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Contents

29.1 Scope.

29.1 Overview.

29.1.1 Current tax.

29.1.2 Deferred tax.

29.2 Recognition and measurement of current tax.

29.2.1 Extract from FRS102: Section 29.3 – 29.5.

29.2.2 OmniPro comment.

29.2.2.1 What tax rate to use.

29.2.2.1.1 Ireland and UK rules.

29.2.2.1.2 Impact of change in tax rate – substantively enacted just after year end.

29.2.2.1.3 Change in rate during the year.

29.2.2.2 Uncertain tax positions.

29.2.2.2.1 Analysis.

29.2.2.2.2 Assessing whether a provision is required.

29.2.2.3 Interest charged on late payment of taxes.

29.2.2.4 Discounting.

29.2.2.5 Adjustments in respect of prior years.

26.2.2.6 Recognition of current tax asset.

29.2.2.6.1 Tax paid in excess of tax charge for current and previous periods.

29.2.2.6.2 Tax losses set back to prior periods.

29.2.2.7 Allocation of the tax expense.

29.3 Provision for close company surcharge.

29.3.1 Extract from FRS 102 Section 29.14.

29.3.2 OmniPro comment.

29.3.2.1 Close company surcharge – distributable estate and investment income/service company close company surcharge.

29.4 Recognition of deferred tax. 

29.4.1 Extract from FRS102: Section 29.6–29.17. 

29.4.2 OmniPro comment. 

29.4.2.1 Deferred tax defined and the purpose of deferred tax. 

29.4.2.2 Permanent differences. 

29.4.2.2.1 Analysis. 

29.4.2.2.1.1 The one exception for recognising a permanent difference for deferred tax. 

29.4.2.3 Temporary differences. 

29.4.2.3.1 Temporary differences defined. 

29.4.2.3.2 Definition of deferred tax assets and instances where they arise. 

29.4.2.3.2.1 When does a deferred tax asset exist including examples. 

29.4.2.3.3 Definition of deferred tax liabilities and instances where they arise. 

29.4.2.3.3.1 When does a deferred tax liability exist including examples. 

29.4.2.3.4 Recognition of timing differences –  the rules. 

29.4.2.3.4.1 Unrelieved tax losses – The rule recognition or not. 

29.4.2.3.4.2 Where conditions for retaining the tax allowances have been met – no requirement to recognise timing differences. 

29.4.2.3.4.3 Non-recognition of timing difference arising as a result of associates/JV’s branches subsidiaries in consolidated financial statements where certain conditions exist. 

29.4.2.3.4.4 No recognition of timing difference on goodwill recognised in a business combination. 

29.4.2.4 Measurement. 

29.4.2.4.0 Initial recognition exception. 

29.4.2.4.1 What tax rate to use. 

29.4.2.4.1.1 The rate to use for non- depreciable land and investment property. 

29.4.2.4.1.2 Review of the recovery of how a deferred tax asset/liability is recovered/settled. 

29.4.2.4.1.2.1 Manner of recovery through use. 

29.4.2.4.1.2.2 Manner of recovery through sale. 

29.4.2.4.1.2.3 Manner of recovery – dual use. 

29.4.2.4.1.3 Effect of change in classification of assets. 

29.4.2.4.1.4 Determining the value of timing difference. 

29.4.2.4.1.4.1 Overview.

29.4.2.4.1.4.2 Indexation and how is this accounted for. 

29.4.2.4.1.5 Discounting. 

29.4.2.4.1.6 Deferred tax impact if unlikely to be taxable/tax deductible on future sale. 

29.4.2.4.1.7 Steps involved to working out deferred tax. 

29.4.2.4.1.8 Some examples of timing differences. 

29.4.2.4.1.8.1 Timing differences on depreciable fixed assets including revaluations (accelerated/decelerated capital allowances). 

29.4.2.4.1.8.1.2 Steps to calculate deferred tax for fixed asset timing differences. 

29.4.2.4.1.8.1.3 Application of deferred tax to fixed assets. 

29.4.2.4.1.8.1.3.1 Deferred tax allowable for tax and depreciable. 

29.4.2.4.1.8.1.3.2 Asset allowable for tax, depreciable and revalued. 

29.4.2.4.1.8.1.3.3. Accounting for revaluations and subsequent movements including deferred tax – depreciable/not allowable for capital allowance purposes. 

