Upload
others
View
2
Download
0
Embed Size (px)
Citation preview
IFRS Tax accounting
KPMG 2019 IFRS Tax accounting seminar
—
November / December 2019
2© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Agenda for today
Welcome and introduction
Tax accounting – Recent developments
Outside basis differences
Effective tax rate reconciliation
Tax accounting – Recent developments
4© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
IFRIC 23 Uncertainty over Income tax treatments
IFRIC 23 is effective for annual periods beginning on or after 1 January 2019.
Tax law is complex and subject to interpretation ― entities need to evaluate tax uncertainties in applying IAS
12.
Previous lack of guidance in IAS 12 resulted in diversity in practice.
Determine if, when and how a tax uncertainty should be reflected in the financial statements.
IFRIC 23
5© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
What is an uncertain tax treatment?
Tax authority
All bodies that
decide whether
tax treatments
are acceptable
under tax law,
including courts.
Uncertain tax
treatment
A tax treatment for
which there is
uncertainty over
whether it would be
accepted by the
relevant tax authority
under tax law.
IFRIC 23
6© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Effective date and transition
Effective for annual periods beginning on or after 1 January 2019.
permitted.
orRetrospectively under IAS 8, if possible
without using hindsight
Retrospectively by adjusting equity at the date of
initial application, without restating
comparatives
1 January 2018
Start of comparative period
1 January 2019
Start of year of initial application
Initially applied:
IFRIC 23
7© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
IFRIC 23, Uncertain tax positions, Effective 1 January 2019IFRIC 23
1
2
3
4
5
6
7
Identify uncertain tax positions.
Apply probable threshold.
Detection risk is not applied.
Use ‘most likely amount’ or ‘expected value’ method for measuring the tax uncertainty.
Reassess for changes in facts and circumstances and new information.
Determine whether a change occurring after the reporting period is an adjusting event.
Significant estimates need to be disclosed.
8© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Question
The entity has been required to make a payment to the tax authority in respect of an uncertain tax treatment in a previously filed tax filing. The entity disputes the tax authority’s decision and plans to appeal, as they consider their position probable. Does the ‘virtually certain’ threshold need to be met to recognise the payment as an asset?
Yes: The entity recognises the payment as an expense in
profit or loss.
No: The entity recognises the payment as an asset in the statement of
financial position.
AA
BB
IFRIC 23
9© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Measurement of uncertain tax positions (1)
The expected value should usually be taken if there is a range of possible outcomes
that are neither binary nor concentrated on one value.
Deductible amount EUR 5.000.000:
Deductible amount accepted Probability Expected value
5.000.000 20% 1.000.000
3.000.000 40% 1.200.000
2.000.000 30% 600.000
0 10% 0
100% 2.800.000
IFRIC 23
10© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Measurement of uncertain tax positions (2)
The single most likely amount when binary or concentrated on one value.
Deductible amount EUR 5.000.000:
Most likely amount
40% 2.000.000
60% 3.000.000
Most likely amount --- > EUR 3.000.000
IFRIC 23
11© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Summary IFRS 16
Balance SheetIAS 17
(Old Standard)IFRS 16
Financial
lease
Operating
leaseAll leases
Leased Asset (‘’right of use’’)
Lease Liability
Operating lease commitments
disclosure
P&LIAS 17
(Old standaard)IFRS 16
Financial
lease
Operating
leaseAll leases
Revenue
Cost of Goods Sold
Other operating expenses
Depreciation
Interest expense
Net Result before tax
IFRS 16 in short: All leases on - balance
IFRS 16
12© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
IFRS 16 leases also allowed for Dutch tax purposes?IFRS 16
― The accounting treatment under IFRS 16 is not allowed for Dutch tax purposes, as a result
of which deductible and taxable temporary differences could arise between the commercial
and tax books.
Source: ‘’ Fiscale moties en toezeggingen Tweede Kamer’, April; 2019; page 5
― These temporary differences generally result in the recognition of deferred tax assets and
liabilities.
13© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
IFRS 16-Lease transaction
Balance Sheet – Accounting
Debit Credit
Leased Asset (‘’right of use’’) 100
Lease Liability 100
Balance Sheet – Tax purposes
Debit Credit
Leased Asset (‘’right of use’’) 0
Lease Liability 0
Book-to-tax difference of 100
(temporary difference) for asset and
liability
Application of initial recognition exemption?
IFRS 16
14© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Proposed amendments to IAS 12IFRS 16
Exposure Draft ED/2019/5 (July 2019)
Deferred Tax related to Assets and Liabilities arising from a Single Transaction
15. Taxable temporary differences
A deferred tax liability shall be recognized for all taxable
temporary differences, except to the extent that the deferred
tax liability arises from:
a) The initial recognition of goodwill; or
b) The initial recognition of an asset or liability in a
transaction which:
I. is not a business combination; and
II. at the time of the transaction, affects neither
accounting profit nor taxable profit (tax loss); and
III. at the time of the transaction, does not give rise to
equal amounts of taxable and deductible temporary
differences.
24. Deductible temporary differences
A deferred tax asset shall be recognized for all
deductible temporary differences to the extent that it is
probable that taxable profit will be available against
which the deductible temporary difference can be
utilized, unless the deferred tax asset arises from the
initial recognition of an asset or liability in a transaction
that:
a) is not a business combination; and
b) at the time of the transaction, affects neither
accounting profit nor taxable profit (tax loss); and
c) at the time of the transaction, does not give rise to
equal amounts of taxable and deductible temporary
differences.
15© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Main Dutch corporate tax developments – CIT Rates
Reduction of Dutch CIT rates in steps – enacted 28 December 2018
Tax plan 2020 – Proposal (presented on Budget day; Prinsjesdag)
Tax accounting implications:
― Deferred tax measured at enacted/substantively enacted tax rate
― Re-assessment of existing deferred taxes based on reversal schedule
― Backward tracing
Profit 2020 2021
> € 200K 25% 21,7%
Profit 2018 2019 2020 2021
≤ € 200K 20% 19% 16,5% 15%
> € 200K 25% 25% 22,55% 20,5%
CIT Rates
16© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Recognising current and deferred tax – Backward TracingCIT Rates
Current and deferred tax is recognised consistently with the underlying transaction or event
to which it relates
Item recognised in profit or loss Item recognised in OCI/equity
Current and deferred tax recognised in
profit or loss
Current and deferred tax recognised in
OCI/equity
Key: OCI = other comprehensive income
17© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Earnings stripping measures Earnings
stripping
Earnings stripping legislation (art. 15b
Dutch CITA) - Effective 1 January 2019Tax accounting implications
― Net borrowing costs will be deductible up to
the higher of
1. 30% of a taxpayer’s fiscal EBITDA; or
2. EUR 1 million.
― Non-deductible net borrowing costs can be
carried forward indefinitely
― Re-assessment DTA based on tax
forecasts
― Recognition of DTA for non-deductible
borrowing costs
Outside basis differences
19© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Why is this relevant? Temporary
differences
20© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Temporary differences Temporary
differences
Carrying amount of an asset is higher than
its tax base
Carrying amount of a liability is lower than
its tax base
Taxable temporary differences Deductible temporary differences
Deferred tax liability Deferred tax asset
Carrying amount of an asset is lower than
its tax base
Carrying amount of a liability is higher than
its tax base
21© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Temporary differences Temporary
differences
Outside basis differences,
arising from temporary
differences on investments
in subsidiaries, branches
and associates and
interests in joint
arrangements.
Inside basis differences; arising
from temporary differences between
the carrying amounts of the
individual assets and/or liabilities of
subsidiary, branch or an interest in a
joint operation and the tax bases of
such assets and liabilities (‘’regular’’
temporary difference).
22© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Inside basis differences Temporary
differences
Example
Company X holds subsidiary Y.
Subsidiary Y recognized an asset for
€ 1,000 in its financial statements,
related to capitalized R&D costs in
2019.
In the tax return of Company Y, the
€ 1,000 R&D costs are expensed at
once, in accordance with relevant tax
law. Hence, a taxable temporary
difference arises as the tax base of
the asset is € 0.
