IFRS Vs German GAAP (PWC)
IFRS Vs German GAAP (PWC)
IFRS Vs German GAAP (PWC)
de
Similarities and
Differences: IFRS
and German GAAP
May 2018
Similarities and
Differences: IFRS
and German GAAP
May 2018
Similarities and Differences: IFRS and German GAAP
By Prof. Dr. Rüdiger Loitz, Guido Fladt, Björn Seidel and Thorsten Seidel
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This publication is intended to be a resource for our clients, and the information therein was correct
to the best of the authors’ knowledge at the time of publication. Before making any decision or taking
any action, you should consult the sources or contacts listed here. The opinions reflected are those
of the authors. The graphics may contain rounding differences.
Foreword
However, the convergence towards the use of IFRS simultaneously influences the
development of German GAAP.
We hope that this publication will be useful in identifying the key differences
between the two accounting frameworks and help you gain a broad understanding
of IFRS.
Contents
A Accounting framework.......................................................................................7
B Financial statements...........................................................................................8
D Business Combinations.....................................................................................26
E Revenue Recognition........................................................................................34
G Non-financial assets.........................................................................................47
H Financial assets................................................................................................73
I Liabilities..........................................................................................................82
J Financial liabilities...........................................................................................84
K Equity instruments...........................................................................................90
M Deferred taxes................................................................................................106
Q Other issues....................................................................................................120
Contacts................................................................................................................122
A Accounting framework
B Financial statements
1
company is publicly traded under German GAAP when it utilises an organised market for trading its issued securities (as defined by the
A
German Securities Trading Act) or when it has applied for an accreditation to trade its issued securities on an organised market.
2
However, small and micro-companies have permission to prepare condensed financial statements and are exempt from including a
management report. Further, micro-companies do not have to supplement their financial statements with notes if details are already
shown under the financial statements. Size-classes depend on companies’ exceeding or falling below certain thresholds concerning
revenue, profit and/or number of employees. Companies have to exceed or fall below two out of those three thresholds in two consecutive
years. Some companies are exempt from preparation of financial statements when their revenue and profit are below certain thresholds in
two consecutive years.
Current assets/liabilities include items due Separate presentation of fixed assets and
or expected to be realised within 12 months current assets is required. Current assets are
after the reporting period. Deferred taxes those not intended for long-term use in the
are classified as non-current in the state business.
ment of financial position with a current/
non-current break up discussed in the
notes.
Offsetting of assets and liabilities is only Offsetting assets and liabilities is only
allowed under restrictive conditions. allowed or compulsory under restrictive
conditions.
The term “exceptional items” is not used In each case, the amount and nature of
or defined. However, the separate the individual income and expenses of
disclosure is required (either on the face exceptional magnitude or of exceptional
of the comprehensive/separate income importance have to be disclosed insofar as
statement or in the notes) of items of the amounts are not of minor importance.
income and expense that are of such size,
nature, or incidence that their separate
disclosure is necessary to explain the
performance of the entity for the period.
3
German Accounting Standards (GAS) are generally applicable to all parent entities that prepare consolidated financial statements under
sec. 290 HGB as well as under sec. 264a subsec. 1 HGB (in conjunction with sec. 290 HGB) and to entities that are required to prepare
consolidated financial statements under sec. 11 PublG and set out procedures for consolidated financial statements. Application to
separate financial statements is encouraged by individual German Accounting Standards (for example GAS 22).
The statement of cash flows may be According to GAS 21 the statement of cash
prepared using the direct method flows shall report cash flows classified by
(cash flows derived from aggregating cash operating (presented either using the direct
receipts and payments associated with or indirect method), investing and financing
operating activities) or the indirect method activities (presented using the direct
(cash flows derived from adjusting method).
net income for non-cash transactions –
for example depreciation). The indirect Special regulations apply to statements of
method is more common in practice. cash flows of financial services institutions
(GAS 21 App. 2) and insurance enterprises
Non-cash financing and investing (GAS 21 App. 3).
transactions are to be disclosed.