29.4.2.4.1.8.1.3.3.1 Treatment of depreciation on upward revaluation. 

29.4.2.4.1.8.2 Accounting for deferred tax on non-depreciable land. 

29.4.2.4.1.8.3 Deferred tax on investment properties carried at fair value. 

29.4.2.4.1.8.3.1 Deferred tax – assessing if tax is payable on settlement/realisation of timing difference.

29.4.2.4.1.8.4 Pension contributions/royalty charges. 

29.4.2.4.1.8.5 Finance leases. 

29.4.2.4.1.8.6 Unrelieved tax losses. 

29.4.2.4.1.8.6.1 Ability to recognise unutilised losses against other deferred tax liabilities. 

29.4.2.4.1.8.7 Fair value adjustments. 

29.4.2.4.1.8.7.1 Further exampls of deferred tax where fair value adjustments are recognised. 

29.4.2.4.1.8.7.1.1 Non-puttable ordinary shares and deferred tax. 

29.4.2.4.1.8.7.1.2 Interest rate swaps – derivatives and deferred tax. 

29.4.2.4.1.8.7.1.3 Forward foreign currency contract and deferred tax. 

29.4.2.4.1.8.7.1.4 Investment is associates/joint ventures or subsidiaries held at fair value and deferred tax. 

29.4.2.4.1.8.7.1.5 Investment in associates, joint venture, subsidiary carry at revolved amount and deferred tax. 

29.4.2.4.1.8.7.1.6 Complex financial instruments held at fair value through profit and loss and deferred tax. 

29.4.2.4.1.8.8 Defined benefit obligations. 

29.4.2.4.1.8.8.1 Presentation of deferred tax on balance sheet and in the statement of comprehensive income. 

29.4.2.4.1.8.9 Consolidation adjustments. 

29.4.2.4.1.8.10 Investment in associates, joint ventures, subsidiaries in consolidated accounts. 

29.42.4.1.8.11 Assets partly allowable for tax purposes. 

29.4.2.4.1.8.12 Items expensed which are capital in nature (allowable for capital allowances). 

29.4.2.4.1.8.13 Transition adjustments to a new GAAP. 

29.5 Measurement of deferred tax on business combinations. 

29.5.1 Extract from FRS102: Section 29.11. 

29.5.2 OmniPro comment. 

29.6 Withholding tax on dividends. 

29.6.1 Extract from FRS102: Section 29.18-29.19. 

29.6.2 OmniPro comment. 

29.7 Offsetting. 

29.7.1 Extract from FRS102: Section 29.24-29.24A.

29.7.2 OmniPro comment. 

29.7.2.1 Off setting current tax. 

29.7.2.2 Offsetting deferred tax assets and liabilities. 

29.8 Value Added Tax (“VAT”) and other similar taxes. 

29.8.1 Extract from FRS 102: Section 29.20. 

29.8.2 OmniPro comment. 

29.9 Presentation and disclosures. 

29.9.1 Extract from FRS102: Section 29.21-29.27. 

29.9.2 OmniPro comment. 

29.9.2.1 Presentation. 

29.9.2.1.1 Where to recognise the tax charge/credits in the statements of comprehensive income. 

29.9.2.1.2 Where to recognise the tax asset or liability on the balance sheet. 

29.9.2.1.2.1 Deferred tax. 

29.9.2.1.2.2 Current tax. 

29.9.2.2 Disclosures. 

29.9.2.2.1 Overview.. 

29.9.2.2.2 Accounting Policies. 

29.9.2.2.3 Notes to the financial statements. 

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The below extracts and guidance is applicable for periods beginning before 1 January 2019 and are based on the September 2015 version of FRS 102. For periods beginning on or after 1 January 2019, the March 2018 version of FRS 102 applies which incorporates the changes made by the Triennial review of FRS 102. Note the March 2018 version of FRS 102 can be voluntarily applies for periods beginning before 1 January 2019. For the extracts from the March 2018 version of FRS 102 and the related guidance please click on the following link. For details of a summary of the main changes as a result of the triennial review please see the following link.

29.9 Presentation and disclosures
29.9.1 Extract from FRS102: Section 29.21-29.27

Allocation in comprehensive income and equity

29.21 An entity shall present changes in a current tax liability (asset) and changes in a deferred tax liability (asset) as tax expense (income) with the exception of those changes arising on the initial recognition of a business combination which shall be dealt with in accordance with paragraph 29.11.