As a result, in the consolidated FS,
Company X accounts for the
temporary difference, resulting in a
DTL of € 200(1)
Accounting in accordance with IAS 12.15 for taxable temporary differences resulting in DTLs and IAS 12.24 for deductible temporary differences potentially resulting in DTAs.
Source: (1) Assuming a tax rate of 20%
23© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Outside basis differences Temporary
differences
Example
Company X holds subsidiary Y,
which is accounted for using the
equity method. The tax base of
subsidiary Y is 0.
As a result of undistributed profits,
the equity value of subsidiary Y has
increased to 100. As a result, a
temporary difference of 100 has
arisen.
A deferred tax liability in relation to
the taxable temporary difference of
100 is recognized (at the level of
company X) if the recognition criteria
are met.
Accounting in accordance with IAS 12.39 for taxable temporary differences resulting in DTLs if criteria are met and IAS 12.44 for deductible temporary differences.
24© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Recognition criteria for outside basis differences Temporary
differences
IAS 12.39: An entity shall recognise a deferred tax liability for all taxable temporary differencesassociated with investments in subsidiaries, branches and associates, and interests in joint arrangements, except to the extent that both of the following conditions are satisfied:
b) it is probable that the
temporary difference will
not reverse in the
foreseeable future.
a) the parent, investor, joint
venturer or joint operator is
able to control the timing of
the reversal of the temporary
difference
25© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Recognition criteria for outside basis differences Temporary
differences
IAS 12.44: An entity shall recognise a deferred tax asset for all deductible temporary differencesarising from investments in subsidiaries, branches and associates, and interests in joint arrangements, to the extent that, and only to the extent that, it is probable that:
b) taxable profit will be
available against which
the temporary difference
can be utilised.
a) the temporary
difference will reverse
in the foreseeable
future.
26© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Most common taxes in relation to outside basis differences Temporary
differences
Withholding taxes that arise upon
dividend distribution.
Capital gains taxes that arise upon
sale of the shares
Corporate income tax charge under
local tax rules if no (full) participation
exemption applies
High chance of applicability for non-EU subsidiaries!
27© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Outside basis differences
X Holding
(tax base subsidiary
Y: 100)
Y Subsidiary
100%
In measuring the outside basis difference, consider local tax law AND applicable tax treaties / EU Law
If both criteria of IAS
12.39 are met, the
DTL of 75
representing the tax
claim upon
distribution of profit
is recognized.
X Holding Subsidiary
Y: 400Equity:
325
DTL: 75
No participation
exemption upon
distribution, 25% tax
payable by X on
distributed amount
300
Tax claim
25% of 300
= 75
Y SubEquity:
400
Cash: 400
Outside basis difference
28© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Outside basis differences - consolidation
X Holding
(tax base subsidiary
Y: 100)
Y Subsidiary
100%
Outside basis differences are NOT eliminated upon consolidation.
X Holding Subsidiary
Y: 400Equity:
325
DTL:
75
No participation
exemption upon
distribution, 25% tax
payable by X on
distributed amount
300
Tax claim
25% of 300
= 75
Y SubEquity:
400
Cash: 400
X+Y Cons.Cash: 400 Equity:
325
DTL:
75
29© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Wrap up
Outside basis differencesImpact on financial statements
― Outside basis differences arise from
temporary differences on investments in
subsidiaries, branches and associates and
interests in joint arrangements (IAS 12.38).
― Most common taxes in relation to outside
basis differences are withholding taxes,
capital gains tax and corporate income tax
in absence of participation exemptions.
― Outside basis differences are not
eliminated upon consolidation
― If the criteria within IAS 12.39 or IAS 12.44
are met, recognition of a deferred tax
liability or asset is required.
― In measuring the outside basis difference,
consider local tax law AND applicable tax
treaties / EU Law
Temporary
differences
30© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 1 - Introduction Temporary
differences
K HoldingK Holding holds one subsidiary (accounted for under the equity method) named KW. K Holding controls the dividend
policy of KW and therefore controls the timing of the reversal of the temporary difference. The subsidiary made a profit
of € 1,000. The profit is not distributed to K Holding at year-end and it’s probable that it will be distributed next year.
