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IAS 19 — Bewertung der leistungsorientierten Nettoverpflichtung bei Plänen für Leistungen nach Beendigung des Arbeitsverhältnisses mit Beiträgen von Arbeitnehmern

Date recorded:

Hintergrund

Im Mai 2012 hatte das IFRS Interpretations Committee received a request seeking clarification of paragraph 93 of IAS 19 Leistungen an Arbeitnehmer. That paragraph refers to the accounting for employee contributions set out in the formal terms of a defined benefit plan. The Standard is effective from annual periods beginning on or after 1 January 2013. The Interpretations Committee discussed this issue at its September and November 2012 meetings.

The Interpretations Committee received two submissions in relation to paragraph 93 of IAS 19. The paragraph states (emphasis added):

Beiträge von Arbeitnehmern oder Dritten, die in den formalen Regelungen des Plans enthalten sind, reduzieren entweder den Dienstzeitaufwand (wenn sie an die Arbeitsleistung gekoppelt sind) oder mindern die Neubewertungen der Nettoschuld (des Nettovermögenswerts) aus einem leistungsorientierten Plan (z.B. sofern Beiträge erforderlich sind, um eine Unterdeckung aufgrund von Verlusten aus dem Planvermögen oder aufgrund von versicherungsmathematischen Verlusten zu mindern). Beiträge von Arbeitnehmern oder Dritten in Bezug auf Arbeitsleistungen werden gemäß Paragraph 70 den Dienstjahren als eine negative Leistung zugeordnet (d.h. die Nettoleistung wird gemäß diesem Paragraphen zugeordnet).

At the November 2012 meeting the Staff presented to the Interpretations Committee an analysis on an arrangement for a defined benefit plan, where an employee receives a reduced salary, in return for an increase in the employer’s contributions to the defined benefit plan. The Interpretations Committee was concerned that even a very simple contributory plan (i.e. a fixed percentage of salary) would be subject to a complex calculation for attributing the benefits to periods of service. The Interpretations Committee observed that some employee contributions, such as contributions related to service rendered in the same period should be classified as a reduction in short-term employee benefits and would therefore not be within the scope of paragraph 93 of IAS 19.

 

Erörterung und Beschlussfassung

The Staff noted that the classification of employee benefits as either short term employee benefits or post-employment benefits determines how they are recognised and measured.  If the employee contributions are classified as a reduction in short term employee benefits the net benefits (i.e. reduced salary) will be measured at the undiscounted amount of the benefits expected to be paid and recognised in the period of service in accordance with paragraph 11 of IAS 19.  If the employee contributions are classified as part of post-employment benefits the obligations for the cost of the benefits including (net of) employee contributions will be measured on a discounted basis, and attributed to periods of service as a negative benefit in accordance with the steps identified in paragraph 57 of IAS 19 that describes recognition and measurement for defined benefit plans.

The Staff also noted that an important criterion to classify employee benefits as a reduction in short term employee benefits is whether the benefits are expected to be settled within twelve months after the related service.  If the benefits are payable after the completion of the employment the benefits are classified as post-employment benefits.

The Staff noted that employee contributions are classified as a reduction in short-term benefits and accounted for as such if:

  1. the contributions are linked solely to the employee’s service rendered in the same period; and
  2. the contributions are expected to be settled wholly before twelve months after the end of the annual reporting period in which the employees render the related service.

The Staff highlighted in their paper that they considered that the contributions that are required to be attributed to periods of service as a negative benefit in accordance with paragraph 93 are the ones that are neither linked solely to the employee’s service rendered in the same period nor expected to be settled wholly before twelve months after the end of the annual reporting period in which the employees render the related service.

The Staff paper therefore highlighted that there are some employee contributions that are accounted for as a reduction in short term employee benefits if they meet the definition of short term employee benefits and there are some that are accounted for as post-employment benefits under paragraph 93 and this distinction affects the recognition and measurement.

The Staff recommended that the Interpretations Committee should provide guidance in the form of Implementation Guidance.  They noted that the guidance should include:

  1. employee contributions are classified as a reduction in short-term employee benefits and are accounted for as such if:
    1. the contributions are linked solely to the employee’s service rendered in the same period
    2. the contributions are expected to be settled (e.g. deducted from salary) wholly before twelve months after the end of the annual reporting period in which the employees render the related service.
  2. employee contributions classified as post-employment benefits and then classified as contributions to defined benefit plans (as opposed to a defined contribution plan) should be attributed to periods of service as a negative benefit as described in paragraph 93, unless they reduce remeasurements of the net defined benefit liability.

The Staff asked the Interpretations Committee whether they agreed with the Staff analysis and recommendation on the classification of employee benefits that involve employee contributions to a defined benefit plan.

One member (who is also on the IASB) noted that the issue being discussed arises as in practice where there is a simple fixed contribution percentage, preparers do not want to go through the exercise that paragraph 93 is requiring them to go through.

One Committee member agreed with the direction that the Staff paper was heading.  However she mentioned that a simpler approach may be to focus on whether employees are taking risks.  She mentioned that if there was some element of risk sharing on behalf of the employees then this would suggest that payments by the employee would relate to elements other than the current service and hence paragraph 93 would apply.  The Staff noted this point and suggested that this approach would get to the same answer as their proposal.

