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India had the unique opportunity to early adopt Ind AS 115 as compared to rest of world.
Nonetheless, entities will have to once again undergo the process of unlearning and relearning.
The five step model is robust and would serve as a useful compass for all types of transactions
in the new digital era. The new challenges which would emerge due to the new standard would
have to be addressed over a period of time (issue which were resolved under old standard may
resurface under the new standard). However consistency, uniformity, transparency and detailed
guidance for accounting revenue in case of complex transaction would outweigh the difficulties.
The impact of accounting on transition to new standard under Income tax law could be an
additional challenge which Corporate India will have to deal with. Application of Ind AS 115
will require new as well as different thinking! Read on to know more…
Overview
Considering the need to converge on one of the
most significant pillar of financial statement,
‘Revenue’, IASB and FASB after more than a
decade of joint work in May 2014 issued converged Av
guidance on recognizing revenue in contracts with On
CA. Sandeep Shah and customers. The IASB titled the standard as ‘IFRS
CA. Milan Mody
15- Revenue from Contracts with Customers’ and
(The authors are members of the
Institute. They can be reached at FASB also titled it ‘Revenue from Contracts with
milanmody23@gmail.com) Customers (Topic 606)’.
Available
Online @
Ind AS 115 which is aligned to IFRS 15 was notified Reasons for issuing the new standard on
by MCA on 28th March, 2018 & is applicable Revenue:
for accounting periods beginning on or after a. remove inconsistencies and weakness in existing
1st April, 2018. revenue recognition guidelines
b. improve comparability of revenue recognition
Ind AS 115 & IFRS 15 replaces the following
practices across entities, jurisdictions and capital
standards and interpretations :
markets
Indian Accounting Standard Title IFRS
Ind AS 18 Revenue IAS 18
Ind AS 18 Guidance note on accounting for Real Estate Transactions IFRIC 15
(note 1)
Appendix A to Ind AS 18 Revenue-xxx Barter Transactions involving Advertising SIC 31
services
Appendix B to Ind AS 18 Customer Loyalty Programmes IFRIC 13
Appendix C to Ind AS 18 Transfer of Assets from Customers IFRIC 18
Ind AS 11 Construction Contracts IAS 11
Note 1 - Guidance note withdrawn by ICAI in
terms of announcement dated 1st June, 2018. Ind AS 115 provides more guidance for deciding
whether revenue is recognised at a point in time or
Note 2 - Service Concession Arrangement & over time. It also provides new and more detailed
disclosures which was part of Ind AS 11 (Appendix guidance on specific topics such as multiple element
A & B) will now be part of Ind AS 115 (Appendix arrangements, variable consideration, contract
D & E). modification, price allocation,
warranties, licensing, etc.
Comparison with Ind AS 18/11 & Ind AS 115
Ind AS 18/11 Ind AS 115
Separate models for: Single model for performance obligations
Construction contracts Satisfied over time
Goods Satisfied at a point in time
Services
Focus on risks and rewards Focus on control
Limited guidance on: More guidance on:
Multiple element arrangements Separating elements
Variable considerations Allocating the transaction price
Licenses Variable consideration
Licenses
Options
Repurchase arrangements
Revenue measured at the fair value of the Consideration measured as the amount the entity
consideration received or receivable. expects to be entitled to.
Contract Revenue-initial amount & variations in Transaction price including variable
contract work. consideration.
Limited disclosure under Ind AS 18. Sufficient disclosure to understand the nature,
amount, timing and uncertainty of revenue and
cash flows arising from contracts.
c. provide more useful information to users also provides requirements for the accounting for
of financial statements through improved contract modifications.
disclosure requirements Step 2: Identify performance obligations in
d. provide a single comprehensive framework Contract
to recognize revenue from customers A contract includes promises to transfer goods or
∙ Ind AS 115 provides more guidance for services to a customer. If those goods or services are
deciding whether revenue is recognised at distinct, the promises are performance obligations
a point in time or over time. It also provides and are accounted for separately. A good or services
new and more detailed guidance on specific is distinct if the customer can benefit from the
topics such as multiple element arrangements, good or service on its own or together with other
variable consideration, contract modification, resources that are readily available to the customer
price allocation, warranties, licensing, etc. and the entity’s promise to transfer the good or
service to the customer is separately identifiable
Scope: from other promises in the contract.
