International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards

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  In the case of assets or CGUs with indefinite useful lives, the terminal value is calculated

  by having regard to the forecast maintainable cash flows that are expected to be

  generated by the assets or CGUs in the final year of the explicit forecast period (‘the

  terminal year’). It is essential that the terminal year cash flows reflect maintainable cash

  flows as otherwise any material one-off or abnormal cash flows that are forecast for the

  terminal year will inappropriately increase or decrease the valuation.

  Impairment of fixed assets and goodwill 1465

  The maintainable cash flow expected to be generated by the asset or CGU is then

  capitalised by a perpetuity factor based on either:

  • the discount rate if cash flows are forecast to remain relatively constant; or

  • the discount rate less the long term growth rate if cash flows are forecast to grow.

  Care is required in assessing the growth rate to ensure consistency between the long

  term growth rate used and the assumptions used by the entity generally in its business

  planning. IAS 36 requires an entity to use in the VIU calculation a steady or declining

  growth rate for subsequent years, unless an increasing rate can be justified. This growth

  rate must not exceed the long-term average growth rate for the products, industries, or

  country or countries in which the entity operates, or for the market in which the asset

  is used, unless a higher rate can be justified. [IAS 36.33].

  7.1.5

  Foreign currency cash flows

  Foreign currency cash flows should first be estimated in the currency in which they will

  be generated and then discounted using a discount rate appropriate for that currency.

  An entity should translate the present value calculated in the foreign currency using the

  spot exchange rate at the date of the value in use calculation. [IAS 36.54]. This is to avoid

  the problems inherent in using forward exchange rates, which are based on differential

  interest rates. Using such a rate would result in double-counting the time value of

  money, first in the discount rate and then in the forward rate. [IAS 36.BCZ49]. However,

  the method requires an entity to perform, in effect, separate impairment tests for cash

  flows generated in different currencies but make them consistent with one another so

  that the combined effect is meaningful. This is an extremely difficult exercise. Many

  different factors need to be taken into account including relative inflation rates and

  relative interest rates as well as appropriate discount rates for the currencies in question.

  Because of this, the possibility for error is great and the greatest danger is understating

  the present value of cash outflows by using too high a discount rate. In practice, valuers

  may assist entities to obtain a sufficiently accurate result by assuming that cash flows

  are generated in a single currency even though they may be received or paid in another.

  Significantly, the rate used to translate the cash flows could well be different from that

  used to translate the foreign currency assets, goodwill and liabilities of a subsidiary at

  the period end. For example, a non-monetary asset such as an item of property, plant

  and equipment may be carried at an amount based on exchange rates on the date on

  which it was acquired but generates foreign currency cash flows. In order to determine

  its recoverable amount if there are indicators of impairment, IAS 21 – The Effects of

  Changes in Foreign Exchange Rates – states that the recoverable amount will be

  calculated in accordance with IAS 36 and the present value of the cash flows translated

  at the exchange rate at the date when that value was determined. [IAS 21.25]. IAS 21 notes

  that this may be the rate at the reporting date. The VIU is then compared to the carrying

  value and the item is then carried forward at the lower of these two values.

  7.1.6

  Internal transfer pricing

  If the cash inflows generated by the asset or CGU are based on internal transfer

  pricing, the best estimate of an external arm’s length transaction price should be used

  in estimating the future cash flows to determine the asset’s or CGU’s VIU. [IAS 36.70].

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  Note that this applies to any cash inflow once a CGU has been identified; it is not

  restricted to CGUs that have been identified because there is an active market for

  their outputs, which are described at 3.2 above.

  In practice, transfer pricing may be based on estimated market values, perhaps with a

  discount or other adjustment, be a cost-based price or be based on specific negotiation

  between the group companies. Transfer prices will reflect the taxation consequences to

  the transferring and acquiring companies and the prices may be agreed with the relevant

  taxation authorities. This is especially important to multinational companies but may

  affect transfer prices within a single jurisdiction.

  Transfer pricing is extremely widespread. The following example describes a small

  number of bases for the pricing and the ways in which it might be possible to verify

  whether they approximate to an arm’s length transaction price (and, of course, even

  where the methodology is appropriate, it is still necessary to ensure that the inputs into

  the calculation are reasonable). An arm’s length price may not be a particular price point

  but rather a range of prices.

