Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 IFRS Convergence and Its Impacts on Taxation: A Case Study on Fixed Assets in Indonesia Prianto Budi Saptono* and Eko Suwardi** This study focuses on aspects of the International Financial Reporting Standards (IFRS) convergence and its impact on taxation in Indonesia, particularly for fixed assets. The study was conducted by reviewing the accounting and tax aspects related to fixed assets, comparing them, and identifying the effect of IFRS convergence in fixed assets for taxation. This study is qualitative and uses exploratory and descriptive research approach. The study refers to the accounting standards and related tax laws. The result shows that the application of SFAS 16 (Revised 2011), in particular the use of revaluation model, can raise significant tax problems. If the revaluation model is applied, but the entity does not apply to the Directorate General of Taxation (DGT), in practice, gain on the revaluation could be recognized in the fiscal and taxed at 10% rate. However, if Article 4 paragraph 1 letter m and Article 19 of the Income Tax Act and Minister of Finance Regulation (MoFR) No. 79/PMK.03/2008 are explored more deeply, the possibility of the imposition of the final tax (10%) does not need to happen. Explicitly, MoFR No. 79/PMK.03/2008 stipulates that to apply fixed asset revaluation for tax purposes, taxpayer’s application and the approval of the Director General of Taxation are required. Key words: IFRS convergence, accounting, fixed assets, taxation, revaluation model. A. Introduction In Indonesia, Financial Accounting Standards (FAS) that is based on IFRS (International Financial Reporting Standard) officially commenced since 2012 as financial reporting standards. In practice, these standards are commonly known as General FAS. Such term is used by Indonesian Institute of Accountants(IAI) to differentiate it from FAS for Small Medium Enterprises (SMEs) applied on entity without significant public accountability. In this case, IAI’s FAS Board decided to implement convergence to IFRS, instead of adoption. There are some international accounting standards that have not been applied, i.e. IFRS 1 and IAS 4. IAI’s FAS Board still also endorsed some accounting standards which are not convergent to IFRS. In addition, some other standards adopted from IFRS were also modified. Related tax problem arises when an entity as a corporate taxpayer is obliged to apply General FAS. One of tax problems is in the application of Statement of Financial Accounting Standard (SFAS) 16 (Revised 2011): Fixed Assets. This SFAS shall be applied for annual periods beginning on or after 1 January 2012. _____________________________ *Master of Management, Faculty of Economics and Business, Universitas Gadjah Mada **A Lecturer at the Faculty of Economics and Business, Universitas Gadjah Mada, Indonesia, Email: fisaqori@yahoo.com, Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 The SFAS refers to International Accounting Standard No. 16 (Revised 2009): Property, Plant and Equipment. There are two model for subsequent measurement: cost model and revaluation model. When applying cost model, entity will not encounter any tax problem as Indonesian tax regulation stipulates that asset is measured based on historical cost. However, when applying revaluation model, entity regularly has to revalue its fixed assets according to paragraph 31 of SFAS 16 (Revised 2011). The paragraph stipulates as follows: “After recognition as an asset, an item of fixed asset whose fair value can be measured reliably shall be carried at a revalued amount, being its fair value at the date of the revaluation less any subsequent accumulated depreciation and subsequent accumulated impairment losses. Revaluations shall be made with sufficient regularity to ensure that the carrying amount does not differ materially from that which would be determined using fair value at the end of the reporting period” (IAI, 2011). If revaluation model as described above is tied up with tax regulation, there will be gain on fixed asset revaluation. The further question is whether or not tax authority may impose 10% tax on the gain when the entity does note apply a letter to get approval from the tax authority. The tax refers to Minister of Finance (MoF) Regulation no. 79/PMK.03/2008 and Article 19 of Income Tax Law. According to these rules, an entity as corporate taxpayer is allowable to apply its fixed asset revaluation for fiscal purpose that is an exemption on 10% tax of capital gain. The rules stipulates that tax authority has obligation to reply application letter by either approving or disapproving the application. In the case that entity is approved by tax authority to revalue its fixed assets for fiscal purpose, the problem is very simple. The entity is obligated to pay 10% final tax on gain of fixed asset revaluation approved by tax authority. On the other hand, if entity applies revaluation model. Then, it revalues its fixed assets without any approval from tax authority since the entity does not apply any letter to tax office. Can tax authority impose tax on the gain? Does tax authority accept the new carrying amount of the assets after revaluation? Such problems are summarized in Tabel 1. Tablel 1: Tax Consequences of Revaluation Model Application According to FAS No.16 (revised 2011) Implementation of Revaluation Model 1) Taxpayer applies the letter to tax office for approval 2) Taxpayer does not apply the letter to tax office for approval Tax Consequences Gain on fixed asset revaluation is allowable for tax purpose and is subject to 10% final tax. There are two possibilities in the point of tax view: a) the gain is not allowable and not subject to tax; or b) the gain is allowable and is subject to 10% final tax Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 B. Problem Formulation and Research Objectives Referring to the above introduction, there are three problems that need indepth