasearrangements
and so on…
Slide 45November 2014Accounting developments seminar
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IFRS 15 Revenue – The five step approach
Step 1 – Identify the contract with the customer
Step 2 – Identify the performance obligations in the contract
Step 3 – Determine the transaction price
Step 4 – Allocate the transaction price
Step 5 – Recognise revenue when (or as) a performance obligation is satisfied
Core principle
Revenue recognised to depict transfer of goods or services
Slide 46November 2014Accounting developments seminar
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IFRS 15 Revenue recognition model
An simple example…
• Contract: Entity sells products X, Y and Z to the customer
• Transaction price: C12m, 50% upfront, 50% when all three delivered
• Stand alone price: Each sold separately for C5m each
• Nature of products:
- Product X: Good, control transferred at a point in time
- Product Y: Good, control transferred at a point in time
- Service Z: Service transferred over one year
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Step 5 – Recognise revenue when (or as) a performance obligation is satisfied
Step 1 – Identify the contract with the customer
IFRS 15 Revenue recognition model – A simpleexample
Slide 48November 2014Accounting developments seminar
Step 1 – Signed contract exists
Step 2 – Identify the separate performance obligations in the contract
Step 3 – Determine the transaction price
Step 5 – C4m each = recognise when control of X/Y transfers
C4m = recognise over the period that Z is provided
Step 2 – Customer can benefit from X, Y and Z separately as they are sold separately –three separate performance obligations
Step 3 – The transaction price is fixed at C12m
Step 4 – Allocate the transaction price
Step 4 – 20% discount is allocated evenlyacross X, Y, Z
Total stand alone price = C15m
Total transaction price = C12m
Total discount = 20%
Discount * stand alone = C4m
PwC
IFRS 15 Transition
Option 1 – Full retrospective (Apply IAS 8)
2016 2017 Reliefs
Effective date = 1 Jan 2017
NEW
IFRS 15
NEW
IFRS 15
For completed contracts:
• No adjustment for interims
• Hindsight allowed for variableconsideration
Cumulative effect at 1 Jan 2016
Option 2 – Prospective
OLD GAAPNEW
IFRS 15
No reliefs
Cumulativeeffect at
1 Jan 2017
Disclose OLDGAAP
Slide 49November 2014Accounting developments seminar
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IFRS 15 Key areas of difference
• In the US, greatest impact for those that use industry based models
• New guidance on multiple elements – performance obligations
• Transaction price allocated on a relative selling price basis
• Change to model for variable consideration recognition
• New guidance on accounting for costs
• New model for licence revenue recognition
• In general, businesses with any combination of multiple elements, modifications, asignificant number of contracts
• Significant disclosure requirements
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IFRS 15 Practical considerations
• Reassessment of contracts will be time consuming
• Full retrospective application may require running dual systems and gathering ofhistoric data
• Opportunities to change contractual terms
• Impact on data requirements, the required systems and related processes and controls
• Potential impact on compensation arrangements
• Multiple stakeholders (Audit Committee, investor relations, FP&A, HR, IT)
Awareness is essential!
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New UK GAAP
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The frameworkAdoption timetable
1 Jan 2015
Mandatory adoption
(years commencing on or after 1 Jan 2015)
1 Jan 2014
Opening balance sheet31 Dec 2015
New FRS/IFRS
Now
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Your two key decisions: what and when
What GAAP should be adopted?
IFRS? FRS 101?FRS 102?
FRS 103?FRSSE?
Companies Act
When should entities adopt the new framework?
Transition subsidiariessimultaneously?
Stagger transition of subsidiaries?
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Revalued assets
Some key differences between existing UK GAAPand new UK GAAP
FinancialInstruments
Retirement and otheremployee benefits
Taxation
Others
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Financial instruments
Intercompany loans
Many intra group loans to bear no or little interest. Other loans may be repayable ondemand and some may not be documented. It is also common for intra group loans to betransferred between group companies at book value.
