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Section 24 – Income Tax
Section 24 deals with the recognition, presentation and measurement of current and deferred taxes. It also covers the accounting for value added tax and other similar sales tax, which are not income taxes.
Scope of this section
Extract from FRS 105 – Section 24.1 – 24.3
24.1 For the purpose of this FRS, income tax includes all domestic and foreign taxes that are based on taxable profit.
24.2 This section covers accounting for income tax. It requires a micro-entity to recognise the current tax consequences of transactions and other events that have been recognised in the financial statements. Current tax is tax payable (refundable) in respect of the taxable profit (tax loss) for the current period or past reporting periods. This section prohibits the recognition of deferred tax which represents the future tax consequences of transactions and events recognised in the financial statements of the current and previous periods.
24.3 This section also covers accounting for value added tax (VAT) and other similar sales taxes, which are not income taxes.
Scope
Section 24 deals with the recognition, presentation and measurement of current and deferred taxes. It also covers the accounting for value added tax and other similar sales tax, which are not income taxes.
Section 24 splits tax into current and deferred tax.
Current tax is tax payable/(refundable) in respect of the taxable profit/(taxable loss) for the current period or past reporting periods.
Deferred tax represents the future tax consequences of transactions and events recognised in the financial statements of the current and previous periods.
Current tax
Extract from FRS 105 – Section 24.4 – 24.6, Section 24.8 and Section 24.12
24.4 A micro-entity shall recognise a current tax liability for tax payable on taxable profit for the current and past periods. If the amount of tax paid for the current and past periods exceeds the amount of tax payable for those periods, the micro-entity shall recognise the excess as a current tax asset.
24.5 A micro-entity shall recognise a current tax asset for the benefit of a tax loss that can be carried back to recover tax paid in a previous period.
24.6 A micro-entity shall measure a current tax liability (asset) at the amount of tax it expects to pay (recover) using the tax rates and laws that have been enacted or substantively enacted by the reporting date.
24.8 A micro-entity shall not discount current tax assets and liabilities.
Presentation – Allocation in profit or loss
24.12 A micro-entity shall present changes in a current tax liability (asset) as tax expense (income).
OmniPro comment
The tax rate to be used in the financial statement is the tax rate that applies to the period under review that has substantively been enacted by the balance sheet date. A substantial enactment occurs where the country has included it in legislation.
The Republic of Ireland tax rate can be regarded as having been substantively enacted if it is included in the Bill that has been passed by the Dail. It is deemed substantively enacted in the UK if a Bill has been passed by the House of Commons and is awaiting only a passage of time through the House of Lords and Royal Assent.
If the tax rate is not enacted until after the reporting period, then this rate cannot be used. The rate in force during the year should be used.
Example 1: Impact of change in tax rate – substantively enacted just after year end
Company A operates in Ireland. During the year the government announced in the budget that the tax rate would change to 10%. The company year-end is 31 December 2014. The tax rate is not substantively enacted by the government until 10 January 2015. The tax rate prior to this was 12.5%. At the year end 31 December 2014, the company should calculate its tax at the 12.5% rate.
Deferred tax should also be measured at the tax rate of 12.5%. In effect it is a non-adjusting post balance sheet event. The fact that the rates changed and the deferred tax impact of the change in rate from 12.5% to 10% should be disclosed in a note to the financial statements.
Example 2: Change in rate during the year
Company A’s year end is 31 December. The tax rate for the first 3 months of the year was 20% and the tax rate for the remaining 9 months was 10%. The tax rate that should be used for computing taxable profits should be the weighted average of these rates.
Tax rate of 20% for 3 months = 20%/12mths*3mths = 5%
Tax rate of 10% for 9 months = 10%/12mths*9mths = 7.5%
Total average rate to be used in the financial statements 12.5%
If the profits are earned somewhat evenly during the year, then the tax rate of 12.5% can be used in the tax computation.
Uncertain tax positions
FRS 105, Section 24 does not specifically deal with uncertain tax positions which can be common issues in entities. Section 16 specifically scopes Section 24 out of its scope. Section 2 of FRS 105 makes it clear that entity’s management should use its judgement in developing and applying an appropriate accounting policy and it can review other sections in determining the policy to take. It may be usual to either apply a weighted average possibility or a best estimate. The policy chosen should be consistently applied.