Upon distribution 15% dividend tax is applicable.
Situation after distribution profit
K Holding
KW
850
150
100%
If distributed,
15% dividend
tax applicable
Tax authority
31© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 1 – Cont’d
1. What is the nature of the difference between the tax base (at cost) and the carrying amount of the subsidiary related
to this profit?
A. Permanent difference
B. Outside basis difference
C. Inside basis difference
Temporary
differences
K Holding
B. Is correct, temporary differences associated with investments in subsidiaries, branches and associates, and interests
in joint arrangements, are generally referred to as outside basis differences (IAS 12.38).
32© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 1 – Cont’d Temporary
differences
A. Is correct, K Holding recognizes the DTL of € 150 in its financial statements as
i) there is control; and
ii) the profit will be distributed in the foreseeable future.
2. Should Y recognize a DTL in relation to this € 1.000 profit?
A. Yes, for an amount of € 150.
B. Yes, for an amount of € 1,000.
C. No deferred tax is recognized.
K Holding
K Holding
KW
850
150100%
If distributed,
15% dividend
tax applicable
Tax authority
33© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 2 - Introduction
Y(UK) has control over its fully owned subsidiary X (Australia). In 2019 X expects a profit of AUD 1,000. Assume that
upon payment of this AUD 1,000 as dividend to the United Kingdom, 15% Australian withholding tax is applicable which
is neither creditable nor deductible for Y against its corporate income tax. Y has not paid an interim dividend in 2019
and has no intention to demand for a dividend payment from X in 2020. Assume a UK tax rate of 20%.
Temporary
differences
X (Australia)
Y (UK)
X (Australia)
850
If distributed 15%
dividend tax
applicable
34© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 2 – Cont’d
1. Please indicate which factor(s) is (are) relevant for the recognition of deferred tax for outside basis differences.
A. Ability of the parent to control the timing of the reversal of the temporary difference
B. Reversal of the temporary difference in the foreseeable future
C. Both A and B
D. None of the above
Temporary
differences
X (Australia)
C. Is correct. Deferred tax liabilities resulting from such differences shall be recognized in accordance with IAS 12.39
following IAS 12.15.
An entity shall recognize a DTL for all taxable temporary differences with investments in subsidiaries except to the
extent that both of the following conditions are satisfied:
a. the parent is able to control the timing of the reversal of the temporary difference; and
b. it is probable that the temporary difference will not reverse in the foreseeable future.
35© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 2 – Cont’d
2. Should Y recognize a DTL in relation to this AUD 1.000 profit per 31 December 2019?
A. Yes, for an amount of AUD 150.
B. Yes, for an amount of AUD 200.
C. Yes, for an amount of AUD 1,000.
D. No deferred tax is recognized.
Temporary
differences
X (Australia)
D. Is correct. Y is assumed to have control over X and can therefore control the timing of the reversal of the temporary
difference. Furthermore, it is probable that the temporary difference will not reverse in the foreseeable future (for
example because X re-invests the proceeds), as no intention exists to distribute the profit of AUD 1,000 in 2020. As a
result, no DTL is recognized at 31 December 2019.
Y (UK)
X (Australia)
850
If distributed 15%
dividend tax
applicable
36© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 3 - Introduction
Y holds an asset in a separate legal entity (‘’B’’) solely consisting of this single asset. B meets the criteria of IFRS 5 and
is therefore classified as an asset held for sale. After applying the measurement requirements in IFRS 5, the carrying
amount of the asset in the consolidated FS of Y is EUR 7,000. The tax base of the asset is EUR 5,000. When Y
disposes of the shares in B, an amount of EUR 8,000 will be deductible for tax purposes. Assume:
― Y’s (UK) tax rate is 20%.
― There will be sufficient taxable profit.
Temporary
differences
Y (UK)
Y (UK)
B (UK)
37© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 3 – Cont’d
1. Is Y required to recognize deferred taxes?
A. Yes, Y should only recognize a DTL of EUR 400 for the taxable temporary difference.
B. Yes, Y should only recognize a DTA of EUR 200 for the deductible temporary difference.
C. Y is required to recognize two deferred positions. A DTL of EUR 400 for the taxable temporary difference and a DTA of EUR 200 for
the deductible temporary difference.