Control exists if the investor (parent) has: Controlling interest exists when the parent
• power over the investee (subsidiary), (directly or indirectly through subsidiaries):
• exposure to variable returns from its • holds the majority of voting rights;
involvement with the investee, and • enjoys the right to appoint or dismiss
• has the ability to use its power over the the majority of the members of the
investee to affect its returns. administrative, management or
supervisory body governing financial and
Paragraph B3 of Appendix B to IFRS 10 operating policies, and is at the same
identifies the factors an investor should time a shareholder;
consider during its assessment of control • enjoys the right to exercise a controlling
over an investee. These are: influence on financial and operating
• the investee’s purpose and design; policies (based on a control agreement/
• what the relevant activities are; articles of association); or
• how decisions about those relevant • in substance obtains the majority of
activities are made; the risks and rewards of an entity that
• whether the rights of the investor give it has a narrow, well-defined purpose
the current ability to direct the relevant (see “Special purpose entity”).
activities;
• whether the investor is exposed, or
has rights, to variable returns from its
involvement with the investee; and
• whether the investor has the ability to use
its power over the investee to affect the
amount of the investor’s returns.
4
IFRS 10 provides a single definition of control that applies to all entities. This definition is supported by extensive application guidance that
explains the different ways in which a reporting entity (investor) might control another entity (investee). All entities are required to apply
this guidance. Previously, control through voting rights was addressed by IAS 27, while SIC 12 placed greater emphasis on exposure to
variable returns. However, the relationship between these two approaches to control was not always clear. IFRS 10 links power and returns
by introducing an additional requirement that the investor is capable of wielding that power to influence its returns.
In such a case, the following should be In this case, HGB offers an inclusion
considered in assessing an entity’s purpose option for the relevant subsidiary. When
and design: all inclusion options for subsidiaries have
• Downside risks and upside potential that been duly exercised and accordingly no
the investee was designed to create. subsidiary is subject to consolidation, the
• Downside risks and upside potential that obligation to prepare consolidated financial
the investee was designed to pass on to statements is not applicable.
other parties in the transaction.
• Whether the investor is exposed to those Under HGB potential voting rights that
risks and upside potential. could be exercised at the present time are
not taken into consideration.
IFRS 10 applies to all entities with the No comparable regulation with regard to
following exception. If the entity meets the investment entities.
definition of an investment entity it is
exempt from consolidating most of its
controlled investments. Instead, it records
most controlled investments as financial
assets at fair value through profit or loss.
5
IFRS 10 provides a single definition of control that applies to all entities. This definition is supported by extensive application guidance that
explains the different ways in which a reporting entity (investor) might control another entity (investee). All entities are required to apply
this guidance. Previously, control through voting rights was addressed by IAS 27, while SIC 12 placed greater emphasis on exposure to
variable returns. However, the relationship between these two approaches to control was not always clear. IFRS 10 links power and returns
by introducing an additional requirement that the investor is capable of wielding that power to influence its returns.
6
Unless the investment entity’s subsidiary provides services that relate to the investment entity’s investment activities; in this case it shall
consolidate that subsidiary and apply the requirements of IFRS 3 to the acquisition of any such subsidiary.
7
he IASB noted that paragraph 2(a) of IFRS 3 excludes, from the scope of IFRS 3, only the accounting by the joint arrangements
T
themselves in their financial statements.
The investor has to determine whether it The equity-method carrying amount has
is necessary to recognise any additional to be reviewed at each group reporting
impairment loss with respect to the investor’s date. If the equity-method carrying amount
net investment in the associate or joint exceeds the fair value of the investment in
venture and with the respect to the investor’s the associate, an impairment loss shall be
interest in the associate or joint venture that recognised.
does not constitute part of the net
investment and the amount of that Impairment losses initially reduce the
impairment loss. Because goodwill that goodwill which is being rolled forward in
forms part of the carrying amount of an the separate computation. Once goodwill
investment in an associate or joint venture has been written down in full, the remaining
is not separately recognised, it is not tested equity value is reduced. The reversal of
for impairment separately. Instead, the entire an impairment on the equity value is only
carrying amount of the investment is tested allowed as far as it is not based on goodwill.
for impairment as a single asset, by
comparing its recoverable amount with its
carrying amount. An impairment loss
recognised in those circumstances is not
allocated to any asset, including goodwill,
that forms part of the carrying amount of the
investment in the associate or joint venture.
D Business Combinations
Acquisition date
Share-based consideration
Contingent consideration
Transaction costs
8
If prior to the initial application of BilMoG consolidation has been carried out according to the book value or pooling of interest method,
these values may be retained and need no adjustment.
Step acquisitions
E Revenue Recognition
The standard sets forth a five-step model Revenues may only be recognised if they
for recognizing revenue from contracts with are realised at the balance sheet date
customers: (realisation principle). Under specific
1. Identify the contract with a customer circumstances, dividends may be
2. Identify the performance obligations (PO) recognised earlier than under IFRS in
in the contract single-entity financial statements.
3. Determine the transaction price
4. Allocate the transaction price to the German GAAP requires measurement
performance obligations of revenues at the fair value of the
5. Recognise revenue when (or as) each consideration received or receivable
performance obligation is satisfied. (usually cash or cash equivalents).
