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

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  recognition of costs and revenue over the term of the arrangement. IAS 17 requires

  lessors and lessees to recognise operating lease payments on a straight-line basis over

  the lease term unless another systematic basis is more representative (see 5.1.2 below)

  Leases (IAS 17) 1615

  and this may not be in line with the payments for the lease element so some adjustments

  might be required. [IFRIC 4.BC39].

  See below for disclosure implications if the arrangement is deemed to contain an

  operating lease and the purchaser concludes that it is impracticable to separate the

  payments reliably.

  2.1.7 Disclosure

  requirements

  IAS 17 requires a general description of the lessee’s material leasing arrangements.

  [IAS 17.31(e)]. This will require disclosure of the details of major transactions that have

  fallen within IFRIC 4.

  As long as the entity is able to distinguish the lease payments from other elements of

  the lease, the disclosed information will relate only to the lease element of the

  arrangement. There appears to be no intention to require entities to disclose the service

  (executory) element of arrangements.

  If the arrangements are assessed as containing finance leases, these arrangements are

  deemed to be within the scope of IAS 17 and therefore within its disclosure

  requirements (see 9 below).

  However, if it were considered to be an operating lease, the Interpretation may result

  in additional disclosures, because IAS 17 specifies that the lessor and lessee should

  disclose the future minimum lease payments. Although the arrangements discussed in

  the Interpretation typically represent significant future commitments, purchasers are

  not required to disclose them in the financial statements unless they fall within the

  scope of IAS 17. The Interpretations Committee argues that bringing such arrangements

  within the scope of IAS 17 will provide users of financial statements with relevant

  information that is useful for assessing the purchaser’s solvency, liquidity and

  adaptability. [IFRIC 4.BC39].

  If the arrangement is one of those in which it is impracticable to separate the payments

  reliably, the Interpretation requires disclosure of all payments under the arrangement

  separately from other minimum lease payments, together with a statement that the

  disclosed payments also include payments for non-lease elements in the arrangement.

  [IFRIC 4.15].

  2.2

  Transactions that involve the legal form of a lease but are not, in

  substance, leases

  While there are some arrangements that contain leases that are not formally lease

  contracts, the reverse is also true: there are some formal lease contracts that do not, in

  substance, contain leases. These issues are addressed by SIC-27.

  Essentially, SIC-27 deals with the issue of how to evaluate the substance of

  transactions, or a series of linked transactions, in the legal form of a lease. The main

  purpose of the Interpretation is to reinforce the principle of substance over form,

  and to ensure that, where appropriate, a series of linked transactions should be

  accounted for as one transaction. If the transaction does not meet the definition of

  a lease under IAS 17, SIC-27 deals with the extent to which the arrangement gives

  1616 Chapter 23

  rise to other assets and liabilities of the reporting entity, the reporting of any other

  obligations and the recognition of fee income. [SIC-27.2].

  An entity may enter into a transaction or a series of structured transactions (an

  arrangement) with an unrelated party or parties (an investor) that involves the legal form

  of a lease. Although the details may vary considerably, a typical example involves an

  entity leasing or selling assets to an investor and leasing the same assets back. The lease

  and leaseback transactions are often entered into so that the investor may achieve a tax

  advantage. [SIC-27.1]. In recent years these arrangements have become less common as

  taxation authorities in various jurisdictions have restricted the tax benefits. The

  following example illustrates an arrangement that does not, in substance, involve a lease

  under IAS 17. [SIC-27.A2(a)].

  Example 23.4: Substance of an arrangement

  Entity A leases a specialised asset that it requires to conduct its business to an Investor and leases the same

  asset back for a shorter period of time under a sublease. At the end of the sublease period, Entity A has the

  right to buy back the rights of the Investor under a purchase option. If Entity A does not exercise its purchase

  option, the Investor has options available to it under each of which it receives a minimum return on its

  investment in the headlease – the Investor may put the underlying asset back to Entity A, or require it to

  provide a return on the Investor’s investment in the headlease.

  The arrangement achieves a tax advantage for the Investor who pays a fee to Entity A and prepays the lease

  payment obligations under the headlease. The agreement requires the amount prepaid to be invested in risk-

  free assets and, as a requirement of finalising the execution of the legally binding arrangement, placed into a

  separate investment account held by a Trustee outside of the control of the entity.

  Over the term of the sublease, the sublease payment obligations are satisfied with funds of an equal amount

  withdrawn from the separate investment account. Entity A guarantees the sublease payment obligations, and

  will be required to satisfy the guarantee should the separate investment account have insufficient funds.