An entity should also assess whether the uncertain tax positions should be looked at collectively or individually, which again will be an accounting choice which should be applied consistently.
When assessing whether a provision is required an assessment has to be made as to whether it is probable that the entity will be able to defend the position it has taken. Where it is not probable then a disclosure is required, where it is probable it can be defended then no provision is required. In effect an entity will usually look to the definition of a provision and contingent liability in Section 16 as to whether a provision is required. Where it is not probable, a decision has to be made as to whether a disclosure is required.
If interest is charged by the tax authorities FRS 105, is not clear on where this should be posted. Given that it is not tax, it is likely appropriate for this to be included in the interest and charges section of the profit and loss. However this is not set in stone and will require judgement. Disclosure should be included in the accounting policy note explaining where interest and penalties are posted (only relevant for ROI entities as ROI entities requires the accounting policies in the financial statements – UK entities do not require this disclosure). There may be a stronger argument for penalties to be posted to the tax line.
Discounting
Current tax cannot be discounted as stated in Section 24.8.
Adjustments in respect of prior years
In determining the current tax charge for the year, the financial statements may be signed off before the corporation tax computation is submitted. Therefore there are likely to be estimates included. It is common practice for the difference between the tax computation submitted and the amount included in the accounts to be adjusted prospectively as a change in accounting estimate.
It is usually included in a line in the tax note stating ‘adjustment in respect of prior years’. However, care should be taken to assess whether it was in fact due to a change in estimate or if it was due to an error. As the tax note disclosure is not required to be disclosed in the financial statements under FRS 105 this will not be shown to the readers of the financial statements. This is not always clear cut. If an incorrect tax rate was used, obviously this was an error and if material a prior year restatement would be required under Section 8 of FRS 105. If it is considered to be a change in estimate, then as per Section 8, disclosure of the reason for the change in estimate should be disclosed as well as the effect on the current year’s financial statements (only required for ROI entities, not required for UK entities).
Recognition of current tax asset
A current tax asset should be recognised where the preliminary tax paid is in excess of the corporation tax charge for the year.
A current tax asset can also be recognised where losses were made in the year for tax purposes as the losses can be carried back to the previous year of the same length. If an entity decides not to carry back losses, then deferred tax should not be recognised on these losses as deferred tax cannot be recognised under Section 24.
Example 3: Carry back of losses
Company A incurred losses of CU100,000 in the year which are all allowable for tax purposes. In the previous year the company had taxable trading profits of CU150,000 and paid tax at 10% so tax of CU15,000 was paid on this income. Therefore the losses in the current year of CU100,000 can be offset against the taxable trading profit in the prior year of CU150,000 which leaves CU50,000 taxable in the prior year. Assuming the prior year tax has been paid, the company can recognise a current tax asset for the CU10,000 (CU100,000*10%) refundable from the tax authorities. If there was CU200,000 losses in this example the remaining CU5,000 (CU50,000*10%) could not be recognised as a deferred tax asset even it is probable future profits will be available to utilise this loss as Section 24 does not permit deferred tax to be recognised.
Taxation of certain adjustments on transition to FRS 105
The tax authorities issued guidelines on how the adjustments posted on transition which effect corporation tax should be dealt with. The Irish Revenue have confirmed that the majority of adjustments which have fallen out for tax purposes will be taxable/tax deductible over a 5 year period starting in the first year of preparing the financial statements under FRS 105 (e.g. if the first year preparing financial statements under FRS 105 is 31 December 2016 then 1/5th of the adjustment will be taken into account in the YE 31 December 2016 tax computation and the remaining amounts included in the tax computation over the following four years unless the company ceases in which case it is taxable/tax deductible in the last year).If the company ceases within the 5 years the remaining adjustment is taxed in the final period.
Where this arises an adjustment will be required on transition to show the the correct corporation tax liability/asset and charge under FRS 105.
Note this is the general rule, however there are special rules for bad debt provision adjustments etc. See the principal transition adjustments for examples where a corporation tax adjustment will be required.