9
The term “probable” means more likely than not – that is, greater than 50 percent likelihood.
10
The stand-alone selling price is the price the good or service would be sold for if sold on a stand-alone basis.
11
ADS provides a list of criteria which have to be fulfilled in order to apply the percentage of completion method under German GAAP.
The actual return on plan assets, excluding German GAAP provides a choice regarding
amounts included in net interest on the net profit or loss derived from discount rate-
defined benefit liability (asset) is recognised related fluctuations, profit or loss due to
in other comprehensive income. changes in the fair value of plan assets
and non-interest income from plan assets.
All three components may consistently be
recognised in operating or finance income/
expense.
G Non-financial assets
Consistent with the component approach, Similar to IFRS. Under German GAAP,
replacement cost is recognised as PPE if impairment can only be applied to an asset
the recognition criteria are met. The as a whole.
carrying amount of the replaced parts is
derecognised.
Costs of conversion
If an entity cannot distinguish the research Distinction between research phase and
phase from the development phase of an development phase is crucial: expenditures
internal project to create an intangible from the research phase – in contrast to
asset, the entity treats all expenditure as if it expenditures from the development
were incurred in the research phase only. phase – shall not be recognised.
Research is the original and planned
investigation undertaken to gain new
scientific of technical knowledge or
experiences of general nature, about whose
usability and economic prospects no
statements can be made.
Inventories
Investment property
Value in use represents the future cash When the reasons for an impairment/
flows discounted to present value by using write-down no longer apply, a lower carrying
a pre-tax, market-determined rate that value resulting from a previous impairment/
reflects the current assessment of the time write-down may not be retained – the
value of money and the risks specific to the impairment has to be reversed. The reversal
asset for which the cash flow estimates of goodwill impairment is prohibited.
have not been adjusted.
1. Identified asset:
An asset is typically identified by being
explicitly specified in a contract.
2. Control of use:
To control the use of an identified asset,
a customer is required to have the right
to obtain substantially all of the economic
benefits and to direct the use throughout
the period of use.
Subsequent measurement:
A lessor shall recognise finance income
over the lease term, based on a pattern
reflecting a constant periodic rate of return
on the lessor’s net investment in the lease.
H Financial assets
Definition
Recognition
Categories
Initial measurement
Subsequent measurement
Disclosures:
Extensive disclosures are required,
including reconciliations of opening to
closing amounts and disclosure of
assumptions and inputs.
I Liabilities
Contingent liabilities
Restructuring provisions
J Financial liabilities
Definition
Classification
Recognition
Categories
Other liabilities
Initial measurement
Subsequent measurement
Convertible debt
K Equity instruments
Items that do not qualify as hedged item All assets, liabilities and derivatives (i. e. firm
comprise: commitments) may qualify as hedged items,
• own equity instruments provided that the risk to be hedged can be
• entity method investment, such as an specifically identified and measured.
associate or joint arrangement
• A derivative instrument can only
be designated as a hedged item as
part of an aggregate exposure with
an non-derivative item.
• A firm commitment to acquire a business
cannot be a hedged item, except for
foreign exchange risk, because the
other risks that are hedged cannot be
specifically identified and measured.
13
Only for fair value hedge of the interest rate exposure of a portfolio of financial assets or liabilities IFRS 9, IFRS 9 permits entities to apply
the hedge accounting requirements in IAS 39 instead of IFRS 9. In that case the entity must also apply the specific requirments for the fair
value hedge accounting for a portfolio hedge of interest rate risk and designate as the hedged item a portion that is a currency amount.
M Deferred taxes
Tax rate
Set off
Distribution restrictions
Discounting
Disclosures
Tax groups
N Share-based payments
Classification
Awards that offer the counterparty the Transactions with choice of settlement
choice of settlement in equity instruments (either counterparty or entity) should be
or settlement in cash should be bifurcated measured either as equity-settled or as
and treated as a compound instrument. cash-settled, whatever is more probable.
If the entity has the choice to settle in cash Before settlement the amount should
or by the issue of equity instruments, the always be shown as a liability and not as
entity has a present obligation (legal or an increase in equity.
constructive) to settle in cash. The entity
has a present obligation if the choice of
settlement has no commercial substance
or if the entity has a past practice or stated
policy of settling in cash. If no such
obligation exists, the entity shall account
the transaction as equity-settled share-
based payment transaction.
Functional currency
P Related parties
Q Other issues
Segment reporting
Discontinued operations
Contacts
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