∙ The new revenue model would apply to all Step 3: Determine transaction price
contracts with customers except Leases,
Insurance contracts, Financial Instruments The transaction price is the amount of consideration
including those covered by Consolidated (for example, payment) to which an entity expects
Financial Statements/ Joint Arrangements/ to be entitled in exchange for transferring promised
Separate Financial Statements/ Investments goods or services to a customer, excluding amounts
in Associates and Joint Ventures and non- collected on behalf of third parties (for e.g. Goods
monetary exchange between entities in same and Service Tax).
business line to facilitate sales to customers or The transaction price can be fixed amount of
potential customers. Extraction of mineral ore customer consideration, but it may sometimes
will be covered as this is not specifically scoped include variable consideration or consideration in
out. a form other than cash.
∙ In case a contract which is partially within the Step 4: Allocate the transaction price to the
scope of Ind AS 115 & another standard, in performance obligations in the contract
case the other standard specify how to separate An entity typically allocates the transaction price
or measure one or more parts of the contracts, to each performance obligation on the basis of
then an entity shall first apply requirement of the relative stand-alone selling prices of each
that standard and in absence thereof, Ind AS distinct good or services promised in the contract.
115 will be applied. If a stand-alone price is not observable, an entity
Five- step model-heart of the standard: estimates it. Various methods that may be used,
including:
Step by step guidance on when, how and how much
should the revenue be recognised: ∙ Adjusted market assessment approach
∙ Expected cost plus a margin approach
Step 1: Identify Contract(s) with a customer
∙ Residual approach (only permissible in
A contract is an agreement between two or limited circumstances)
more parties that creates enforceable rights and
obligations and which has been agreed upon Step 5: Recognise revenue when (or as) the
with a customer and meets specified criteria. entity satisfies a performance obligation
The contract could be oral or written or based on An entity recognises revenue when it satisfies
customary industry practise. In some cases, Ind a performance obligation by transferring a
AS 115 requires an entity to combine contracts promised good or services to a customer (When
& account for them as one contract. Ind AS 115 customer obtains control of that good or service).
The entity will recognize a revenue over time if any Costs to fulfil a contract
of the following criteria are met: Costs incurred to fulfil a contract with a customer
∙ The customer receives and consumes the are not within the scope of another standard are
benefits of the seller’s performance as the recognised as an asset only if all the following
seller performs criteria are met:
∙ The seller creating a work in progress asset a. Costs are directly related to contract
which is controlled by the customer b. Costs generate or enhance resources that will
∙ The seller creating a work in progress asset be used to satisfy performance obligations in
which could not be directed to a different future
customer and in respect of which the c. The entity expects to recover the cost
customer has an obligation to pay for the Examples: Direct labour, direct materials,
entity’s work to date payments to subcontractors, etc.
Over a period of time is somewhat akin to Contract Modifications
percentage of work completed method (POCM)
under the erstwhile Ind AS 11 Construction A contract modification is a change in the scope or
contracts and the Guidance Note on Accounting price (or both) that is approved by the contracting
for Real Estate Transactions. parties & can be accounted as a separate contract
provide both of the conditions are met:
An entity will recognise a revenue at a point in time
for performance obligations that do not meet the ∙ The scope of the contract increases because
criteria for recognition of revenue over time. of the addition of promised goods or services
that are distinct
Factors which may indicate that control is passed
at a point in time include, but are not limited to: ∙ Price of the contract increases by an amount
of consideration that reflects the entity’s
∙ The entity has a present right to payment for stand-alone selling price of the additional
the asset; goods or services & any other adjustments
∙ The customer has legal title to the asset;
E-commerce market place where bundle of
∙ The entity has transferred physical possession products on on-going basis are added to the
of the asset; contract and prices of existing/new products are
∙ The customer has significant risks and rewards not always on standalone price, the revenue per
related to the ownership of the asset; and product (balance of original and new products/
∙ The customer has accepted the asset. quantities) will have to be determined carefully.
Contract Cost Repurchase agreements
Ind AS 115 provides a guidance about two types A repurchase agreement is a contract in which an
of costs related to the contract, namely cost to entity sells an asset and also promises or has the
obtain the contract and cost to fulfil the contract option (either in the same contract or in another
contract) to repurchase the asset. The repurchased ∙ The most likely amount ( where there are
asset may be the asset that was originally sold to few amounts to consider)
the customer, an asset that is substantially the same Constraining estimate : include variable
as that asset, or another asset of which the asset consideration only to the extent that it is highly
that was originally sold is a component. probable that a significant reversal in the amount
of cumulative revenue recognised will not occur
when the uncertainty associated with the variable
Non-refundable upfront fees includes additional fees consideration is subsequently resolved.