29.22 An entity shall present tax expense (income) in the same component of total comprehensive income (i.e. continuing or discontinued operations, and profit or loss or other comprehensive income) or equity as the transaction or other event that resulted in the tax expense (income).

Presentation in the statement of financial position

29.23 An entity shall present deferred tax liabilities within provisions for liabilities and deferred tax assets within debtors.

Disclosures

29.25 An entity shall disclose information that enables users of its financial statements to evaluate the nature and financial effect of the current and deferred tax consequences of recognised transactions and other events.

29.26 An entity shall disclose separately the major components of tax expense (income). Such components of tax expense (income) may include:

(a) current tax expense (income);

(b) any adjustments recognised in the period for current tax of prior periods;

(c) the amount of deferred tax expense (income) relating to the origination and reversal of timing differences;

(d) the amount of deferred tax expense (income) relating to changes in tax rates or the imposition of new taxes;

(e) adjustments to deferred tax expense (income) arising from a change in the tax status of the entity or its shareholders; and

(f) the amount of tax expense (income) relating to changes in accounting policies and material errors (see Section 10 Accounting Policies, Estimates and Errors).

29.27 An entity shall disclose the following separately:

(a) the aggregate current and deferred tax relating to items that are recognised as items of other comprehensive income or equity;

(b) a reconciliation between:

(i) the tax expense (income) included in profit or loss; and

(ii) the profit or loss on ordinary activities before tax multiplied by the applicable tax rate;

(c) the amount of the net reversal of deferred tax assets and deferred tax liabilities expected to occur during the year beginning after the reporting period together with a brief explanation for the expected reversal;

(d) an explanation of changes in the applicable tax rate(s) compared with the previous reporting period;

(e) the amount of deferred tax liabilities and deferred tax assets at the end of the reporting period for each type of timing difference and the amount of unused tax losses and tax credits;

(f) the expiry date, if any, of timing differences, unused tax losses and unused tax credits; and

(g) in the circumstances described in paragraph 29.14, an explanation of the nature of the potential income tax consequences that would result from the payment of dividends to its shareholders.

29.9.2 OmniPro comment
29.9.2.1 Presentation
29.9.2.1.1 Where to recognise the tax charge/credits in the statements of comprehensive income

As per section 29.20 of FRS 102 an entity should recognise current and deferred tax as a tax expense in the income statement/profit and loss account. The one exception to this is deferred tax recognised in a business combination as stated in section 29.11 of FRS 102, in that case it gets recognised in goodwill.  (see 29.5.2)

Section 29.22 of FRS 102 makes it clear that the tax or equity expenses should be recognised in the same area where the related cost was recognised e.g. if a revaluation was recognised in other comprehensive income then the  tax expense (deferred tax)  will also get recognised in the other comprehensive income:

29.9.2.1.2 Where to recognise the tax asset or liability on the balance sheet
29.9.2.1.2.1 Deferred tax

Section 29.23 of FRS 102 requires that deferred tax liabilities are included within provisions for liabilities and deferred tax assets within debtors.

29.9.2.1.2.2 Current tax

Current tax liability is to be recognised within debtors and current tax assets within debtors.

29.9.2.2 Disclosures
29.9.2.2.1 Overview

It is evident from sections 29.25 to 29.27 of FRS 102 that the tax note should not show any timing differences within it. A reconciliation of the expected tax charge (i.e. applying the standard rate of tax to the profit before tax) to the total tax charge is required. See below for illustration of the disclosure requirement of Sections 29.25 to 29.27 of FRS 102.

29.9.2.2.2 Accounting Policies

Example 41: Extract from the accounting policy note and notes to the financial statements
A Taxation

The company is managed and controlled in the location and, consequently, is tax resident in location.  Tax is recognised in the profit and loss account, except to the extent that it relates to items recognised in other comprehensive income or directly in equity.  In this case tax is also recognised in other comprehensive income or directly in equity respectively.

Current tax

(i) Current tax is calculated on the profits of the period. Current tax is determined using tax rates (and laws) that have been enacted or substantively enacted by the balance sheet date.

(ii) Deferred tax

Deferred tax arises from timing differences that are differences between taxable profits and total comprehensive income as stated in the financial statements. These timing differences arise from the inclusion of income and expenses in tax assessments in periods different from those in which they are recognised in financial statements.