D. Y is required to recognize two deferred positions. A DTL of EUR 400 for the taxable temporary difference and a DTA of EUR 280 for
the deductible temporary difference.
Temporary
differences
Y (UK)
38© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 3 – Cont’d
Y holds an asset in a separate legal entity (‘’B’’) solely consisting of this single asset. B meets the criteria of IFRS 5 and is therefore
classified as an asset held for sale. After applying the measurement requirements in IFRS 5, the carrying amount of the asset in the
consolidated FS of Y is EUR 7,000. The tax base of the asset is EUR 5,000. When Y disposes of the shares in B, an amount of EUR
8,000 will be deductible for tax purposes. Assume:
― Y’s (UK) tax rate is 20%.
― There will be sufficient taxable profit.
Temporary
differences
Y (UK)
D. Is correct. Y is required to recognize two deferred positions.
― Inside basis difference (IAS 12.15)
- Taxable temporary difference of EUR 7,000 -/- EUR 5,000 = EUR 2,000
- DTL of EUR 400 (EUR 2,000 * 20% = 400).
― Outside basis difference (IAS 12.39)
- Carrying amount of legal entity B is recalculated at EUR 6,600 (EUR 7,000 -/- EUR 400)
- Tax base of Y in B is EUR 8,000.
- Deductible temporary difference of EUR 8,000 -/- EUR 6,600 = EUR 1,400.
- DTA of EUR 280 (EUR 1,400 * 20%), considering a) reversal of deductible temporary difference in the foreseeable future; and b)
sufficient taxable profit.
39© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 4 – Introduction
Y (Sri Lanka) is loss making for several years now. Management of Y has indicated to management of X (the
Netherlands) that, due to the recent terrorist attacks in Sri Lanka, room occupancy has collapsed and it is not expected
that recovery will follow within the next couple of years. Given these circumstances, management of X has decided to
liquidate the investment in Y.
In 2019, X will impair Y to EUR nil. The tax base of Y is EUR 1,000. The liquidation of Y will take some time due to legal
requirements that have to be met and management expects to finalize the liquidation in 2020. For Dutch tax purposes,
a so-called liquidation loss is tax deductible in the year the entity is dissolved / liquidated. Assume that the EUR 1,000
liquidation loss will be tax deductible. X is a very profitable company and it is expected that sufficient future taxable
profit is available. The applicable tax rate is 25%.
Temporary
differences
Y (Sri Lanka)
X (The
Netherlands)
Y
( Sri Lanka)
40© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Case 4 – Cont’d Temporary
differences
Y (Sri Lanka)
1. What should be recognized in this case at 31 December 2019?
A. Is correct.
- The carrying amount of Y is EUR 0.
- The tax base of Y is EUR 1,000.
- The (deductible) temporary difference is EUR 1,000 (EUR 1,000 -/- EUR 0) at 31 December 2019.
- Recognition of DTA of EUR 250 (EUR 1,000 * 25%) at 31 December 2019, considering a) reversal of deductible
temporary difference in the foreseeable future (i.e. in 2020); and b) sufficient taxable profit.
A. A DTA of EUR 250.
B. A DTL of EUR 250.
C. No DTA or DTL has to be recognized at 31 December 2019.
Effective tax rate reconciliation
42© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Why is the effective tax rate reconciliation important? ETR
43© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
OverviewETR
Effective tax rate =Income tax P&L (current and deferred)
Accounting pre-tax profit
Why effective tax rate ≠ applicable tax rate?
― Non-taxable income and non-deductible expenses.
― Changes in estimates (e.g. recoverability of deferred tax assets or uncertain tax positions) or tax rates.
