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IAS 18 Revenue Recognition – Customer Contributions
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Issue Description:

How should a utility or other company account for the receipt of customer contributions? Such contributions arise because the customer is required to contribute an asset (or cash towards the construction or acquisition of an asset) that is then used to provide access to an ongoing supply of goods or services to the customer.

Discussion at IFRIC Meeting July 2007

The IFRIC noted that this issue could potentially apply to a diverse set of arrangements and raised the concern that considering all such arrangements could make the scope too broad for interpretation purposes. Therefore, the IFRIC decided to approach to the issue in a number of stages.

At this meeting the IFRIC discussed situations in which a customer contributes an item of property, plant and equipment to a service provider. The Chairman noted that after having reached a conclusion on the treatment of property, plant and equipment the IFRIC would debate whether the scope can be widened to other assets.

The staff analysis considered the following:

  • Has an asset transfer occurred (including considering the effect of IFRIC 4 Determining whether an Arrangement contains a Lease)?
  • Is IAS 20 Accounting for Government Grants and Disclosure of Government Assistance an appropriate accounting standard to use to account for a contributed asset?
  • Should the asset received be measured at cost or fair value on initial recognition?
  • How should any resulting credit should be accounted for

Has an asset transfer occurred?

The IFRIC tentatively decided that only contributed items of property, plant and equipment that meet the criteria for recognition as assets of the service provider should be in the scope of any Interpretation.

Therefore, the entity receiving the assets should first consider whether it is required to recognise the asset in its financial statements. In particular, it should consider whether it can obtain the future economic benefits flowing from the asset and can restrict the access of others to those benefits, and whether it has control over those assets.

In a second step the entity should assess whether the provision of the ongoing service to the customer contains a lease in accordance with IFRIC 4. If so, the entity should account for the lease of the asset to the customer in accordance with IAS 17 Leases.

The staff was directed to prepare a revised paper for discussion at the next meeting.

Is IAS 20 an appropriate accounting standard to use to account for a contributed asset?

The IFRIC unanimously concluded that it is not appropriate to consider customer contribution as being similar to government grants.

Should the asset received be measured at cost or fair value on initial recognition?

The IFRIC tentatively agreed that the contributed asset should be recognised initially at fair value since the contribution is part of an exchange of assets, that is, that it is not a unilateral transaction. In the IFRIC's view, in return for the contributed asset the customer may receive an access right to receive an ongoing service and/or an executory contract to receive a supply of goods and/or an ongoing service. There seemed to be a consensus that recognition at fair value should be applied irrespective of how the entity accounts for the credit record.

In addition it was noted that the fair value should be determined from the view of the utility company/service provider.

How should any resulting credit should be accounted for?

The IFRIC discussed two views:

View 1:

The credit does not represent a liability or an equity contribution but instead gives rise to income.

View 2:

The credit represents a liability which should be recorded as a liability and recognised over the life of the ongoing service.

The IFRIC had a thorough debate and mixed views were expressed. There seemed to be a consensus that the credit does not represent an equity contribution but that this issue exclusively relates to the allocation of income. The IFRIC acknowledged that the accounting for the credit depends on the contractual arrangements; in particular:

  • If there is a contract between the contributor and the service provider it is most likely that the service provider has a liability and that the revenue arising from the receipt of a customer contribution should be deferred and recognised over the life of the ongoing service.
  • If there is no contract between the contributor and the service provider the service provider may not have a liability. This might, for example, be the case if a house builder contributes an item to a utility company and in the absence of any contractual arrangements the utility company may neither have an obligation to provide services nor to grant access to their services. One IFRIC member suggested that in this case the revenue recognition should follow the guidance in IAS 18.

One IFRIC member pointed out that in both cases the accounting principle should be to 'spread the income' over the service period but that this period might be 'zero' in some circumstances.

No decisions were made but the staff was asked to bring back a paper considering the views expressed at this meeting. In particular, the paper should include indicators for upfront recognition and deferral of income.

Discussion at the September 2007 IFRIC Meeting

The IFRIC continued their discussion of the accounting for non-cash distributions (See July 2007 IASPlus report). The discussion at this meeting concentrated on the following issues:

  • (i) How to account for the receipt of customer contributions
  • (ii) Estimating the duration of the ongoing service (service period)
  • (iii) Potential extensions of the scope

How to account for the receipt of customer contributions

The staff presented a flowchart illustrating the approach agreed at the July meeting:

  • Step 1: Assess whether an item of property, plant and equipment (PPE) has been transferred
  • Step 2: Assess whether the ongoing service arrangement contains a leaseback to the customer

With regard to step 1 the IFRIC decided not to provide detailed guidance on the notion of control of an item of PPE. Any Interpretation should reference to the existing guidance in IFRSs and just point out the key factors. Regarding step 2 the IFRIC decided that such assessment should be made with reference to IFRIC 4 Determining whether an Arrangement contains a Lease.

The IFRIC then discussed the accounting implications of the three accounting models arising from this approach. (For a detailed analysis and illustrative examples we refer to Agenda Papers 4A and the Appendix to Agenda Paper 4 available on the IASB website).

Contributions with no lease back

In this case the PPE is initially recognised on the balance sheet at fair value with a corresponding liability. The PPE is depreciated over its useful economic life. The obligation is recognised in income on a basis that reflects the provision of access to the ongoing services provided, that is, over the service period.

Contributions with an operating lease back

The only difference to contributions with no lease back is that part of the revenue arises from rental income rather than from the provision of a service.

Contributions with a finance lease back

The IFRIC believed that in this case no item of PPE has been transferred (step 1) and the transaction would therefore be outside the scope.