Example 4: Taxation of certain adjustments on transition
Under previous GAAP Company A did not accrue for holiday pay. FRS 105 requires holiday pay to be accrued. The amount of the accrual at the date of transition was CU10,000 and at the end of the comparative year was CU15,000. At the end of the comparative year this CU15,000 was not allowed as a deduction in the tax computation. Assuming the tax authorities guidelines on taxing items that have fell out on transition from previous GAAP to FRS 105 is that these are taxed/tax deductible over a 5 year period, then an adjustment will be required on transition to the corporation tax liability/asset and comparative year corporation tax charge so that the charge and liability shown is what would have been shown had FRS 105 applied from inception. The journals required would be to (assuming a corporation tax rate is 10%):
On date of transition
|
|
CU |
CU |
|
Dr Corporation Tax on balance sheet (CU10,000*10%) |
1,000 |
|
|
Cr Profit and Loss Reserves |
|
1,000 |
Being journal to reflect the correct corporation tax liability at date of transition if FRS 105 applied from inception (will be realised over 5 years from the current year i.e. the year of first preparing FRS 105 financial statements)
At the end of the comparative year
|
|
CU |
CU |
|
Dr Corporation Tax on balance sheet ((CU15,000-CU10,000)*10%) |
500 |
|
|
Cr Corporation tax in P&L |
|
500 |
Being journal to reflect the correct corporation tax liability and in the comparative year (will be realised over 5 years from the current year i.e. the year of first preparing FRS 105 financial statements)
|
At end of current year |
CU |
CU |
|
Dr Corporation Tax in P&L |
300 |
|
|
Cr Corporation Tax in Balance Sheet |
|
300 |
Being journal to reflect the additional deduction for 1/5th of the expense not previously given up to 31/12/15 which has therefore fallen out under FRS 105. Note this assumes that the tax journal posted will include the transition tax adjustment for the CU300 when it is finally recognised. If there was no corporation tax in 2016, then the CU300 would still be recognised as a debit to the P&L as it would no longer be refundable from the tax authorities. As no deferred tax can be recognised under FRS 105 it cannot be held as deferred tax asset on the balance sheet as a timing difference. The remaining CU1,200 (CU1,500-CU300) will still be included as an asset at the year end in the corporation tax nominal and released over the remaining 4 yrs.
Allocation of the tax expense
Section 24 makes it clear that the tax expense follows the accounting treatment for the transaction. Therefore where share costs are incurred on issue of shares, the tax deduction is posted to equity. See Section 17 for further details. FRS 105 does not require a tax note reconciling the tax charge per the accounts to the actual tax charge multiplied by the standard rate of tax, therefore there is no disclosure requirements with regard to the tax charge other than showing the tax charge in the P&L.
Deferred tax
Extract from FRS 105 – Section 24.7
24.7 A micro-entity shall not recognise deferred tax.
OmniPro comment
Section 24 does not permit deferred tax to be recognised. The tax charge equals the actual charge per the tax computation.
Offsetting
Extract from FRS 105 – Section 24.13
24.13 A micro-entity shall offset current tax assets and current tax liabilities, if and only if, it has a legally enforceable right to set off the amounts and it intends either to settle on a net basis or to realise the asset and settle the liability simultaneously.
OmniPro comment
See illustration of the point above through examples below:
Example 5: Offset of current tax assets and liabilities
Company A owes tax for year 1 totaling CU10,000 which has not been paid but a refund is due for year 2 of CU5,000.
In the financial statements the net CU5,000 can be shown as a creditor in the notes to the financial statements. Netting is allowed as it is tax due to the same tax authority and there is a right of offset.
Example 6: Offset of current tax assets and liabilities
Company A owes tax for year 1 totaling CU10,000 to the Irish government for its operations in Ireland and a tax refund of CU2,000 is due from the UK government.
In this instance no netting can occur. CU10,000 would be shown as a tax creditor and CU2,000 shown as a tax debtor.
Withholding tax on dividends
Extract from FRS 105 – Section 24.9 – 24.10
24.9 When a micro-entity pays dividends to its shareholders, it may be required to pay a portion of the dividends to taxation authorities on behalf of shareholders. Outgoing dividends and similar amounts payable shall be recognised at an amount that includes any withholding tax but excludes other taxes, such as attributable tax credits.
24.10 Incoming dividends and similar income receivable shall be recognised at an amount that includes any withholding tax but excludes other taxes, such as attributable tax credits. Any withholding tax suffered shall be shown as part of the tax charge.
OmniPro comment
Dividend should be accounted gross in the financial statements for the receiver and payer. Where dividend is paid by an Irish resident company to another one, then no element needs to be withheld. However where dividend is received by countries outside of Ireland then dividend tax may be withheld.