Deferred tax is provided in full on temporary differences arising between the tax bases of assets and liabilities and their carrying amounts in the financial statements.

Deferred tax is determined using tax rates (and laws) that have been enacted or substantively enacted by the balance sheet date and are expected to apply when the related deferred income tax asset is realised or the deferred tax liability is settled.

Deferred tax assets are recognised to the extent that it is probable that future taxable profits will be available against which the temporary differences can be utilised.

Current or deferred taxation assets and liabilities are not discounted.

INCLUDE THE BELOW IF CONSOLIDATED FINANCIAL STATEMENTS ARE BEING PREPARED

If a temporary difference arises from initial recognition of an asset or liability in a transaction other than a business combination that at the time of the transaction does not affect accounting or taxable profit or loss, no deferred tax is recognised.  Deferred tax is provided on temporary differences arising on investments in subsidiaries and associates and joint ventures, except where the timing of the reversal of the temporary difference is controlled by the Group and it is probable that the temporary difference will not reverse in the foreseeable future.


29.9.2.2.3 Notes to the financial statements
Extract from notes to the financial statements – tax note
 

              2015

CU

              2014

CU

   
a)    Analysis of tax expense in profit and loss:    
      Current tax:    
      Irish corporation tax on profit/(loss) on ordinary activities               XXX               XXX
      Adjustment in respect of prior years               XXX               XXX
      Foreign tax

              XXX

                      

              XXX

                      

            XXXX             XXXX
      Deferred tax:
      Origination and reversal of timing differences
      Adjustment in respect of prior periods
      Impact of change in tax rate

            XXXX

                      

            XXXX

                      

      Tax on profit on ordinary activities (see note 9(c)) 1,500,000 1,000,000

(i)   During the year the Irish Government changed the capital gains tax rate from X% to X% which was substantively enacted on 2016. The year end deferred tax asset/liability has been measured at X% being the tax rate in force at the year end date. The impact of applying the updated rate of x% would result in the deferred tax asset/liability increasing by X%.

b)   Analysis of tax expense in other comprehensive income:    
      Deferred tax:  
      Actuarial loss on pension scheme             XXXX                     –
      Impact of change in tax rate

            XXXX

                      

            XXXX

                      

      Tax included in other comprehensive income            XXXX            XXXX

 c) Reconciliation of the expected tax charge at the statutory tax rate to the actual tax charge at the effective rate

The assessed tax charge for the year/period is different to the statutory rate of corporation tax in the Republic of Ireland of 10% (2014: 10%).  The differences are explained below:

2015

CU

2014

CU

      Profit/(loss) on ordinary activities before tax       9,463,690             (XXX)
      Profit/(loss) on ordinary activities multiplied by statutory rate of corporation tax in Republic of Ireland of 10% (2014: 10%)

946,369

(XXX)

      Effects of:
      Expenses not deductible for tax purposes          132,138                     –
      Income taxed at passive rate              1,349                     –
      Indexation on capital gains              1,349                     –
      Effect of deferred tax not previously recognised            (9,280)                     –
      Adjustment in respect of prior years            (9,280)                     –

      Other

Deferred tax at a higher rate

             3,618

XXX

                    –

XXX

      Higher rate of tax on foreign earnings

         565,875

                      

                    –

                      

      1,500,000                     –

d) Factors that may affect future tax charges

The company has tax losses carried forward of CUXXXX (2014: CUXXX) that are available indefinitely for offset against future taxable profits. The directors have reviewed the potential deferred tax asset of CUXXX at 31 December 2015 (2014: CUXXX) and have concluded that it is inappropriate to recognise it in the company’s balance sheet at this time.

e) Included in the charge is a close company surcharge of CUXXX. As requested by Section 29.14 of FRS 102 this must be recognised in the year it arises regardless of the fact that if a dividend is ad within 18 months it is no longer payable. If a dividend is paid within this time period, then the tax charge of CUXXX would no longer arise.