  Example 20.12: Transfer prices

  A vehicle manufacturer, Entity A has a CGU that manufactures parts, transferring them to the vehicle

  assembly division. The parts are specific to the manufacturer’s vehicles and the manufacturer cannot

  immediately source them on the open market. However, Entity A and other manufacturers in the sector

  do enter into parts supply arrangements with third parties, which set up the specific tooling necessary

  to manufacture the parts and could provide an external comparable transaction to help validate that the

  parts’ internal transfer price is equivalent to an arm’s length transaction. If not, the forecasts should

  be adjusted.

  Entity B is an oil company that transfers crude oil from the drilling division to the refinery, to be used in the

  production of gasoline. There are market prices for crude oil that can be used to estimate cash inflows in the

  drilling division CGU and cash outflows for the refinery CGU.

  7.1.7

  Overheads and share-based payments

  When calculating the VIU, entities should include projections of cash outflows that are:

  (i) necessarily incurred to generate the cash inflow from continuing use of the asset

  (or CGU); and

  (ii) can be directly attributed, or allocated on a reasonable and consistent basis to the

  asset (or CGU). [IAS 36.39(b)].

  Projections of cash outflows include those for the day-to-day servicing of the

  asset/CGU as well as future overheads that can be attributed directly, or allocated on a

  reasonable and consistent basis, to the use of the asset/CGU. (IAS 36.41).

  In principle, all overhead costs should be considered and most should be allocated to

  CGUs when testing for impairment, subject to materiality.

  Judgements might however be required to determine how far down to allocate some

  overhead costs and in determining an appropriate allocation basis, in particular when it

  comes to ste
wardship costs and overhead costs incurred at a far higher level in a group

  to the CGU/asset assessed for impairment. Careful consideration of the entity’s specific

  relevant facts and circumstances and cost structure is needed.

  Impairment of fixed assets and goodwill 1467

  Generally, overhead costs that provide identifiable services to a CGU (e.g. IT costs from

  a centralised function) as well as those that would be incurred by a CGU if it needed to

  perform the related tasks when operating on a ‘stand-alone basis’ (e.g. financial

  reporting function) should be allocated to the CGU being tested for impairment.

  Conversely, overhead costs that are incurred with a view to acquire and develop a new

  business (e.g. costs for corporate development such as M&A activities) would generally

  not be allocated. These costs are similar in nature to future cash inflows and outflows

  that are expected to arise from improving or enhancing a CGU’s performance which are

  not considered in the VIU according to IAS 36.44.

  The selection of a reasonable and consistent allocation basis of overhead costs will

  require analysis of various factors including the nature of the CGU itself. A reasonable

  allocation basis for identifiable services may be readily apparent, for example in some

  cases volume of transaction processing for IT services or headcount for human resource

  services may be appropriate. However, a reasonable allocation basis for stewardship

  costs that are determined to be necessarily incurred by the CGU to generate cash

  inflows may require more analysis. For example, an allocation basis for stewardship

  costs such as revenue or headcount may not necessarily be reasonable when CGUs have

  different regulatory environments, (i.e. more regulated CGUs may require more

  governance time and effort) or maturity stages (i.e. CGUs in mature industries may

  require less governance effort). The allocation basis may need to differ by type of cost

  and in some cases may need to reflect an average metric over a period of time rather

  than a metric for a single period or may need to reflect future expected, rather than

  historic, metrics.

  Overheads not fully pushed down to the lowest level of CGUs might need to be included

  in an impairment test at a higher level group of CGUs if it can be demonstrated that the

  overhead costs are necessarily incurred and can be attributed directly or allocated on a

  reasonable and consistent basis at that higher level. After a careful analysis, there could

  be instances when certain overhead costs are excluded from cash flow projections on

  the basis that they do not meet the criteria under paragraph 39(b) of IAS 36.

  Many entities make internal charges, often called ‘management charges’, which purport

  to transfer overhead charges to other group entities. Care must be taken before using

  these charges as a surrogate for actual overheads as they are often based on what is

  permitted, (e.g. by the taxation authorities), rather than actual overhead costs. There is

  also the danger of double counting if a management charge includes an element for the

  use of corporate assets that have already been allocated to the CGU being tested, e.g.

  an internal rent charge.

  In certain situations it may be argued that some stewardship costs are already included

  in the impairment test through the discount rate used. This would among other factors

  depend on the way the discount rate has been determined, and whether the relevant

  stewardship cost should be regarded more as a shareholder cost covered in the

  shareholders’ expected return rather than a cost necessarily incurred by the CGU to

  generate the relevant cash flows. Due to the complexity of such an approach it would

  need to be applied with appropriate care.