― Tax rate in parents’ jurisdictions ≠ tax rate in subsidiaries’ jurisdictions. ≠
44© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
DisclosureETR
― Two approaches:
- Amount-to-amount
Tax income reconciled to
accounting income:
expressed in numbers
- Rate-to-rate
Tax income reconciled to
accounting income:
expressed in
percentages
45© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Examples typical tax reconciliation itemsETR
Change in estimate about
the recoverability of
deferred tax asset
Non-taxable income
Non-deductible expenses Unrecognised tax losses
Change in applicable tax rate Foreign tax rates
46© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
No tax reconciliation itemsETR
― Regular reversal of temporary differences for which deferred tax
was recognised.
― Income taxes on items recognised outside profit or loss:
- Income taxes on items recognised in other comprehensive
income (OCI) or equity.
- Business combinations (deferred taxes recognised in
goodwill).
47© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Group operating in multiple tax jurisdictionsETR
Determine applicable tax rate:
Domestic tax rate in the country in which the
entity is domiciled.
Aggregate separate reconciliations prepared
using the domestic rate in each individual
jurisdiction.
Domestic
tax rate
Aggregate
or
48© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Subsidiaries in lower tax rate jurisdictionETR
Group G’s results Year 1 Year 2
Parent’s profit € 3,000 € 0
Subsidiary’s profit € 0 € 3,000
Current tax€ 900
(€ 3,000 X 30%)
€ 600
(€ 3,000 X 20%)
Under which approach would ‘subsidiary in lower tax rate jurisdiction’ be included in the tax reconciliation?
Group G
Parent
Country X: 30% tax rate
Subsidiary
Country Y: 20% tax rate
49© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Approaches 1 and 2ETR
Year 1 Year 2
Profit before tax € 3,000 € 3,000
Tax using applicable tax rate (P:30%) € 900 € 900
Reconciliation:
- Subsidiaries in the group located in
jurisdictions with lower income tax
rate
€ 0 (€ 300)
Income taxes (total) € 900 € 600
Effective tax rate 30% 20%
Approach 1: Domestic tax rate in which P is
domiciled
Approach 2: Domestic tax rate applicable to
profits in individual jurisdictions
Year 1 Year 2
Profit before tax € 3,000 € 3,000
Tax using applicable tax rate
(P:30%, S:20%)
€ 900 € 600
Reconciliation: N/A N/A
Income taxes (total) € 900 € 600
Effective tax rate 30% 20%
50© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 1: Utilisation of unrecognised tax losses ETR
Tax losses € 1,000; no
DTA recognised.
Year 1 Year 2
Pre-tax profit(1) € 200;
utilization of prior year tax
losses.
Tax rateManagement: Nil DTA
for unused tax losses
30%
What is the reconciling item? Year 2
Profit before tax € 200
Tax using applicable tax rate (30%) € 60
Reconciliation:
- Unrecognised tax losses ?
Income taxes (total) ?Note: (1) Accounting profit = tax profit, DTA: Deferred tax asset
51© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 1: SolutionETR
Year 2
Profit before tax € 200
Tax using applicable tax rate (30%) € 60
Reconciliation:
- Unrecognised tax losses (€ 60)
Income taxes (total) 0
Effective tax rate 0%
Applicable tax rate 30%
[€ 200 X 30%]
No Journal entry – Income taxes
52© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 2: Utilisation of recognised unused tax lossesETR
― Tax losses € 1,000
― Tax losses DTA
recognised
Year 1 Year 2
― Pre-tax profit(1) € 200
― Utilise tax losses € 200
Tax rateManagement: Continue
to recognise DTA for
remaining € 800 tax
losses carry forward
30%
In Year 2, what is the reconciling item? Year 2
Profit before tax € 200
Tax using applicable tax rate (30%) € 60
Reconciliation:
- Unrecognised tax losses ?
Income taxes (total) ?Note: (1) Accounting profit = tax profit
53© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 2: SolutionETR
Year 2
Profit before tax € 200
Tax using applicable tax rate (30%) € 60
Reconciliation:
- Unrecognised tax losses -
Income taxes (total) € 60
Effective tax rate 30%
Applicable tax rate 30%
M recognised a deferred tax asset in Year 1
for unused tax losses so the utilisation of the
deferred tax asset has no impact in year 2.