review and they are: 1) what is the difference between accounting treatment and tax treatment for fixed assets?; 2) what kind of tax impact will arise from the implementation of SFAS 16 (Revised 2011)?; and 3) have Indonesian tax regulations accomodated and anticipated the development of accounting methods through IFRS convergence? Based on the introduction and the problem formulation above, this research is aimed to: 1) identify the difference between accounting treatment and tax treatment for fixed assets after IFRS convergence in Indonesia; and 2) identify IFRS convergence on fixed assets and its tax impact. C. Method Dan Resources This research uses qualitative method. Cooper & Schindler (2008) quoted opinion of Maanen (1979) concerning the definition of qualitative research as the following: “Qualitative research includes an array of interpretive techniques which seek to describe, decode, translate, and otherwise come to terms with the remaining, not the frequency of certain more or less naturally occuring phenomena in the social world”. Further, Cooper & Schindler (2008) said that this qualitative study can be used to collect and analyze data. In this case, since the availability of data and information relevant to IFRS convergence in Indonesia since 2012 and its impact on taxation is very limited, the research approach uses exploratory and descriptive research. In the exploratory research, applied methodology is adopted from Cooper & Schindler (2008). First, concept is more clearly defined and developed; priority is determinded; and then final research design is developed. Then, descriptive research is used for answering and disclosing questions related to 5W and 1H (who, what, when, where, and how) in accordance with research topic. Not all of our discussions include all 5W and 1 H, however, part of them are expected to provide enough explanation on the impact of Convergence of IFRS on tax matters. In accordance with the research method as described above, references that are relevant to fixed assets and used in this study include: 1) IAS 16 issued by IASB (International Accounting Standard Board) for the year 2009, 2) SFASs as of 1 July 2009, 3) SFAS 16 (Revised 2011) & Exposure Draft - SFAS 16 (Revised 2010), 4) Tax regulations including laws, government regulations, MoF Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 regulation/decision, Director General of Taxes (DGT) regulations/decisions, and DGT’s circular letters (relevant to fixed assets); 5) Internet search engine. In order to obtain simple and comprehensive understanding on accounting treatment for fixed asset, the linkage of various accounting references are elaborated and analyzed through diagram as shown in Figure 1. Such a step is required to support the following steps in the form of analyzing and reviewing the difference between accounting treatment and tax treatment. Figure 1 Step to Understand an Accounting Standard Simply and Comprehensively Figure 2 Step to Understand A Tax Treatment Simply and Comprehensively In the next step, as shown in Figure 2, research focuses on tax regulations relevant to fixed asset treatment. If there is no specific tax regulations on the fixed asset, study is perfomed to understand tax treatment based on prevailing tax laws. To get simple and comprehensive understanding, all relevant tax regulations are analyzed and reviewed integratedly. The word “simple” and “comprehensive” are emphasized in this case since tax laws have not regulated specific tax treatment and still need implementative regulations in the form of MoF regulations and or DGT regulations, even DGT’s circular letter. In some occasion, simple and comprehensive understanding is obtained after integrated analysis and review on all relevant tax rules. Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 The following step is to perform comparative analysis, as depicted in Figure 3. This step is to compare simple and comprehensive understanding between accounting treatment and tax treatment. In addtion, this step also covers the analysis/identification of tax impact resulted from IFRS convergence in the issuance of SFAS 16 (Revised 2011). Figure 3 Step to Analyze Comparison between Accounting Treatment and Tax Treatment D. Result and Discussion D.1. Accounting Treatment for Fixed Asset D.1.1. Objective and Scope SFAS 16 (Revised 2011): Fixed Asset supersedes SFAS 16 (Revised 2007): Fixed Asset. Substantially there is no difference in the two SFASs. SFAS 16 (Revised 2011) only adopts IFRS issued as of 1 January 2009. This SFAS is adopted from IAS 16 (Revised 2009): Property, Plant and Equipment. Objective and scope of this SFAS are described in Table 2. Main topics of this SFAS consist of measurment and recognition. Table 1 Objective & Scope of SFAS No. 16 (Revised 2011) Subject matter Objective Scope Description The objective of this SFAS is to prescribe the accounting treatment for fixed assets so that users of the financial statements can discern information about an entity’s investment in its fixed assets and the changes in such investment. This SFAS shall be applied in accounting for fixed asset except when another SFAS requires or permits a different accounting treatment; This SFAS does not apply to mineral rights and mineral reserves such as oil, natural gas and similar non-regenerative resources. However, this Standard applies to fixed assets used to developor maintain the assets relevant to mineral rights and mineral reserves. Other SFAS may require recognition of an item of fixed assets based on an approach different from that in this Standard. For example, SFAS 30: Leases requires an entity to evaluate its recognition of an item of leased fixed assets on the basis of the transfer of risks and rewards. However, in such cases other aspects of the accounting treatment for these assets, including depreciation, are prescribed by this Standard. This SFAS applies to properties that is constructed or developed to be