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  In many jurisdictions employees’ remuneration packages include share-based

  payments. Share-based payments may be cash-settled, equity-settled or give the entity

  or the counterparty the choice of settlement in equity or in cash. In practice, many

  share-based payment transactions undertaken by entities are awards of equity-settled

  shares and options. This gives the entity the possibility of rewarding employees without

  incurring any cash outflows and instead the cash costs are ultimately borne by the

  shareholders through dilution of their holdings.

  When it comes to impairment assessment, a question that often faces entities is whether

  and how to consider share-based payments in the recoverable amount, in particular the

  VIU calculation. IAS 36 itself does not provide any specific guidance as to whether or

  how share-based payments should be considered in determining the recoverable amount.

  As IAS 36 focuses on cash flows in determining VIU, it seems that expected cash

  outflows in relation to cash-settled share-based payments would need to be reflected

  in the VIU calculation. The future expected cash outflow could, for example, be

  reflected by the fair value of the award at the balance sheet date, through including the

  amount of that fair value expected to vest and be paid out in excess of the liability

  already recognised at that date in the VIU calculation. In such a case the liability already

  recognised at the date of the VIU determination would not form part of the carrying

  value of the CGU.

  While theoretically this seems to be straight forward, in practice it can be quite a

  challenging and judgemental task, in particular when the entity consists of a large

  number of CGUs. Share-based payments are in general awarded by the parent to

  employees within the group. There may be no correlation between any change in the

  value of share-based payments after the grant date and the performance of the

  employing CGU. This may be relevant in assessing whether and how such changes in

  value and the ultimate expected cash flows are allocated to a specific CGU.

  What is even less clear is whether an entity should reflect in the VIU calculation

  equity-settled share-based payments. Such share-based payment transactions will

  never result in any cash outflows for the entity, and therefore a literal reading of

  IAS 36 may indicate that they can be ignored in determining the recoverable

  amount. However, some might argue an entity should appropriately reflect all share-

  based payments in the VIU calculation, whether or not these result in a real cash

  outflow to the entity. Such share-based payments are part of an employee’s

  remuneration package and therefore costs (in line with the treatment under IFRS 2

  – Share-based Payment) incurred by the entity for services from the employee are

  necessary as part of the overall cash flow generating capacity of the entity. Others

  may argue that they need to be considered through adjusting the discount rate in

  order to reflect a higher return to equity holders to counter the dilutive effects of

  equity settled share based payment awards.

  The time span over which the recoverable amount is calculated is often much longer

  than the time period for which share-based payments have been awarded. Companies

  and their employees would often expect that further share-based payment awards will

  be made in the future during the time period used for the recoverable amount

  calculation. Depending on the respective facts and circumstances an e
ntity would need

  Impairment of fixed assets and goodwill 1469

  to consider whether to include the effect of share-based payments over a longer period,

  considering the discussion above.

  7.1.8

  Events after the reporting period

  Events after the reporting period and information received after the reporting period

  end should be considered in the impairment assessment only if changes in assumptions

  provide additional evidence of conditions that existed at the end of the reporting period.

  Judgement of all facts and circumstances is required to make this assessment.

  Information available after the year end might provide evidence that conditions were

  much worse than assumed. Whether an adjustment to the impairment assessment would

  be required or not would depend on whether the information casts doubts on the

  assumptions made in the estimated cash flows for the impairment assessment.

  Competitive pressures resulting in price reductions after the year end do not generally

  arise overnight but normally occur over a period of time and may be more a reaction to

  conditions that already existed at the year-end in which case management would reflect

  this in the year end impairment assessment.

  IAS 10 – Events after the Reporting Period – distinguishes events after the reporting

  period into adjusting and non-adjusting events (see Chapter 34). IAS 10 mentions

  abnormally large changes after the reporting period in asset prices or foreign exchange

  rates as examples of non-adjusting events and therefore would in general not be a

  reason to update year end impairment calculations. The standard implies that

  abnormally large changes must be due to an event that occurred after the period end

  and therefore more or less assumes that the cause of such abnormally large changes are

  not conditions that already existed at the year-end. However, management would need

  to carefully assess the reason for the abnormally large change and consider whether it

  is due to conditions which already existed at the period end.

  7.1.9

  ‘Traditional’ and ‘expected cash flow’ approach to present value

  The elements that must be taken into account in calculating VIU are described at 7

  above. IAS 36 requires an estimate of the future cash flows the entity expects to derive

 

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