Extract from notes to the financial statements – deferred tax note (balance sheet) classified as Provision for liabilities in the balance sheet

Deferred tax

The deductible and taxable temporary differences at the year/period end dates in respect of which deferred tax has been recognised are analysed as follows:

 

              2015

CU

              2014

CU

Deferred tax liabilities/(assets) (deductible temporary differences)
Capital allowances in excess of depreciation                     –                     –
Provisions                     –                     –
Post-employment benefits                     –                     –
Tax losses carried forward                     –                     –
Other deductible temporary differences

                    –

                   

                    –

                   

                    –                     –

Movement in deferred tax assets and liabilities, during the year, were as follows:

Capital allowances Provisions Tax losses -carried forward Post- employment benefit Other Total
   CU  CU CU CU CU CU
2015
At 1 January 2015                    –                     –                     –                     –                –
Recognised in profit and loss 177,328 307,132 307,132 484,460
Acquisitions                    –                     –                     –                     –                –
Recognised in other comprehensive income 177,328 307,132 307,132 484,460
Disposals                    –                     –                     –                     –                –
Foreign exchange and other                    –                     –                     –                     –                –
At 31 December 2015 177,328 307,132 307,132                     – 484,460
  Capital allowances Provisions Tax losses -carried forward Post- employment benefit Other Total
   CU CU CU CU CU CU
2014
At 1 January 2014                     –
Recognised in profit and loss 177,328 307,132 307,132 484,460
Acquisitions
Recognised in other comprehensive income 177,328 307,132 307,132 484,460
Disposals
Foreign exchange and other
At 31 December 2014 177,328 307,132 307,132 484,460

(i) The net deferred tax liability/asset expected to reverse in the 2016 year is CUXXXX. The reversal relates to the timing difference on tangible fixed assets and capital allowances through depreciation and amortisation. The above amount also incorporates the expected usage of losses carried forward.

(ii) The unused tax losses are as year end as detailed above. There are no unused tax credits. There is no expiry date with regard to these losses.

(iii) No deferred tax is recognised on unremitted profits of its associates as there is no liability to tax on these when remitted.

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Examples

Example 1: Impact of change in tax rate – substantively enacted just after year end.

Example 2: Change in rate during the year.

Example 3: Carry back of losses.

Example 4: Close company surcharge.

Example 5: Close company surcharge –  no distributable reserves.

Example 6: Losses forward – recognition of deferred tax.

Example 7: Deferred tax liabilities available to utilise deferred tax assets.

Example 8: Conditions for retaining tax allowances have been met.

Example 9: Dual use manner of recovery.

Example 10: Indexation of base cost – non depreciable asset.

Example 11: Allowable for tax and depreciable.

Example 12: Asset allowable for tax, depreciable and revalued.

Example 13: Accounting for revaluations and subsequent movements including deferred tax – depreciable/not allowable for capital allowance purposes.

Example 14: Transfer of depreciation on revalued amount from profit and loss reserves. 

Example 15: Accounting for initial and subsequent revaluations on non-depreciable assets – i.e. on land. 

Example 16: Fair value movements and deferred tax impact. 

Example 17: Investment Property Fair value movements and deferred tax impact (no tax expected when settled until a certain date). 

Example 18: Pensions/royalties. 

Example 19: Pensions/royalties. 

Example 20: Finance lease. 

Example 21: Non-puttable ordinary shares and deffered tax. 

Example 22: Interest rate swaps – derivatives and deffered tax. 

Example 23: Forward foreign currency contract and deffered tax. 

Example 24: Investment is associates/joint ventures or subsidiaries held at fair value and deffered tax. 

Example 25: Investment in associates, joint venture, subsidiary carry at revolved amount and deffered tax.

Example 26: Complex financial instruments held at fair value through profit and loss and deferred tax. 

Example 27: Defined benefit obligations. 

Example 28: Presentation of deferred tax on balance sheet and in the statement of comprehensive income. 

Example 29: Deferred tax on net defined benefit asset/liability. 

Example 30: Recognising deferred tax. 

Example 31: Deferred tax on consolidated adjustments – elimination of profit from inventory. 

Example 32: Undistributed profits of a subsidiary. 

Example 33: Assets partly allowable for tax purposes

Example 34: Deferred tax on business combinations. 

Example 35: Deferred tax on a business contribution where net assets as opposed to shares are acquired. 

Example 36: Dividend received. 

Example 37: Offset of current tax assets and liabilities. 

Example 38: Offset of current tax assets and liabilities. 

Example 39: Offset of current tax assets and liabilities. 

Example 40: Offset of deferred tax assets and liabilities. 

Example 41: Extract from the accounting policy note and notes to the financial statements. 

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