used in the future as Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Table 1 Objective & Scope of SFAS No. 16 (Revised 2011) Subject matter Description investment properties, but does not meet the criteria of investment property’s definition under SFAS 13: Investment Properties. When construction or development is finished, the property is categorized as investment property and an entity shall apply SFAS 13. Investment property being re-developed to be used in the future as investment property as well shall refer to SFAS 13. An entity using the cost model for investment property in accordance with SFAS 13 Investment Property shall use the cost model in this Standard. Source: Paragraph 1-5 SFAS 16 (Revised 2011) (IAI, 2011) and IAS 16 (IASCF, 2009) D.1.2. Key Concept The principal issues in accounting for fixed assets are the recognition of the assets, the determination of their carrying amounts and the depreciation charges and impairment losses to be recognized in relation to them In paragraph 6 SFAS 16 (Revised 2011), fixed assets are defined as tangible items that: (a) are held for use in the production or supply of goods or services, for rental to others, or for administrative purposes; and (b) are expected to be used during more than one period. D.1.3. Accounting Treatment Table 3 describes summary of primary accounting treatment for fixed asset based on SFAS 16 (Revised 2011). The treatment refers to italic and bold paragraphs in the SFAS. Table 3 also describes some other paragraphs in order to make the description more clear. Table 2 Accounting Treatment for Fixed Assets Based on SFAS 16 (Revised 2011) Items Recognition Description The cost of an item of property, plant and equipment shall be recognised as an asset if, and only if: (a) it is probable that future economic benefits associated with the item will flow to the entity; and (b) the cost of the item can be measured reliably [par.7] SFAS 16 (Revised 2011) does not prescribe the unit of measure for recognition, i.e. what constitutes an item of fixed asset. Thus, judgement is required in applying the recognition criteria to an entity’s specific circumstances. It may be appropriate to aggregate individually insignificant items, such as moulds, tools and dies, and to apply the criteria to the aggregate value [par.9]. Measurement at recognition 1) Elements of cost An item of fixed asset that qualifies for recognition as an asset shall be measured at its cost, comprising. a) its purchase price, including import duties and non-refundable purchase taxes, after deducting trade discounts and rebates. b) any costs directly attributable to bringing the asset to the location and condition necessary for it to be capable of operating in the manner intended by management. c) the initial estimate of the costs of dismantling and removing the item and restoring the site on which it is located, the obligation for which an entity incurs either when the item is acquired or as a consequence of having used the item during a particular Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Table 2 Accounting Treatment for Fixed Assets Based on SFAS 16 (Revised 2011) Items Description period for purposes other than to produce inventories during that period [par.1516]. 2) Measurement of a. The cost of an item of fixed asset is the cash price equivalent at the recognition Cost date. If payment is deferred beyond normal credit terms, the difference between the cash price equivalent and the total payment is recognized as interest over the period of credit unless such interest is capitalized in accordance with SFAS 26: Borrowing Cost [par.23]. b. Asset acquired in exchange for a non-monetary asset or assets, or a combination of monetary and non-monetary assets is measured at fair value unless 1) the exchange transaction lacks commercial substance or 2) the fair value of neither the asset received nor the asset given up is reliably measurable [par.24] c. The cost of an item of fixed asset held by a lessee under a finance lease is determined in accordance with SFAS 30 (Revised 2011): Lease [par.27] d. The carrying amount of an item of fixed asset may be reduced by government grants in accordance with SFAS 61: Accounting for Government Grants and Disclosure of Government Assistance [par.28]. Measurement after An entity shall choose either the cost model in paragraph 30 or the revaluation model recognition in paragraph 31 as its accounting policy and shall apply that policy to an entire class of fixed asset [par.29]. 1) Cost Model After recognition as an asset, an item of property, plant and equipment shall be carried at its cost less any accumulated depreciation and any accumulated impairment losses [par.30] 2) Revaluation a. After recognition as an asset, an item of fixed asset whose fair value can be Model measured reliably shall be carried at a revalued amount, being its fair value at the date of the revaluation less any subsequent accumulated depreciation and subsequent accumulated impairment losses. Revaluations shall be made with sufficient regularity to ensure that the carrying amount does not differ materially from that which would be determined using fair value at the end of the reporting period [par.31]. b. If an item of fixed asset is revalued, the entire class of fixed asset to which that asset belongs shall be revalued [par.36]. c. If an asset’s carrying amount is increased as a result of a revaluation, the increase shall be recognized in other comprehensive income and accumulated in equity under the heading of revaluation surplus. However, the increase shall be recognized in profit or loss to the extent that it reverses a revaluation decrease of the same asset previously recognised in profit or loss [par.39]. d. If an asset’s carrying amount is decreased as a result of a revaluation, the decrease shall be recognized in profit or loss. However, the decrease shall be recognized in other comprehensive income to the extent of any credit balance existing