Debit Credit
Deferred tax
expense
€ 60
DTA € 60
Journal entry – Income taxes
54© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 3: Change in estimate – tax lossesETR
Tax losses €
1,000; no DTA
recognised.
Year 1 Year 3
Pre-tax profit(1) €
200; utilise prior
year tax losses.
Tax rateManagement:
Year 2: No DTA
Year 3: DTA of € 180
(€ 600 * 30%)
30%
In year 3, what is the reconciling item? Year 3
Profit before tax € 200
Tax using applicable tax rate (30%) € 60
Reconciliation:
- Unrecognised tax losses ?
Income taxes (total) ?Note: (1) Accounting profit = tax profit
Year 2
Pre-tax profit(1) €
200; utilise prior
year tax losses.
55© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 3: SolutionETR
Year 3
Profit before tax € 200
Tax using applicable tax rate (30%) € 60
Reconciliation:
Unrecognised tax losses
- Utilisation of unused tax losses (€ 60)
- Recognition of previously unrecognised
tax losses
(€ 180)
Income tax (total) (€ 180)
Effective tax rate (90%)
Applicable tax rate 30%
2. [€ 600 X 30%]
1. [€ 200 X 30%]
Debit Credit
DTA € 180
Deferred tax
expense
€ 180
Journal entry – recognition of previously unrecognised tax losses
56© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 4: Tax rate changeETR
What is reconciling item (change in tax rate) in Year 1 and Year 2?
Year 1 Year 2
Profit before tax € 1000 € 1000
Tax using applicable tax rate (30%) € 300
(30%)
€ 200
(20%)
Reconciliation:
- Change of tax rate ? ?
Income taxes (total) ?Note: (1) Accounting profit = tax profit
October Year 1:
Statutory tax
rate reduction
announcement
Years 1 and 2
pre-tax profit(1)
Enacted 1
January Year 2
30%20% € 1,000
― Deductible temporary difference of € 100
resulting in DTA € 30 (€ 100 x 30%) –
before tax rate reduction.
― Tax rate reduction is substantively enacted
by government announcement; DTA
reduced from € 30 to € 20.
57© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Example 4: SolutionETR
Year 1 Year 2
Profit before tax € 1,000 € 1,000
Tax using applicable tax rate € 300
(30%)
€ 200
(20%)
Reconciliation:
- Change of tax rate € 10 -
Income tax (total) € 310 € 200
Effective tax rate 31% 20%
Applicable tax rate 30% 20%
In Country X, on announcement by the
government the reduced tax rate is substantially
enacted, and therefore P reduces the deferred tax
asset by € 10 from € 30 to € 20.
Although the change in the tax rate does not effect
current taxes for Year 1, it affects deferred taxes,
because they are measured at the rate expected
to apply to the period when the temporary
difference reverses.
In Year 2, the applicable tax rate is 20%: no
reconciling item.
Debit Credit
Deferred tax
expense
€ 10
DTA € 10
Journal entry – change of tax rate
58© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
Key points to remember!ETR
Transparent disclosure enables users to understand the relationship between accounting profit and
tax expense.
Typical reconciling items include non-taxable income and non-deductible expenses and changes in
tax rates or differences in tax rates applied to entities in the group.
Reconciling items should not include changes in temporary difference for which deferred tax is
recognised, and taxes recognised outside profit and loss.
Thank you for your presence today! If you have any questions, please feel free to contact one of our Tax accounting specialists!
Arthur PlantfeberTax accounting specialist CMAAS
Phone +31 (0)20 656 4614
Mobile +31 (0)6 1081 9715
Stefan PaantjensTax accounting specialist CMAAS
Phone +31 (0)20 656 7404
Mobile +31 (0)6 2554 1029
KPMG on social media KPMG app
The KPMG name and logo are registered trademarks of KPMG International.
© 2019 KPMG Advisory N.V., registered with the trade register in the Netherlands under number 33263682, is a member firm of the KPMG network of independent member firms
affiliated with KPMG International Cooperative (‘KPMG International’), a Swiss entity. All rights reserved.
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate
and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on
such information without appropriate professional advice after a thorough examination of the particular situation.