Thursday, 24 August 2023

Note on Exposure Draft Ind AS 12

Indian Accounting Standards (Ind AS) are based on the IFRS Standards issued by the International Accounting Standards Board (IASB).

 

In this regard, it may be noted that IFRS Standards are being issued/revised by the IASB from time to time. As a part of convergence with IFRS Standards, the Ind AS may be issued/revised corresponding to the IFRS Standards. Accordingly, whenever any amendments are made or new IFRS Standard/IFRIC is issued by the IASB, the Accounting Standards Board (ASB) of the ICAI considers those amendments and other related aspects for amending the corresponding Ind AS.

 

In this regard, the Accounting Standards Board has issued Exposure Draft of International Tax Reform—Pillar Two Model Rules – Amendments to Ind AS 12 corresponding to Amendments to IAS 12 issued by the IASB.

 

The draft amendments to Ind AS 12 aim to provide temporary relief from requirements to recognise and disclose information about deferred tax assets and liabilities arising from Pillar Two model rules published by the Organisation for Economic Co-operation and Development (OECD).

 

 

Below is the amendments to IAS 12 :

 

On 23 May 2023, the International Accounting Standards Board (the IASB or Board) issued International Tax Reform—Pillar Two Model Rules – Amendments to IAS 12 (the Amendments) to clarify the application of IAS 12 Income Taxes to income taxes arising from tax law enacted or substantively enacted to implement the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) Pillar Two model rules (Pillar Two income taxes).

 

What is Pillar 2:

Pillar 2 arose out of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project and aims to end the ‘race to the bottom’ on tax rates by ensuring that multinationals pay a minimum effective corporate tax rate (of 15% regardless of the local tax rate or tax base).

 

In March 2022, the OECD released technical guidance on its 15% global minimum tax agreed as the second ‘pillar’ of a project to address the tax challenges arising from digitalisation of the economy. This guidance elaborates on the application and operation of the Global Anti-Base Erosion (GloBE) Rules agreed and released in December 2021 which lay out a co-ordinated system to ensure that multinational enterprises with revenues above €750 million pay tax of at least 15% on the income arising in each of the jurisdictions in which they operate.

 

The IASB decided to respond to stakeholders’ concerns about the potential implications of the imminent implementation of these rules on the accounting for income taxes by jurisdictions. In particular, the IASB noted that the situation is very complicated as:

 

·       jurisdictions may change statutory tax rates to avoid being considered a low-tax environment;

·       companies might decide to move their business to jurisdictions with higher statutory tax rates; and

·       companies might engage in business that comes with tax incentives that might bring down their statutory tax rate to below 15% although the jurisdiction they are doing business in is not generally considered a low-tax environment.

 

All of these and further considerations would entail most complicated calculations of deferred tax in a situation that is highly volatile due to the fact that jurisdictions implement the OECD rules at different speed and different points of time. Due to the many unknown variables involved, the IASB has decided to develop a mandatory exemption until the global tax system has settled and reestablished itself and the IASB can thoroughly assess the situation and provide a reliable solution.

 

Changes to IAS 12:

 

The amendments in International Tax Reform — Pillar Two Model Rules (Amendments to IAS 12) are:

 

1.     An exception to the requirements in IAS 12 that an entity does not recognise and does not disclose information about deferred tax assets and liabilities related to the OECD pillar two income taxes. An entity has to disclose that it has applied the exception.

2.     A disclosure requirement that an entity has to disclose separately its current tax expense (income) related to pillar two income taxes.

3.     A disclosure requirement that state that in periods in which pillar two legislation is enacted or substantively enacted, but not yet in effect, an entity discloses known or reasonably estimable information that helps users of financial statements understand the entity’s exposure to pillar two income taxes arising from that legislation.

4.     The requirement that an entity applies the exception and the requirement to disclose that it has applied the exception immediately upon issuance of the amendments and retrospectively in accordance with IAS 8. The remaining disclosure requirements are required for annual reporting periods beginning on or after 1 January 2023.

 

The IASB will continue to monitor developments related to the implementation of the pillar two model rules. It plans to undertake further work to determine whether to remove the temporary exception — or to make it permanent — after there is sufficient clarity about how jurisdictions implemented the rules and the related effects on entities.

 

The mandatory temporary exception –applies immediately.

 

The remaining disclosure requirements apply for annual reporting periods beginning on or after 1 January 2023, but not for any interim periods ending on or before 31 December 2023.

 

Entities need to monitor the developments around the implementation and (substantive) enactment of the Pillar Two model rules in the relevant jurisdictions and should get ready to provide the disclosures required by the amendments to IAS 12.

 

 

 

Exposure draft issued based on the above IAS 12.

 

The draft amendments to Ind AS 12 aim to provide temporary relief from requirements to recognise and disclose information about deferred tax assets and liabilities arising from Pillar Two model rules published by the Organisation for Economic Co-operation and Development (OECD).

 

Below is the amendment in IND AS 12

 

This Standard applies to income taxes arising from tax law enacted or substantively enacted to implement the Pillar Two model rules published by the Organisation for Economic Co-operation and

Development (OECD), including tax law that implements qualified domestic minimum top-up taxes described in those rules. Such tax law, and the income taxes arising from it, are hereafter referred to

as ‘Pillar Two legislation’ and ‘Pillar Two income taxes’. As an exception to the requirements in this Standard, an entity shall neither recognise nor disclose information about deferred tax assets and liabilities related to Pillar Two income taxes

 

Below are the disclosure requirements as per draft IND AS 12:

 

Disclosure

 

International tax reform—Pillar Two model rules

 

88A An entity shall disclose that it has applied the exception to recognising and disclosing information about deferred tax assets and liabilities related to Pillar Two income taxes (see

paragraph 4A).

 

88B An entity shall disclose separately its current tax expense (income) related to Pillar Two income taxes.

 

88C In periods in which Pillar Two legislation is enacted or substantively enacted but not yet in effect, an entity shall disclose known or reasonably estimable information that helps users of

financial statements understand the entity’s exposure to Pillar Two income taxes arising from that legislation.

 

88D To meet the disclosure objective in paragraph 88C, an entity shall disclose qualitative and quantitative information about its exposure to Pillar Two income taxes at the end of the reporting period. Thisinformation does not have to reflect all the specific requirements of the Pillar Two legislation and can be provided in the form of an indicative range. To the extent information is not known or reasonablyestimable, an entity shall instead disclose a statement to that effect and disclose information about the entity’s progress in assessing its exposure.

 

Examples illustrating paragraphs 88C–88D

Examples of information an entity could disclose to meet the objective and requirements in paragraphs 88C–88D include:

(a) qualitative information such as information about how an entity is affected by Pillar Two legislation and the main jurisdictions in which exposures to Pillar Two income taxes might

exist; and

(b) quantitative information such as:

(i) an indication of the proportion of an entity’s profits that might be subject to Pillar Two income taxes and the average effective tax rate applicable to those profits; or

Examples illustrating paragraphs 88C–88D

(ii) an indication of how the entity’s average effective tax rate would have changed if Pillar Two legislation had been in effect.

 

Effective date

 

98M International Tax Reform—Pillar Two Model Rules, added paragraphs 4A and 88A–88D. An entity shall:

(a) apply paragraphs 4A and 88A immediately upon the issue of these amendments and retrospectively in accordance with Ind AS 8; and

(b) apply paragraphs 88B–88D for annual reporting periods beginning on or after 1 April 2023. An entity is not required to disclose the information required by these paragraphs for any interim period ending on or before 31 March 2024.

 

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