in the revaluation surplus in respect of that asset. The decrease recognized in other comprehensive income reduces the amount accumulated in equity under the heading of revaluation surplus [par.40]. e. If an entity changes accounting policy from cost model to revaluation model in fixed asset measurement, the change applies prospectively [par.43] f. If in an entity, there is fixed asset available for sale, accounting treatment for the asset is as follows: 1) the asset is recognized when discontinued operation; 2) the asset is measured at carrying amount or fair value minus selling costs of the asset, whichever is lower; 3) the asset is presented as asset held available for sale if its carrying amoung will be recovered through sales from further usage; and 4) the asset is disclosed in the financial statement in order to evaluate the impact of discontinued operation and disposal of non-current asset [par.45]. Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Table 2 Accounting Treatment for Fixed Assets Based on SFAS 16 (Revised 2011) Items Depreciation Description a. Each part of an item of fixed asset with a cost that is significant in relation to the total cost of the item shall be depreciated separately [par.46]. b. The depreciation charge for each period shall be recognised in profit or loss unless it is included in the carrying amount of another asset [par.51]. c. The depreciable amount of an asset shall be allocated on a systematic basis over its useful life [par.53]. d. The residual value and the useful life of an asset shall be reviewed at least at each financial year-end and, if expectations differ from previous estimates, the change(s) shall be accounted for as a change in an accounting estimate in accordance with SFAS 25 (Revised 2009): Accounting Policies, Changes in Accounting Estimates and Errors [par.54]. e. The depreciation method used shall reflect the pattern in which the asset’s future economic benefits are expected to be consumed by the entity [par.63]. f. The depreciation method applied to an asset shall be reviewed at least at each financial year-end and, if there has been a significant change in the expected pattern of consumption of the future economic benefits embodied in the asset, the method shall be changed to reflect the changed pattern. Such a change shall be accounted for as a change in an accounting estimate in accordance with SFAS 25 (Revised 2009) [par.64]. Impairment To determine whether an item of fixed asset is impaired, an entity applies SFAS 48: Impairment of Assets. That Standard explains how an entity reviews the carrying amount of its assets, how it determines the recoverable amount of an asset, and when it recognises, or reverses the recognition of, an impairment loss [par.66]. Compensation from third parties for items of fixed asset that were impaired, lost or given up shall be included in profit or loss when the compensation becomes receivable [par.67] Derecognition 1. The carrying amount of an item of fixed asset shall be derecognized: (a) on disposal; or (b) when no future economic benefits are expected from its use or disposal [par.69].. 2. The gain or loss arising from the derecognition of an item of fixed asset shall be included in profit or loss when the item is derecognized (unless SFAS 30 requires otherwise on a sale and leaseback). Gains shall not be classified as revenue [par.70]. 3. The gain or loss arising from the derecognition of an item of fixed asset shall be determined as the difference between the net disposal proceeds, if any, and the carrying amount of the item [par.73]. Source: SFAS 16 (Revised 2011) (IAI, 2011) and IAS 16 (IASCF, 2009) D.2. Tax Treatment for Fixed Asset D.2.1. Asset Measurement Base for Tax Purpose Tax rules regulate how to measure transaction of asset in more details. According to Article 10 of Income Tax Law, type of transaction and measurement base of asset is described in Table 4. Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Table 3 Asset Measurement Base for Tax Purpose No Transaction Type 1. Acquisition cost or selling price in an arm’s length transaction referring to Article 18 paragraph (4) of Income Tax Law 2. Acquisition cost or selling price in related Taxpayers referring to Article 18 paragraph (4) of Income Tax Law 3. Acquisition value or selling value in the case of an exchange of assets 4. Acquisition value or transfer value of transferred asset in the case of liquidation, merger, split-up, spin-off, split-off, or taking over of a business a transfer of asset in the form of donation, including a) zakat received by any amil zakat body or amil zakat institution established or legalized by the Government and eligible recipients of zakat or b) compulsory religious donation of followers of religions recognized in Indonesia, received by religious institutions established and legalized by the government and received by eligible recipient of donations with the provision thereof governed by or on the basis of Government Regulation: to the extent that it has no linkage(s) of business, employment, ownership, or possession between related parties; to the extent that it has linkage(s) of business, employment, ownership, or possession between related parties 6. Grant asset received by family by blood in a straight line of descent of one degree and by any religious body, including foundation, cooperative, or individual running micro and small-scale business with the provision thereof ruled by or on the basis of the regulation of Finance Minister: to the extent that it has no linkage(s) of business, employment, ownership, or possession between related parties; to the extent that it has linkage(s) of business, employment, ownership, or possession between related parties 7 Transfer of asset, including cash remittance received by a body taxpayer as substitute to shares or in substitute to capital participation Sumber: adopted from Article 10 of Income Tax Law Measurement Base The amount actually paid or