International Finance and Accounting Handbook

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taxes are the deferral method and the liability method. The objective of the deferral
method is to match tax expense with pretax book income. Deferred taxes are based
on the effect of past tax differences; they are not updated for subsequent events or
changes in tax rates. This approach was most prevalent in Canada. However, Cana-
dian entities must use the liability method (as discussed below) in determining de-
ferred tax beginning in 2002. The alternative is the liability method. The focus of de-
ferred tax accounting under this method is the balance sheet, whereas the focus of the
deferral method is the income statement. The objective of the liability method is to
determine the amount of future taxes payable or receivable on the basis of cumula-
tive temporary differences between the book and tax basis of assets and liabilities at
the balance sheet date. Deferred taxes on temporary differences are accrued on the
basis of tax rates expected to be in effect when the differences reverse. Amounts pre-
viously deferred are subsequently adjusted when tax rates change. Countries in which
variations of this method are followed include the Netherlands, the United Kingdom,
Italy, and the United States. It is interesting to note that standard setters have taken
different approaches to limiting the recognition of deferred taxes. For example, in the
United Kingdom, a deferred tax provision is required to be recorded when it is rea-
sonable to assume that the circumstances that gave rise to these differences will re-
verse in the foreseeable future.
The original IAS 12, “Accounting for Taxes on Income,” permitted either the de-
ferral method or the liability method to be applied, but the revised IAS 12, “Income
Taxes,” approved in 1996, mandates a comprehensive liability method.
The revised IAS 12 is similar to U.S. GAAP. However, certain differences will
arise, for example, with respect to the determination of the enactment date of a
change in tax rates and with respect to intercompany profit eliminations. The revised
IAS indicates that deferred tax assets and liabilities should be measured according to
tax rates that have been enacted or substantively enacted at the balance sheet date.
The substantively enacted concept is intended to acknowledge that in some jurisdic-
tions, such as Australia, Canada, and the United Kingdom, announcements by the
government have the substantive effect of actual enactment even though the tax rate
change may not occur for several months. This is because in their systems of parlia-
mentary democracy, the party with the majority in parliament has a high degree of
certainty that the tax rate change it announces will be passed. While final outcome of
the U.S. legislative process may not always be so easily predicted, there have been
instances where, through announcements of support, it is virtually certain that a tax
bill will be passed by Congress and signed into law by the president. Under U.S.
GAAP, however, the tax rate change must have been enacted before it is booked. Ac-
tual enactment does not occur until an act is finally passed into law (i.e., signed into
law by the president or given Royal Assent in a commonwealth country). Thus, sub-
stantive enactment and actual enactment may occur in two different reporting peri-
ods. Conceptually, there are strong arguments for and against the substantive-enact-
ment-date concept, and few would take the position that the IAS approach is
unreliable.
Intercompany profit eliminations give rise to temporary differences in cases where
the gain is recognized for tax purposes but deferred for book purposes until realized.
The issue is whether the tax effect of the temporary difference should be measured
by reference to the seller’s tax rate or the buyer’s tax rate. Using the seller’s tax rate
removes any income statement effect of the sale in the period in which it occurs by
eliminating the gain and deferring the tax paid on the gain in the seller’s tax juris-


12 • 18 SUMMARY OF ACCOUNTING PRINCIPLE DIFFERENCES
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