Value added tax and other similar sales tax
Extract from FRS 105 – Section 24.11
24.11 Turnover included in profit or loss shall exclude VAT and other similar sales taxes on taxable outputs an/d VAT imputed under the flat rate VAT scheme. Expenses shall exclude recoverable VAT and other similar recoverable sales taxes. Irrecoverable VAT allocable to fixed assets and to other items separately recognised shall be included in their cost where practicable and material.
OmniPro Comment
Turnover and costs should be stated exclusive of vat where the company is vat registered other than irrecoverable VAT as stated in the VAT Acts. Where the entity is not vat registered it should be included inclusive of vat
Transition exemptions
Section 24 does not provide any exemption on transition therefore all adjustments have to be made retrospectively. As a result deferred tax will have to be derecognised at the date of transition. In addition as FRS 102 requires the close company surcharge to be accrued in the year it arises, this may require an adjustment as FRS 105 does not require this to be recognised.
Principal transition adjustments
1) Derecognition of deferred tax recognised under previous GAAP (applicable to entities transitioning from old GAAP/FRSSE and FRS 102)
FRS 105 does not permit deferred tax to be recognised.
Under old GAAP (FRS 19)/ and FRSSE the company was required to recognise deferred tax on all timing differences other than on revaluation of fixed assets (unless there is a binding agreement to sell) and fair value adjustments in business combinations.
Under FRS 102 the company was required to recognise deferred tax on all timing differences including revaluations and fair value adjustments in business combinations.
As a result on transition to FRS 105 a journal will be required to derecognise all deferred tax assets/liabilities on the balance sheet at the date of transition. An adjustment will also be required in the comparative year to reverse any deferred tax recognised in the P&L/STRGL/OCI such that no deferred tax is shown in the P&L and balance sheet at the end of the comparative year. Where the current year GAAP is initially prepared under previous GAAP a similar adjustment will be required in the current year.
When making this journal, there would be no need to derecognise on a transaction by transaction basis instead it can be done as one journal.
Example 8: Derecognition of deferred tax recognised under previous GAAP (applicable to entities transitioning from old GAAP/FRSSE and FRS 102)
Under previous GAAP the company had a deferred tax liability of CU52,992, CU84,323 and CU133,684 recognised on the balance sheet at 31 December 2014, 2015 and 2016 respectively and movement of CU31,331 and CU49,361 recognised in the P&L in the 2015 and 2016 year respectively. At the date of transition CU10,000 of the CU52,992 related to a revaluation reserve and therefore was included as a debit against the revaluation reserve (deferred tax on revaluation reserve only applicable for entities transitioning from FRS 102)
In addition a further CU1,000 and CU2,000 of deferred tax movement was recognised in OCI/STRGL and then the revaluation reserve in the 2015 and 2016 year respectively.
FRS 105 does not permit deferred tax to be recognised as a result an adjustment is required on transition. Therefore wherever deferred tax was recognised on the balance sheet or in the P&L or OCI/STRGL –a journal should be posted to strip it out of the balance sheet and P&L/OCI.
The following journals are posted to reflect this derecognition:
On 1 January 2015:
|
|
CU |
CU |
|
Dr deferred tax liability |
52,992 |
|
|
Cr Revaluation Reserve |
|
10,000 |
|
Cr P&L reserves |
|
42,992 |
Being journal to reflect derecognition of all deferred tax on the balance sheet at the date of transition
In the year ended 31 December 2015 assuming the above journals are posted to reserves etc:
|
Dr deferred tax liability (CU84,323-CU52,992) |
31,331 |
|
|
Cr deferred tax in OCI/STGRL/Revaluation Reserve |
|
1,000 |
|
Cr deferred tax in P&L |
|
30,331 |
Being journal to reverse the movement on deferred tax recognised in the P&L/OCI under FRS 102/old GAAP/FRSSE in 2015
In the year ended 31 December 2016 assuming the above journals are posted to reserves etc:
|
|
CU |
CU |
|
Dr deferred tax liability |
49,361 |
|
|
Cr deferred tax in OCI/STGRL/Revaluation Reserve |
|
2,000 |
|
Cr deferred tax in P&L |
|
47,361 |
Being journal to reverse the movement on deferred tax recognised in the P&L/OCI under FRS 102/ old GAAP/FRSSE in 2016
2) Derecognition of close company surcharge accrual in the year in which it arises (applicable to entities transitioning from FRS 102 only)
FRS 105 does not require the close company surcharge to be recognised in the year it arises assuming that a dividend would be paid within 18 months of the year end to avoid it or there was no distributable reserves which prevented the company from paying it.