actually received the amount which should have been paid or received the amount which should be paid or received on the basis of the market price the amount which should be paid or received in accordance with the market price except the Minister of Finance otherwise determines 5. the book value in the hands of the transferor or other value determined by the Director General of Taxes the market value of the asset the book value in the hands of the transferor or other value determined by the Director General of Taxes the market value of the asset the market value of the asset Article 10 of Income Tax law also illustrates how to determine acquisition cost when exchange of asset takes place.Table 5 shows the illustration. Suppose PT A and PT B agreed to exchange their assets. PT A owned X asset and PT B owned Y asset. Although there is no payment between the parties concerned, since the market price of the property exchanged is Rp 20,000,000.00, then this amount of Rp 20,000,000.00 will be regarded as the acquisition price which should have been paid or the sale price which should have been received. The difference between the market price and the book value of the property exchanged constitutes profit which is subject to tax. PT A obtained a profit of Rp 10,000,000.00 (Rp 20,000,000.00 – Rp 10,000,000.00) and PT B obtained a profit of Rp 8,000,000.00 (Rp 20,000,000.00 – Rp 12,000,000.00) Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Table 4 Illustration on How to Determine Acquisition Cost in an Asset Exchange for Tax Purpose Uraian Book Value Market Price Margin Source: Article 10 of Income Tax Law PT A’s Asset - X (Rp) 10,000,000 20,000,000 10,000,000 PT B’s Asset - Y (Rp) 12,000,000 20,000,000 8,000,000 D.2.2. Tax Depreciation Depreciation for tax purpose is regulated in Article 11 of Income Tax Law. Table 6 summarizes tax treatment according to the tax rule. The description covers depreciation method and when to start depreciation. Table 5 Methods and When to Start Tax Depreciation No Item 1. Methods Measurement Base 1) Straight Line Method (SLM) Depreciation on expenditure for the purchase, establishment, addition, repair, or change to a tangible asset, except land with the status of ownership right, building benefit right, business benefit right, and use right, owned and used to obtain, claim, and maintain income which has a benefit period of more than one year is calculated in parts of equal sume measure of the benefit period stipulated for the said asset. 2) Doube Declining Balance Method (DDB) Depreciation on expenditure for a tangible asset, other than building, may also be done in descending parts of the useful period, reckoned by applying the depreciation tariff on residual value, and at the end of the useful period the residual value is depreciated all at once, provided that it is done consistently. 3) Other Method Further provision on the depreciation of tangible assets owned by and used in certain business lines, other than SLM and DDB as described above, shall be regulated by a regulation of Finance Minister. 2. Commencement 1) Depreciation shall commence in the month expenditures are incurred. For the of depreciation asset still in progress, the depreciation shall commence in the month when the process is completed. 2) Subject to the approval of the Director General of Taxes, a Taxpayer may start to claim depreciation at the beginning of the month the asset is used to earn, to collect and to secure income or of the month the asset produces income. 3) If a Taxpayer revalues the asset referred to in Article 19 of Income Tax Law, then the basis of depreciation for the asset shall be the value resulting from the revaluation. Source:Article 11 of Income Tax Law D.2.3. Classification of Tangible Assets, Useful Lifes and Depreciation Tariffs To calculate depreciation for tax purpose, useful life and tariff for depreciating tangible asset is stipulated under Article 11 of Income Tax Law (see Table 7). The classification of tangible assets according to their useful life referred to in Article 11 paragraph (6) of Income Tax Law is determined by Finance Minister’s Regulation No. 96/PMK.03/2009 (see Table 8). Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Tabel 6 Classification of Assets, Depreciation Method, and Depreciation Tariff Group of Tangible Assets I. Non-Building Class Group 1 Group 2 Group 3 Group 4 II. Building Class Permanent Non-Permanent Useful Life SLM Depreciation Rate DDB 4 year 8 year 16 year 20 year 25% 12.5% 6.25% 5% 20 year 10 year 5% 10% 12,5% 6.25% 12.5% 10% Source: Article 11 of Income Tax Law Tabel 7 Classification of Tangible Assets, Other than Building, for Tax Depreciation Purpose No Group A. Class 1 1. All business type 2. 3. 4. 5. 6. 7. B. 1. 2. 3. Type of Tangible Assets a. Furniture and tools made from wood or rattan, including tables, benches, chairs, cabinets and the like that are not part of the building. b. Office machines such as typewriters, calculators, duplicators, copiers, accounting / bookkeeping machines, computers, printers, scanners and the like. c. Other equipment such as amplifiers, tape / cassette, video recorders, televisions and the like. d. Motorcycles, bicycles and tricycles. e. Special fittings (tools) for specific industry / service. f. Dies, jigs, and mold. g. Communication tools such as telephone, fax, cell phones and the like Agriculture, The tool not driven by a machine such as hoe, animal husbandry, fisheries, rakes, horticulture, forestry etc. Food and beverage Movable lightweight machine such as manual huller, dehydrator, pallet, and the industry like Tranportation & Taxi car, bus, truck used for public transportation. Warehouse Semi-conductor Falsh memory tester, writer machine, biporar test system, elimination (PE8-1), industry pose checker. Mooring equipment Anchor, Anchor Chains, Polyester Rope, Steel Buoys, Steel Wire Ropes, rental Mooring Accessories. Cellular Base Station Controller telecommunication industry Group 