The IFRIC reaffirmed its tentative decision at the July 2007 meeting that PPE transferred by the contributor should be recorded at fair value in the financial statements of the service provider unless the application of IFRIC 4 results in a finance lease back.

Estimating the duration of the ongoing service (service period)

In July 2007 the IFRIC noted that the service provider would need to assess whether the contribution resulted in any ongoing obligation. If so, this obligation should be recognised in the balance sheet and the contribution should be recognised in income over the periods in which the obligation is satisfied.

The IFRIC had a lengthy discussion and mixed views were expressed. The following questions were raised:

  • What is the obligation of the provider: to grant initial access to the asset, to provide ongoing access to the asset and/or to provide an ongoing service?
  • Should the service period be the period for which the customer has the right to receive access to the asset and/or ongoing services (for example, under a contract or under statute) or the period over which the customer is expected to receive access to the asset and/or the ongoing services (that is, taking into account contract renewals)?
  • Does the accounting treatment differ in situations in which the PPE is contributed by one party but access to the asset and ongoing service and/ or the ongoing service is received by another party? In these cases it was acknowledged that the contributor normally contributes the asset in return for an ability to access a service rather than a right to access the service; for example, a property developer may contribute an electricity sub-station to facilitate the development of a number of houses. The developer does not itself use the asset or service, rather the ultimate customer who purchases a house within the development receives the access to the service.

With regard to the first two issues, some IFRIC members noted that in some jurisdictions industries are regulated (for example, energy suppliers) and therefore the obligation to grant access could be considered to be perpetual. Others mentioned that the legal contract period may be unreasonably short compared to the expected life of the service contract.

Regarding the third issue some believed that there would be no further obligation in cases where the service provider is only required to grant initial access to the asset. Other IFRIC members were concerned about full revenue recognition on day 1 as, in their view, it does not appear reasonable that an item of PPE is contributed and the other party 'is obliged to do nothing'.

No decisions were made; however, there was a consensus that the service period should not exceed the useful life of the PPE.

The staff was directed to include in the draft Interpretation indicators how the revenue arising from the credit entry should be allocated to future periods taking into account the views and concerns expressed at this meeting. The draft Interpretation should also identify the different types of performance obligations that may arise.

Potential extensions of the scope

The IFRIC tentatively decided to extend the scope to contributions of PPE or cash which is contributed for the construction or acquisition of specific items of PPE.

The IFRIC intends to discuss a draft Interpretation reflecting these decisions at the next meeting.

Discussion at the November 2007 IFRIC Meeting

Cash contributions

In September 2007 the IFRIC agreed to extend the scope of its customer contributions project to include cash contributions. Such contributions arise when a customer contributes cash to a supplier. As a result of receiving the cash, the supplier is required to construct or acquire an item of property, plant and equipment that is then used to supply goods or services to the customer. The property, plant and equipment is an asset of the supplier. However, the ongoing service arrangement may contain a lease of the asset to the customer.

In deciding to include cash contributions in its project on customer contributions, the IFRIC agreed that the contribution of cash has a similar economic effect to the contribution of an item of property, plant and equipment. The two should therefore result in similar accounting consequences.

The IFRIC considered how cash contributions should be accounted for by the entity receiving them. In determining how an entity should account for the receipt of a cash contribution, the IFRIC considered 5 possible approaches:

  • Approach 1: the construction or acquisition of the property, plant and equipment is not a service to the customer.
  • Approach 2: the cash contribution should be allocated between the construction or acquisition of the asset and the ongoing service based on fair value.
  • Approach 3: Recognition of the cash contribution as revenue immediately.
  • Approach 4: The construction or acquisition of an item of property, plant and equipment is a service to the customer but no revenue should be allocated to it.
  • Approach 5: Two transactions take place. The construction or acquisition of an asset in return for a cash contribution and the provision of access to a supply of goods or services in return for contribution of that asset.

A number of IFRIC members expressed concern with the double recognition of revenue in Approach 5 and queried how customer contributions could be conceptually distinguished from the requirements of IFRIC 12. One IFRIC member noted that the distinction was that when a customer contribution occurs it is the operator that ends up with the asset.

The IFRIC noted that the treatment of customer contributions ultimately will be dependent on specific facts and circumstances.

The IFRIC tentatively agreed (none objected) to support Approach 1.

Draft Interpretation

In September 2007 the IFRIC asked the staff to develop a draft Interpretation on customer contributions. The staff presented the draft Interpretation to the IFRIC.

The IFRIC considered the following issues as outlined in Agenda Paper 4A:

  • Whether guidance on the accounting for contributions of property, plant, and equipment is appropriate: Tentatively agreed, subject to some redrafting, that the guidance was appropriate.
  • Whether the Draft Interpretation should contain an exclusion from the principle in IAS 8 that a change in policy should be applied retrospectively: Tentatively agreed that the draft Interpretation should prescribe prospective application.
  • Whether to develop further guidance on the measurement of fair value in the draft Interpretation: Tentatively agreed no further guidance would be provided.
Finally, the IFRIC considered a letter commenting on the current status of the project which disagreed with some of the tentative decision made to date. The IFRIC tentatively agreed not to make any further changes to the Draft Interpretation as a result of this letter.

The IFRIC directed staff to redraft the Draft Interpretation to reflect the decisions made and other editorial comments and re-circulate to IFRIC prior to release. The Draft Interpretation will not be discussed at another meeting prior to its release.

January 2008: Draft Interpretation D24

On 17 January 2008, IFRIC issued for public comment Draft Interpretation D24 - Customer Contributions. Comment deadline is 25 April 2008.

Comment at the March 2008 IFRIC Meeting

The IFRIC Co-ordinator indicated that the comment letter analysis for draft Interpretation D24 Customer Contributions will be discussed at the July 2008 IFRIC meeting.

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