charged at (or near) the inception of the contract
(e.g. joining fees, activation fees, set-up fees etc.). Warranties
Treatment depends on whether the fee relates to Assurance type (apply Ind AS 37) :
the transfer of goods or services to the customer at
inception. In most of the cases, it would be enabler for ∙ An assurance to the customer that the good
provision for future supply of goods and services and or service will function as specified
hence will be treated as advance payment. ∙ The customer cannot purchase this warranty
separately from the entity
Service type (accounted for separately in
Repurchase agreements generally come in three accordance with Ind AS 115) :
forms:
∙ A service is provided in addition to an
∙ an entity’s obligation to repurchase the asset assurance to the customer that the good or
(a forward) service will function as specified
∙ an entity’s right to repurchase the asset (a ∙ This applies regardless of whether the
call option) customer is able to purchase this warranty
∙ an entity’s obligation to repurchase the asset separately from the entity
at the customer’s request (a put option) In determining the classification (or part thereof)
Under all the scenarios detailed accounting of a warranty, an entity considers:
guidance is provided as to whether the transaction
Legal requirements: warranties required by
is to be accounted as (a) Lease transaction, (b)
law are usually assurance
financing arrangement or (c) sale of product with
type
a right to return.
Length: longer the length of
Variable considerations coverage, more likely
If the consideration promised in a contract additional services are
includes a variable amount, an entity shall estimate being provided
the amount of consideration (subject to constraint) Nature of tasks: do they provide a service
to which the entity will be entitled in exchange for or are they related to
transferring the promised goods or services to a assurance
customer.
Non-refundable upfront fees
Examples: Discounts, rebates, refunds, credits,
Includes additional fees charged at (or near)
incentives, performance bonuses, penalties, etc.
the inception of the contract (e.g. joining fees,
An entity shall estimate an amount of variable activation fees, set-up fees etc.). Treatment
consideration by using either of the following depends on whether the fee relates to the transfer
methods : of goods or services to the customer at inception. In
∙ The expected value based on probability most of the cases, it would be enabler for provision
weighted amounts within a range (i.e. for for future supply of goods and services and hence
large number of similar contracts) will be treated as advance payment. The revenue
recognition period may in some cases be longer Impact on bottom-line due to changes in
than the contractual period if the customer has guidance on top line
a right to, and is reasonably expected to, extend/ ∙ It is difficult to conclude whether revenue
renew the contract. would be accelerated or postponed, each
Licensing (of an entity’s intellectual industry will have different impact.
property (IP)) ∙ Due to combining of contracts, revenue
would be deferred, but due to separating of
Ind AS 115 includes specific guidance on performance obligations, the revenue may
accounting for Licences & whether it is distinct be recognised earlier.
from other goods or services or not.
∙ For real estate the impact has been elaborated
below in the section on challenges
The new standards focus on qualitative and ∙ For software, telecom and construction
quantitative disclosures. The disclosure companies the impact would be significant
requirements are more exhaustive but at the same on certain specific nature of transactions.
time the standard requires a balance between too ∙ Incremental cost to acquire a contract being
much information and too little information. The
objective of the disclosure requirements in the new accounted as an asset as opposed to expense
standards is to provide “sufficient information to will improve the net result position.
enable users of financial statements to understand ∙ Given the pervasive nature of the impact
the nature, amount, timing and uncertainty of of the standard, in addition to the financial
revenue and cash flows arising from contracts with
customers.”
reporting impact, companies would also
have to assess impact on business contracts
and processes, as well as the needs of
Other items: stakeholders such as investors and analysts.
This article deals with only few of the topics Presentation and disclosures
and not with application concerning specific The new standards focus on qualitative and
conditions and situations. Considering that quantitative disclosures. The disclosure
Ind AS 11 & Ind AS 18 are being combined requirements are more exhaustive but at the same
into single standard, Ind AS 115 also lays time the standard requires a balance between too
down principles as to whether Goods and much information and too little information.
Services will constitute distinct contract or
The objective of the disclosure requirements in the
single performance obligation. In particular
new standards is to provide “sufficient information
Engineering, Procurement, Construction and/
to enable users of financial statements to understand
or Management (EPC or EPCM), Hospitality
the nature, amount, timing and uncertainty of
(wedding function wherein rooms, function
revenue and cash flows arising from contracts with
areas & other services are provided), Telecom
customers.” To achieve that objective, entities are
/ IT & IT enabled industry, Engineering
required to provide disclosures about its contracts
companies in supply of capital goods with
with customers, the significant judgements and
extensive integration into existing facilities will
changes in those judgements used in applying the
have to reassess / analyse the ongoing contracts
standards and assets arising from costs to obtain
in light of the principles enunciated. Once
and fulfil its contract.
having analysed, each component will also have
to be tested whether the performance obligation Transition
is satisfied at a point in time or over time. There An entity can elect to adopt the new standard
can be various combination in a single contract retrospectively with or without optional practical
and price allocation to each of the component expedient or through cumulative effect adjustment
will have to be determined. on the date of initial application i.e. 01st April, 2018