2 All business type a. Furniture and equipment made from metal, including tables, benches, chairs, cabinets and the like that are not a part of the building. Air regulating device such as air conditioning, fans and the like. b. Car, bus, truck, boat speed and the like. c. Container and the like. Agriculture, a. Agricultural machinery / farm machinery such as tractors and plows, rakes, horticulture, planting tool, seed spreader, and the like. forestry, fisheries b. Machines that process or produce or manufacture materials or goods for agriculture, plantation, animal husbandry and fisheries. Food and beverage a. Machines processesing products from animal, poultry and fisheries, for industry example dairy plants, fish canning. b. Machines processesing products from vegetable, such as palm oil machine, 12 Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Tabel 7 Classification of Tangible Assets, Other than Building, for Tax Depreciation Purpose No Group Type of Tangible Assets margarine machine, coffee milling, confectionery, grain processing machinery (such as rice, wheat, tapioca). c. Machines producing/manufacturing beverages and all kinds of beverage materials. d. Machines producing/manufacturing foodstuffs and all kinds of food. 4. Machine industry Machines producing / manufacturing light machines (eg sewing machine, water pump). 5. Timber, forestry a. Logging Machines and equipments. b. Machines processing or producing or manufacturing forestry materials or goods. 6. Construction Equipments such as heavy truck, dump truck, crane buldozer and the like. 7. Transportation and a. Work trucks for transportation and unloading, platform trucks, and the like; Warehouse b. Passenger ships, cargo ships, special vessels for transporting specific goods (e.g. wheat, stones, mining ore, etc.) including air boats, tankers, fishing vessels and the like, whose weight is up to 100 DWT; c. Ship made specifically to drag or push boats flares, fire boats, dredgers, floating faucet and the like whose weight is up to 100 DWT; d. Sailboats without motors whose weight is up to 250 DWT; e. Balloon Ships. 8. Telecommunication a. Telephone equipments; b. Telegraph including telegraph radio and telephone radio. 9. Semi-conductor Auto frame loader, automatic logic handler, baking oven, ball shear tester, industry bipolar test handler (automatic), cleaning machine, coating machine, curing oven, cutting press, dambar cut machine, dicer, die bonder, die shear test, dynamic burn-in system oven, dynamic test handler, eliminator (PGE-01), full automatic handler, full automatic mark, hand maker, individual mark, inserter remover machine, laser marker (FUM A-01), logic test system, marker (mark), memory test system, molding, mounter, MPS automatic, MPS manual, O/S tester manual, pass oven, pose checker, re-form machine, SMD stocker, taping machine, tiebar cut press, trimming/forming machine, wire bonder, wire pull tester. 10. Mooring equipment Spoolling Machines, Metocean Data Collector rental 11. Cellular Mobile Switching Center, Home Location Register, Visitor Location Register. telecommunication Authentication Centre, Equipment Identity Register, Intelligent Network Service Control Point, intelligent Network Service Managemen Point, Radio Base Station, Transceiver Unit, Terminal SDH/Mini Link, Antenna C. Group 3 1. Mining other than Machines used in the mining sector, including machinery processing pelicans oil and gas products. 2. Spinning, weaving a. Machines processing / producing textile products (e.g. cotton, silk, artificial and dyeing fibers, wool and other animal hair, flax, hemp rugs, fur fabrics, tulle). b. Machines for preparation, bleaching, dyeing, printing, finishing, texturing, packaging and the like. 3. Timber a. Machines processing / producing wood products, goods from straw, grass and other woven materials. b. Machinery and sawmill equipment. 4. Chemical industry a. Machinery that processes/produces chemical products and product related to the chemical industry (e.g. inorganic chemicals, organic and inorganic compounds and precious metals, radioactive elements, isotopes, organic chemicals, pharmaceutical products, fertilizers, dyes, drugs dyes, paints, varnishes, etheric oils and resinoids-resinonida perfumes, medicines and medical beauty makeup, soap, detergents and other cleaning organic materials, substances albumina, adhesives, explosives, pirotehnik products, Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Tabel 7 Classification of Tangible Assets, Other than Building, for Tax Depreciation Purpose No Group Type of Tangible Assets lighters, alloy piroforis, photographic goods and cinematography. b. Machines that process/produce other industrial products (e.g.: artificial resins, plastic materials, esters and ethers of cellulose, synthetic rubber, artificial rubber, leather, hides, and skins). 5. Machinery industry Machines that produce / manufacture medium and heavy machinery (eg automobile engines, ship engines). 6. Transportation and a. Passenger ships, cargo ships, special vessels for the transport of certain goods warehousing (eg wheat, rocks, ore, and the like) including air ships and tankers, fishing vessels and the like, which have a weight of over 100 DWT to 1000 DWT. b. Ships intended for mengela or pushing boats, flares, fire boats, dredgers, floating faucet and the like, which has a weight above 100 DWT up to 1,000 DWT. c. Floating docks. d. Sailboat with no motor use or weigh over 250 DWT. e. Airplanes and helicopters of all types. 