Under Section 29.14 of FRS 102 the close company surcharge is required to be provided for in the year to which it relates unless a dividend is declared pre-year end regardless of whether a dividend will be paid to avoid this surcharge.
Example 9: Derecognition of close company surcharge accrual in the year in which it arises (applicable to entities transitioning from FRS 102 only)
Company A is a close company. The date of transition is 1 January 2015.
Under FRS 102 there was a close company surcharge payable of CU50,000, CU30,000, CU35,000 and CU40,000 for the 31 December 2013, 2014, 2015 and 2016 year end respectively which had been accrued in the FRS 102 results. The reason for this is that under FRS 102 Section 29.14 the close company surcharge is required to be provided for in the year to which it relates unless a dividend is declared pre-year end regardless of whether a dividend will be paid to avoid this surcharge.
A dividend had not been paid or declared for the 2013 and 2014 years up to 1 January 2015 and no dividend had been declared for the 2015 and 2016 years. However it was probable a dividend would be paid to avoid it. Assume the:
– 2013 dividend was declared and paid in 2015 year and therefore the close company surcharge was avoided.
– 2014 dividend was declared and paid in 2016 year and therefore the close company surcharge was avoided.
Under FRS 105 the entity should not account for the close company surcharge in the year it arose on the basis that it was probable a dividend would be paid within 18 months of the year end to avoid it or there was no distributable reserves which allowed the company to avoid paying it. As a result of this difference a transition adjustment is required.
The transition adjustments required are:
1 January 2015
|
|
CU |
CU |
|
Dr close company surcharge provision |
80,000 |
|
|
Cr profit and loss reserves |
|
80,000 |
Being journal to reverse the provision for the close company surcharge for the 2013 and 2014 year previously accounted for under FRS 102 not required under FRS 105
The journals required on 31 December 2015 assuming the above journals are posted to reserves etc are:
|
|
CU |
CU |
|
Dr close company surcharge provision |
35,000 |
|
|
Cr corporation tax in P&L |
|
35,000 |
Being journal to reverse the close company surcharge for 2015 recognised under FRS 102 but not required under FRS 105
|
|
CU |
CU |
|
Dr corporation tax in P&L |
50,000 |
|
|
Cr close company surcharge provision |
|
50,000 |
Being journal to reverse the posting recognised under FRS 102 which released the 2013 close company surcharge for 2013. As this provision no longer existed under FRS 105 due to the journal posted on the date of transition, it needs to be reversed under FRS 105.
The journals required on 31 December 2016 assuming the above journals are posted to reserves etc are:
|
|
CU |
CU |
|
Dr close company surcharge provision |
40,000 |
|
|
Cr corporation tax in P&L |
|
40,000 |
Being journal to reverse the close company surcharge for 2015 recognised under FRS 102 but not required under FRS 105
|
|
CU |
CU |
|
Dr corporation tax in P&L– adjustment in respect of prior year |
30,000 |
|
|
Cr close company surcharge provision |
|
30,000 |
Being journal to reverse the posting recognised under FRS 102 which released the 2014 close company surcharge for 2014. As this provision no longer existed under FRS 105 due to the journal posted on the date of transition, it needs to be reversed under FRS 105.
If we assume in the above example that the dividend to avoid the 2013 surcharge was not paid (although it was assumed it would be at each period end before this) and therefore the surcharge was paid over in 2014 and the surcharge provision released under FRS102. The journal required on transition would be to:
|
|
CU |
CU |
|
Dr corporation tax in P&L |
50,000 |
|
|
Cr close company surcharge provision |
|
50,000 |
Being journal to reverse the set off of the surcharge payment for 2013 from the provision for the surcharge under FRS 102 (as this no longer exists under old GAAP) and instead post it to the P&L.
The same approach would be adopted in the 2016 year if the 2014 surcharge was not avoided.
3) Derecognition of discounting on current tax
FRS 105 does not permit current tax to be discounted. Old GAAP(FRS 19) and FRSSE gave the option to entities to discount current taxes. As a result in the event discounting was utilised an adjustment will be required on transition. In the majority of instances entities will not have discounted the current tax however where this has been done it should be adjusted.
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