• FV at inception
• Repayable on demand
• Interest free/non market rates
• Letters of support
Type of financial instrument FRS 102 section Accounting treatment
Basic Section 11 Amortised cost
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Financial instruments
Further Considerations
• Determining fair values
• Hedging versus fair value through P&L – hedging considerations:
- Economic relationship required
- Effectiveness - no bright line
- Documentation
• Different tax hedging rules to be considered
• Company net investment hedging – no longer possible
Type of financial instrument FRS 102 section Accounting treatment
Complex Section 12 Fair value through P&L
Slide 57November 2014Accounting developments seminar
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Retirement and other employee benefits
Defined Benefit Schemes
• Group/multi employer schemes:
- At least one entity has to apply defined benefit accounting in its individual financialstatements
- Consider impact on distributable reserves when deficit is booked within entityaccounts
• Determining DB finance cost
• Pension asset surplus recognition
• Past service cost treatment
Holiday pay
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Revalued assets
• DT recognised on revalued assets v UK GAAP where only recognised on “bindingagreement to sell”
• Investment properties are required to be held at FV when they can be ‘measuredreliably without undue cost or effort’
• Fair value movements go through the P&L rather than through the STRGL/SORIE
• No FRS 102 exemption for investment properties that rented to group companies –PPE under SSAP 19
• Group may now have investment property (fair value) at the entity level (due tointragroup arrangements) but PPE on consolidation
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Other differences
• Business combinations
• Leases
• Foreign exchange
• Policy choices
- R&D
- Grants
- Capitalised borrowing costs
• Other, other differences!
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Taxation
• Tax transition date is 1 January 2015
• GAAP transition adjustments are taxed
• First cash tax payment impacted likely to be 14 July 2015
• Profit changes usually equals change to cash tax
• FRS 102 deferred tax recognition is on a timing + approach:
- Revalued assets
- No discounting of deferred tax
- Unremitted earnings of overseas subsidiaries
• Early adoption may result in positive cash flows (timing benefit and permanent benefitdue to reducing corporate tax rate)
• May result in negative cash flows but possible to restructure before transition date
Consider transitional adjustments early
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FRS 102Wrap up
• Financial Instruments
- Basic v complex
- Intercompany loans need to be reviewed
- Complex include forex forwards, interest rate swaps = fair value on balance sheet
- Hedging v fair value through p&l – hedging requirements to be assessed
• Recognition of pension deficit in at least one entity
• Revalued assets – deferred tax recognition required
• Investment property accounting may be triggered in entity accounts
• Other significant measurement differences include business combinations, foreignexchange, leases, R&D and borrowing costs
• Transition may have an impact on distributable reserves and cash tax
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FRS 101 – Qualification Criteria
Conditions to be met to apply FRS101:
• Member of a group where parent prepares publicly available consolidated financial statements with true and fair view
• FRS 101 can’t be applied in group accounts
• JV’s/associates cannot apply
• Shareholders notified of disclosure exemptions
• Objections from less than 5% of shareholders
• Measurement principles of EU-IFRS (as amended by FRS 101) are adopted
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FRS 101Video – TUI Travel Plc
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FRS 101Identification of exemptions
Available exemptions
• Cash flow statement (IAS 7)
• Disclosure of the effect of futurestandards (IAS 8)
• Some related parties disclosure(IAS 24)
Available if ‘equivalent disclosures’in group accounts
• Some share-based payments(IFRS 2)
• Some business combinations(IFRS 3)
• Financial instruments (IFRS 7)
• Fair value measurement (IFRS 13)
• Disclosure exemptions not all automatic
• Certain exemptions only available if disclosure included in group accounts – considermateriality to entity
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FRS 101Identification of exemptions
Financial instrument disclosures
• Financial institutions
• Non-financial institutions – financial instruments at fair value
Financial institutions
• Eight defined types of institution e.g. a bank
• Also ‘any other entity whose principal activity is to generate wealth ormanage risk through financial instruments’
• A parent entity whose sole activity is to hold investments in other group entitiesis not a financial institution
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What to considerTransition (FRS 101 and FRS 102)
• Underlying principle is retrospective application
• There are some exceptions and exemptions to the full retrospective rule
Mandatory exceptions
• Financial instrumentsderecognised before the date oftransition
• Hedging relationships that nolonger exist at date of transition
• Discontinued operations and NCI
Optional exemptions
• Business combinations
• Tangible fixed assets
• Lease incentives for leases thatcommenced before date oftransition
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What to considerFRS 101 vs FRS 102 – Our experience to date
FRS 101
• Listed group subsidiaries or overseasowned IFRS group reporters
• Companies looking to list/exit in theforeseeable future
Consider transition yeartransactions
• Unlawful distributions
• Business combinations
• Material new contracts
• Refinancing
Other considerations
• Measurement differences in every area -devil is in the detail.