7. Telecommunication radio navigation device, radar and remote control. D. Group 4 1. Construction Heavy equipment for construction 2. Transportation and a. Steam locomotive and tender on the tracks. warehousing b. Electric locomotive on rails, run by batteries or electrical power from an outside source. c. Locomotive on the other rail. d. Train, carriage of passengers and goods, including containers specially made and equipped for towing with a tool or some means of transportation. e. Passenger ships, cargo ships, special vessels for the transport of certain goods (eg wheat, rocks, ore, and the like) including air ships and tankers, fishing vessels and the like, which have a weight of over 1,000 DWT. f. Ship made specifically to drag or push boats, flares, fire boats, dredgers, floating taps and so on, which have a weight of over 1,000 DWT. g. Floating docks. Source: Minister of Finance (MoF) Regulation No. 96/PMK.03/2009 In association with other types of tangible property, other than building not listed in Table 8, for the purpose of fiscal depreciation, useful life used in Group 3 (16 years) applies. This rule is stipulated in Article 2 MoF Regulation No. 96/PMK.03/2009. However, taxpayers may obtain useful life determination of tangible property (other than building) based on the actual useful life. To obtain such determination, they have to submit an application to the Director General of Taxation by showing the actual useful life of tangible property. If the application is denied, the taxpayers still use 16-year useful life in accordance with Group 3 in Table 8. D.2.4. Fixed Asset Revaluation for Tax Purpose The provisions on revaluation of fixed assets for tax purposes is regulated in the Income Tax Law (Article 4 paragraph (1) point m, Article 11 paragraph (5), and Article 19). Its technical provisions refer to MoF Regulation No. 79/PMK.03/2008 and Director General of Taxation (DGT) Regulation No. Per-12/PJ/2009. Table 9 outlines a summary of taxation aspects for the fixed asset revaluation. Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Tabel 8 Summary of Taxation Aspects for Fixed Asset Revaluation No Item 1. Subject 2. 3. 4. 5. 6. Description Companies that can revalue fixed assets for tax purposes are a) domestic corporate taxpayer, and b) a permanent establishment (BUT), excluding the company obtained permission to keep books in English and in U.S. Dollars, with the conditions that all its tax obligations is fulfilled until the last tax period prior to the period in which fixed asset revaluation is executed. Procedure 1) The company files an application to the Director General of Taxation 2) The Director General of Taxes is authorized to issue a decree regarding fixed asset revaluation of which the company files the application. 3) Revaluation of fixed assets is carried out on: a) all tangible fixed assets, including land with ownership status or the right to build, or b) all tangible fixed assets, excluding land, which is situated in Indonesia, owned, and used to obtain, collect, and maintain taxable income. 4) Revaluation of fixed assets can not be returned within the period of 5 (five) years since the revaluation of fixed assets last performed under MoF Regulation No. 79/PMK.03/2008. Revaluation Base 1) Revaluation of fixed assets should be based on market value or fair value of fixed assets that is in force at the time of revaluation of fixed assets are determined by the registered/official appraiser. 2) In case that market value or fair value determined by the registered appraiser does not reflect the real situation, the Director General of Taxes is authorized to redetermine the market value or the fair value of the related assets. 3) Revaluation of fixed assets is made within a maximum period of 1 (one) year from the date of this report or the appraisal company expert appraiser. Tax on Gain on 1) The excess of the revaluation of fixed assets in the company's fiscal book Fixed Asset value of the original is subject to final income tax of 10% (ten percent). Revaluation 2) The company, whose financial condition does not allow it to pay off the income tax payable, may submit a request for payment by installments with maximum of 12 (twelve) months in accordance with Article 9, paragraph (4) of Law No. 36 year 2007. Tax Base for 1) After the month in which the revaluation of fixed assets is made, the Depreciation after following conditions apply: Fixed Asset a) Tax base for depreciation of fixed assets is the value at the time of the Revaluation revaluation; b) The useful life of fixed assets for tax purpose is adjusted back into the full useful life of fixed assets for the group; c) Calculation of depreciation begins in the month in which the fixe asset revaluation is made. 2) For the fiscal year before the month in which the fixed asset revaluation is made, the following provisions apply: a) Tax base for depreciation of fixed assets refers to the value at the beginning of the fiscal year. b) The remaining useful life of fixed asset is the remaining useful life at the beginning of the fiscal year. c) Depreciation is calculated using prorate basis according to the number of months in the fiscal year. 3) Depreciation of fixed assets, of which the revaluation is not approved by DGT, still uses the original tax base and residual useful life before the revaluation of fixed assets is made. Tax on assets 1) Transfer (sales) on fixed assets a) assets in group one or two that have been aproved to be revalued before transfer (sales) its useful life expired as stated in article 7 versus (1) b Ministrial decree after No. 79/PMK.03/2008; or revaluation. b) fixed assets in group 3 and 4, building and land that have been approved to be revalued before 10 years Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 Tabel 8 Summary of Taxation Aspects for Fixed Asset Revaluation No Item Description Capital gain from the transfer is taxable and the rate is the highest corporate tax rate in the time of revaluation minus 10%. These two a and b principles do not apply for transfer due to force majeur, combination, merger or expansion that has been aproved by Minister of Finance and assets widrawl from its normal usage. The difference between transfer prices with book valeu is considered to be gain or loss according to Indonesian tax regulation. 7. Tax on conversion 1) after tax capital gain is recorded as equity of capital gain to 2) bonus stock based on capital gain is not taxable, bonus stock. 