  Entity A, but not the Investor, has the right to terminate the sublease early under certain circumstances (e.g.

  a change in local or international tax law causes the Investor to lose part or all of the tax benefits, or Entity A

  decides to dispose of (e.g. replace, sell or deplete) the underlying asset) and on payment of a termination

  value to the Investor. If Entity A chooses early termination, then it would pay the termination value from

  funds withdrawn from the separate investment account, and if the amount remaining in the separate

  investment account is insufficient, the difference would be paid by Entity A.

  A series of transactions that involve the legal form of a lease should be accounted for

  as one transaction when the overall economic effect cannot be understood without

  reference to the series of transactions as a whole. All aspects and implications of an

  arrangement should be evaluated to determine the substance of the arrangement, with

  greater weight given to those aspects and implications that will have an economic

  effect in practice. The accounting should reflect the substance of the arrangement.

  [SIC-27.3, 4].

  2.2.1 The

  arrangement

  First, the series of transactions must be part of a single ‘arrangement’; a series of

  transactions may be closely interrelated, negotiated as a single transaction, and take

  place concurrently or in a continuous sequence. [SIC-27.3].

  Second, there must be indicators that individually demonstrate that an arrangement

  may not, in substance, involve a lease under IAS 17. SIC-27 states that in circumstances

  such as those in Example 23.4 above, these indicators are as follows:

  Leases (IAS 17) 1617

  (a) the entity retains all the risk
s and rewards of ownership and there is no significant

  change in its rights to use the asset;

  (b) the primary reason for the arrangement is to achieve a particular tax result, and

  not to convey the right to use an asset; and

  (c) the options on which the arrangement depends are included on terms that make

  their exercise almost certain (e.g. a put option that is exercisable at a price

  sufficiently higher than the expected fair value when it becomes exercisable).

  [SIC-27.5].

  In other words, the entity retains more rights than it would in a straightforward sale and

  finance leaseback. In Example 23.4 above, for instance, it retains all of the residual

  interests in the asset. The investor has no interest at all in the underlying asset while a

  lessor under a finance lease will often retain title and some residual value in the asset.

  The investor has only entered into the transaction to obtain a tax benefit.

  2.2.2

  Accounting for assets and liabilities arising under the arrangement

  The balances arising under the arrangement (in Example 23.4 these comprise the

  separate investment account and the lease payment obligations under the sublease)

  must be assessed to see whether they represent assets and liabilities of the entity.

  SIC-27 refers to definitions of assets and liabilities and guidance in the Conceptual

  Framework for Financial Reporting (‘Framework’). [CF(2010) 4.4-19]. It argues that:

  (a) the investment account is not an asset of the entity because it cannot control it;

  (b) there is only a remote risk that the entity will have to pay out under the guarantee

  or reimburse the entire amount of any fee received; and

  (c) once the arrangement has been set up and the initial payments have been made,

  no further cash flows will be made by the entity.

  The entity cannot use the cash in the investment account for its own benefit, nor can it

  prevent it from being used to make lease payments to the investor. The lease payments

  will be satisfied solely from funds withdrawn from the separate investment account

  established with the initial cash flows. In the example, the terms of the arrangement

  require that a prepaid amount is invested in risk-free assets that are expected to

  generate sufficient cash flows to satisfy the lease payment obligations. [SIC-27.6]. This also

  demonstrates, among other things, that the entity is not, in substance, entering into a

  financing arrangement, as it has no need for the funds.

  Care must be taken to ensure that the assets in which the prepayment is invested are in

  fact ‘risk-free’ and this will have to be monitored throughout the arrangement. The

  financial crisis in 2008 revealed that many so-called ‘AAA’ or ‘risk-free’ assets, including

  sovereign debt, were not risk-free, leaving entities exposed to shortfalls in the cash held

  in the investment account for which they may have been required to make provision.

  Other obligations of the entity, including any guarantees provided and obligations incurred

  on early termination, should be accounted for under IFRS 4 – Insurance Contracts (or

  IFRS 17 – Insurance Contracts – if the entity applies that standard), IAS 37 – Provisions,

  Contingent Liabilities and Contingent Assets – or IFRS 9 – Financial Instruments,

  depending on the terms of the arrangement. [SIC-27.7]. Therefore, if Entity A were to elect

  to terminate the arrangement, it would have to provide for its exposure in excess of the

  1618 Chapter 23

  available funds in the investment account. In addition, if the arrangement is within a special

  purpose entity or trust, the entity will need to consider the effect of IFRS 10 –

  Consolidated Financial Statements. The interaction of IFRS 10 and IAS 17 in connection

  with special purpose entities leaves room for interpretation, but the Interpretations

  Committee decided in May 2015 not to clarify the matter (see Chapter 6 at 4.1.3).