• Financial instruments proving complex
• Tax teams need to be involved
• Disclosure/accounts presentationsignificantly different
Slide 68November 2014Accounting developments seminar
FRS 102
• Everyone else!
• Groups are taking FRS 102 dormantexemption however
• Entities may be “reactivated” throughthe transition process
PwC
What to considerGroup reporting versus entity accounts
• Significant differences/complexity arises in groups transitioning to FRS 101 whereIFRS group reporting in place
• Transactions that are netted out on consolidation need to be considered at entity level:
- Intra-group loans
- Intra-group rentals/trading transactions
- Intra-group contracts
• Consideration of all contracts to ensure appropriate accounting under New UK GAAP
• Taxation will be based on IFRS measurement (FRS 101) not old UK GAAP profitswhich may result in significant tax movements
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Next steps
• Speak to your advisor
• Put an agreed plan in place soon
• Need support?
- PwC has dedicated New UK GAAP team
- Supporting many clients on their transitions
- Speak to your PwC contact/New UK GAAP team or
- Email –[email protected]
Need help andadvice from
PwC
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Tax debate
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In 2012 the tax landscape changed – Tax hit theheadlines…
Large UK Corporates hit the headlines for ‘questionable’ tax practices
Addressing the balance between perceived tax avoidance and ‘Britain is open for business’
‘Starbucks, Amazon &Google accused ofbeing immoral’
(Telegraph)
‘Cameron hits out ataggressive taxavoiders ‘
(Times)
‘Big 4 to appear atPAC’
(Economist)
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Where is the debate now?
• Tax is now in the boardroom
• Morality agenda sits closely with reputational agenda
• EU Reform
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The future of tax
• UK Economy shaped by huge economic and social change
• Significant impact on how businesses operate
• Yet basic structure of tax system remain unaltered for decades
• We need a tax system fit for the future
‘The world has changed and so should our tax system’
Andrew Sentance
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A tax system fit for the future
• A vision of what the UK will look like in several decades’ time and what that means fora tax system for future generations
• The international tax reform process to be multi-lateral to regain public trust whilesupporting – rather than stifling – global trade
• A focus on the wider impact of business-tax policies, not concentrating on corporationtax alone.
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What does this mean for you?
• Do you know what your Total Tax Contribution is as an organisation?
• Do you talk to that in your financial statements?
• Do you have an agreed tax strategy?
• Is your tax accounting robust? Have your tested where your weaknesses are – where isyour tax risk??
Slide 76November 2014Accounting developments seminar
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UK tax revenues 2014/15
27.6%
18.6%
18.7%
11.2%
9.2%
7.0%
4.2%3.5%
% of total tax revenue = £592bn
Income Tax NIC VAT Specific Expenditure tax
Local Taxes Corporation Tax Capital / Property Other
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Paying for tomorrow: Future tax
Creating a fit for purpose tax system – A major UK campaign investigating how theUK tax system could change to meet the needs of the modern and future economy.
Slide 78November 2014Accounting developments seminar
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Paying for tomorrow: Future tax4 key components
Student competition04
Citizens’ Jury01
Discussion paper – Time of a fresh look at ourtax system02
Business Jury03
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Join the debate – www.pwc.co.uk/futuretax
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Thank you
Contacts for your new UK GAAP teamon the next slide
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Your new UK GAAP contacts
Slide 82November 2014Accounting developments seminar
Matthew Walker
Assurance lead
T: 0121 265 6879
Andrew Wiggins
Tax lead
T: 0121 232 2065
Paul Carter
T: 07812 345683
Sarah O’Donnell
T: 07738 311222
Ajay Kabra
T: 07718 340387
Lucy Gartside
T: 07841 490455
Richard Kay
T: 07841 567888
Thomas Rees
T: 07960 019301
Helen Ditchfield
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