3) however, for capital gain comes from excess comercial value is taxable. Source: UU PPh (Pasal 4 ayat (1) huruf m, Pasal 11 ayat (5), dan Pasal 19) jo. PerMenkeu No. 79/PMK.03/2008 dan PerDirjen Pajak No. Per-12/PJ/2009 Revaluation of fixed assets for tax purpose is under Income Tax Act, article 4, verses 1, number m, article 11, verses 5 and article 19. Technically, this revaluation is under MOF decree number 79/PMK.03/2008 and Circular of DGT No. Per-12/PJ/2009. D.3. Summary The Influence of IFRS Convergence for Fixed Assets on Income Tax Based on PSAK 16 (Revised 2011) and Tax Regulation as Stated in Table 9.. Rangkuman Pada Table 10 Contains Asset Measurement, Depreciation, and Fixed Asset Classification. Table 9. Summary The Different between Recognition of Fixed Assets for Accounting and Tax Purpose No Items 1. Recognition Accounting Taxation Fixed asset is recognised if it Fixed asset is recognised if it has potential has potential future future economics benefit and this benefit is economics benefit and this reasonably measurable. This asset must be in the benefit is reasonably list of asset under MOF decree No. measurable. 96/PMK.03/2009 2. Measurement Initial measurement of assets Initial recognition of assets based on costs. based on costs. The following asset valuation Measurement based on cost method. may be based on cost or fair Measurement based on fair value must be value. approved by DGT. Fair value method requires asset is measured based on market value. Thus the value may be more or less than historical cost. 3 Depreciation No specific method (various Depreciation and useful life are ruled under method allowed) article no. 11 Income Tax Act. Useful life based on Depreciation is only applied on assets used for management decision and it aquiring, maintaining and collecting income. may change. No residual value allowed. Residual value is allowed. 3. Asset Decreasing asset value is Impairment asset value is not allowed. impairment allowed Source: PSAK 16 (Revisi 2011) (IAI, 2011) dan Pasal 11 UU PPh Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 As presented in Table 10, IFRS convergence PSAK 16 (statetement of financial accounting standard(Revisi 2011) has a substatial influence on taxation when management choose to use fair value method. As stated before, adoption fair value method must have an approval from DGT. However, if adoption of fair value method is not reported to the DGT, the question is whether capital gain is taxable? This issue creates controversion among managements/tax payers, consultant and tax officers. Tax officers contend that this capital gain is taxable, however management of firms generally have opposite opinion. According to MOF decree 79/PMK.03/2008 capital gain resulted from revaluation of fixed assets that is not reported to the DGT is not taxable. tentang penilaian kembali aktiva An other important issue is the diference on depreciable value, thus depreciation costs. Tax rule uses costs as basis for depreciation, on the other hand accounting method that adopts fair value, periodically adjust the value of fixed assets. Up to this time, no regulation which overcome this gap or difference. E. Conclusion In conclusion, upon convergence to IFRS, assets may be recorded based on costs or fair value (value based on revaluation). Cost method is consistent with current tax regulation, however when firm choose fair value in asset valuation, the capital gain resulted from the valuation is taxable. In this case firm should ask permission to the Directorat General of Taxation. Thus, there is no problem when assets are recorded based on costs, however, when assets are recorded based on fair value (revaluation) and firms do not report the valuation of assets to the DGT, two possibilities may imposed to the matter. First, asset valuation is not recognized fiscally (according to tax rule) and therefore the capital gain is not taxable. Second, asset valuation is recognized fiscally, consequently the capital gain resulted from the revaluation is taxable. Scrutinizing tax rule eg. Income Tax Act, article 4, veses 1, number m and article 19 and MOF decree No. 79/PMK.03/2008, the second possibility can be avoided because the act and the decree madate revaluation assets for tax purpose must be reported and approved by the DGT. Refferences Cooper, D.R. & Schindler, P.S. Business Research Method. 10th Edition. International Edition. McGraw Hill Companies Inc. New York. 2008. Ikatan Akuntan Indonesia. Standar Akuntansi Keuangan Per 1 Juli 2009. Penerbit Salemba Empat. Jakarta. 2009. Ikatan Akuntan Indonesia. Undangan Menyusun Kajian atas Topik-Topik Akuntansi Terkini Dalam Rangka Konvergensi IFRS 2012. http://www.iaiglobal.or.id/berita/detail.php?catid=1&id=123. Diakses tanggal 13 Februari 2010. Ikatan Akuntan Indonesia. PSAK No. 16 (Revisi 2011): Aset Tetap. IAI. Jakarta. Proceedings of 23rd International Business Research Conference 18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8 2011. International Accounting Standards Board. International Financial Reporting Standards (as issued at 1 January 2009). International Accounting Standards Committee Foundation (IASCF). London. 2009. Peraturan Menteri Keuangan Nomor 79/PMK.03/2008 tentang Penilaian Kembali Aktiva Tetap Perusahaan Untuk Tujuan Perpajakan. Ditetapkan pada Tanggal 23 Mei 2008. Jakarta. Peraturan Menteri Keuangan Nomor 96/PMK.03/2009 tentang Jenis-Jenis Harta yang Termasuk dalam Kelompok Harta Berwujud Bukan Bangunan untuk Keperluan Penyusutan. Ditetapkan pada Tanggal 15 Mei 2009. Jakarta. Undang-undang Nomor 28 Tahun 2007 tentang Perubahan Ketiga atas Undang-undang Nomor 6 Tahun 1983 tentang Ketentuan Umum dan Tata Cara Perpajakan. Disahkan pada Tanggal 17 Juli 2007. Jakarta. Undang-undang Nomor 36 Tahun 2008 tentang Perubahan Keempat atas Undang-undang Nomor 7 Tahun 1983 tentang Pajak Penghasilan. Disahkan pada Tanggal 23 September 2008. Jakarta.