Another Committee member also agreed with the Staff recommendation and agreed with the notion that where there are simple fixed percentage contributions, preparers should not have to follow the more complicated paragraph 93 accounting.  This member was, however, concerned with example 2 as he noted that, aside from the Staff’s analysis, it was still unclear as to how this could not be a short-term employee benefit.  This concern was shared by the Chair and a number of other Committee members.

Another Committee member also shared this view and noted that just because there was a different percentage contribution in future years (because of year of service, for instance), how does this demonstrate that this relates to a post-employment benefit.

The Staff responded that there were pretty clear cases where one would get to a short-term employee benefit answer, for instance a flat percentage contribution.  They noted that judgement would need to be applied as to the attribution method to adopt and that there were no definitive characteristics that would make it clear whether to adopt paragraph 93 or not.

One member also liked the Staff proposal and summed the issue up to say that if the current year’s contribution depends upon things that happen other than in the current year then paragraph 93 would apply, if not it would be a short-term employee benefit.  This member also liked the distinctions that were being drawn between simpler and more complicated plans.

A number of other Committee members agreed with the direction of the Staff paper.  One noted that he was concerned with the robustness of the distinction between short-term and post-employment benefits.  He questioned whether this is based solely on fixed percentage versus variable percentage or some other bases.  He questioned whether a robust line could be drawn.

Another Committee member was concerned that IAS 19 noted that contributions in respect of service should be accounted for in accordance with paragraph 93 (attributing to periods of service) but the Staff proposed Implementation Guidance stated that if the contributions were solely linked to service then paragraph 93 does not apply.  He was of the view that the Board should potentially reconsider their approach in paragraph 93 of IAS 19 to provide more clarity on this distinction (possibly as an amendment to the standard) – he also shared the view that Implementation Guidance with paragraph 93 as it currently is written will not help.  This member also argued that if the contributions are a percentage of your salary then you could always argue that this relates to service of this period as the contributions relate to the salary that is paid in the same period.  This member stated that he did not think that IAS 19 was clear on whether contributions that are made in a specific year are related to the service of the period.

The first Committee member later in the discussion noted that she thought that the real issue was when one had to apply the projected unit credit method to the employee contributions or when contributions would not be accounted for this way.  She noted that paragraph 32 of the Staff paper highlighted that contributions that are required to be attributed to periods of service as a negative benefit in accordance with paragraph 93 are those that are neither liked solely to the employee’s service rendered in the same period nor expected to be settled wholly before 12 months after the end of the annual reporting period in which the employees render the related service.  This member noted paragraph 32 of the Staff paper should end at “rendered in the same period” and that this would provide clarification of the meaning of service under paragraph 93.  This member also continued the view that the wording should make reference to the employee risk – i.e. if the contributions are related to funding the deficit in the plan then they fall under paragraph 93 as relate to an element of employee risk sharing.  In this situation she also then mentioned that Implementation Guidance could be issued.

The Chair highlighted that the views of the Committee members were suggesting that the Implementation Guidance alone would not be enough and to get to the view in the Implementation Guidance there would need to be an amendment to the standard.  The majority of the Committee members tentatively to this although it was not entirely clear what the Board would need to do in relation to the amendment.

One member noted that the amendment could be in the form of an exception to the rule of paragraph 93 of IAS 19.

Another mentioned that the definition of short-term employee benefit may need to be included within the amendment.  A discussion then took place as to the vesting of the employee benefits and for those that had vested (i.e. were settled) they would meet the current definition of a short-term employee benefit and would not be accounted for under paragraph 93.  Views were also shared that for those employee benefits that had an element that were settled and an element that was not settled, the settled element would be short-term and the non-settled (i.e. that had not vested) would be a post-employment benefit under paragraph 93.  It was noted that all employee contributions should therefore be taken as a reduction in service unless they are vested immediately.  An example given on the non-vested benefits was that the employee contributions are not paid out only based on the current service as an individual would have to work for more years to receive the benefit.  In this situation the short-term benefit is the net of the salary and the required employee contribution.  I.e. if the salary is £100 and the contribution is £4, the short term employee benefit is £100 if vested and £96 if not.  And if not vested then paragraph 93 will apply to the £4.  A number of Committee members shared this later view.

The Chair brought the discussion to a close and proposed two approaches to consider:

  • Approach 1 – follow the approach in the Implementation Guidance (some employee contributions are short-term and some are long term) – this will possibly require an amendment to IAS 19.
  • Approach 2 – Take the approach that the only aspect that is a short-term employee benefit is the net salary.  All employee contributions in a defined benefit plan follow paragraph 93.

The majority of Committee members tentatively agreed to approach 1.

The Chair then asked whether Implementation Guidance was enough on its own without an amendment.

The majority of Committee members tentatively agreed to an amendment to IAS 19 in the form of an exception to paragraph 93.

The Chair also noted that this would be taken immediately to the Board rather than as part of an Annual Improvement.

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