  2.2.3 Fee

  income

  SIC-27 addresses the recognition of fee income. There are many factors that could

  affect the economic substance and nature of the fee, and it may not be appropriate to

  recognise it in its entirety at the inception of the agreement if the entity has significant

  future performance obligations, retained risks or a significant risk of repayment. Factors

  to be taken into account include:

  (a) obligations that are conditions of earning the fee so that entering into the

  agreement is not the most significant act required by the arrangement;

  (b) limitations are put on the use of the underlying asset that lead to significant

  changes in the entity’s rights to use the asset, e.g. the entity’s right to deplete or sell

  it or pledge it as collateral;

  (c) the possibility of reimbursing any amount of the fee and possibly paying some

  additional amount is not remote. This occurs when, for example:

  (i) the underlying asset is essential for the entity’s business, in which case there

  is a possibility that the entity may be prepared to pay to terminate the

  arrangement early and be required to repay all or part of the fee; or

  (ii) the possibility that there are insufficient assets in the investment account to

  meet the lease payment obligations is not remote, and therefore it is possible

  that the entity may be required to pay some additional amount. This may

  occur if the entity is required, or has some or total discretion, to invest in

  assets carrying more than an insignificant amount of risk (e.g. currency,

  interest rate or credit risk). [SIC-27.8].

  An entity must take great care before it considers any investment as carrying an

  insignificant amount of risk.

  2.2.4

  Presentation and disclosure requirements.

  The fee must be presented in the income statement based on its economic substance

  and nature. [SIC-27.9]. The entity must disclose the following in each period that an

  arrangement exists:

  An entity has to make the disclosures that are necessary to understand the arrangement

  and the accounting treatment adopted, including the following:

  (a) a description of the arrangement including:

  (i) the underlying asset and any restrictions on its use;

  (ii) the life and other significant terms of the arrangement;

  (iii) the transactions that are linked together, including any options; and

  (b) the accounting treatment of any fee received, the amount that has been recognised as

  income in the period, and the line item of the income statement in which it is included.

  Leases (IAS 17) 1619

  These disclosures should be provided individually for each arrangement or in aggregate

  for each class of arrangement. A class is a grouping of arrangements with underlying

  assets of a similar nature. [SIC-27.10, 11].

  3

  SCOPE AND DEFINITIONS OF IAS 17

  3.1

  Scope of IAS 17

  The standard applies in accounting for all leases other than:

  • lease agreements to explore for or use minerals, oil, natural gas and similar non-

  regenerative resources (see Chapter 39); and

  • licensing agreements for such items as motion picture films, video recordings,

  plays, manuscripts, patents and copyrights.

  The standard should not be applied to the measurement by:

  • lessees of
investment property held under finance leases;

  • lessors of investment property leased out under operating leases, as in these cases

  IAS 40 – Investment Property – applies (see Chapter 19);

  • lessees of biological assets held under finance leases; or

  • lessors of biological assets leased out under operating leases, as in these cases

  IAS 41 – Agriculture – applies (see Chapter 38). [IAS 17.2].

  3.1.1

  Leases and licensing agreements

  IAS 17 does not define a licensing agreement so the distinction between ‘leases’ and

  ‘licensing agreements’ is not clear.

  Whether or not the arrangement is within scope of IAS 17 does not depend on the type

  of asset or, as discussed in 2.2 above, on how the contract is labelled, but rather on the

  nature of that arrangement.

  IAS 17 does not apply to agreements that do not transfer the right to use assets from one

  contracting party to the other. A conventional licence over an intangible asset such as

  a film or video commonly gives a non-exclusive right of ‘access’ to show or view the

  video simultaneously with many others but not a ‘right of use’ of the original film or

  video itself because the licensee does not control that asset. This puts many licence

  agreements outside the scope of IAS 17. However, if the right to use the intangible asset

  is provided in the license agreement, the arrangement may be a lease; see the discussion

  in 2.1 above regarding IFRIC 4 and the right to use the asset.

  The assets subject to licensing agreements excluded from the scope of IAS 17 (such as

  motion picture films, video recordings, plays, manuscripts, patents and copyrights) are

  specific intangible assets but arrangements involving, for example, motion picture films

  are not out of scope simply because of the nature of that asset but rather because the

  nature of arrangements over such assets typically grants a non-exclusive right of access

  to those assets rather than a right of use.

  It follows, therefore, that an arrangement that has been labelled a ‘licence’ will be within

  scope of IAS 17 if it transfers a right of use of the asset that is the subject of the

  1620 Chapter 23

  arrangement to the licensee. This ‘licence’ will include features in addition to those in

 

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