deferred tax liabilities

advertisement

CHAPTER 15

International taxation

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Contents

Introduction – Main types of taxation

Corporate income tax and dividends

Deferred taxation

International taxation

Transfer pricing

Tax havens

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Main types of taxation

Taxation as costs

Social security charges

Local/regional taxes

National corporate income taxes

Taxation on behalf of a third party

Value added tax

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Value added tax

Imposed on customers at each stage of a product’s value-added chain, based on the value added at that point

Gross amount of VAT on sales and on purchases is netted in the accounting system and net amount is paid periodically to the tax authorities

Not part of revenue or expenses, but included in receivables and payables (cash flow effect)

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Corporate income tax

Income tax payable = Taxable profit * Tax rate (f.i. 30%)

Taxable profit is not equal to accounting profit

Differences?

Some expenses are not allowed tax-wise

(entertaining, fines, excess depreciation, excess provisions, etc.)

Special tax allowances (for capital investment, environmental protection, etc.)

Income that is non-taxable

Deferred taxes arise from these differences

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Taxable profit

Reconciliation statement:

Accounting profit before tax

Add back: disallowed expenses

Deduct: special tax allowances and nontaxable income

= Taxable profit

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Taxation of dividends

Problem of potential double taxation of dividends due to concurrent corporate and personal taxation

Solutions:

Profits paid to shareholders are taxed at a lower rate than those retained in the company, or

Tax credit on the dividend for shareholders

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Deferred taxation

Deferred taxes

Income statement perspective on deferred taxes

Balance sheet perspective on deferred taxes

Presentation of deferred taxes in the financial statements

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Deferred taxes

Differences between objectives of measuring

(accounting) profit for financial reporting purposes and basic tax raising motives of measuring taxable profit

Accounting rules regarding income taxes:

Tax effects of transactions are recognised in the financial statements in the same period as the related business transactions themselves

Current income tax cost ( taxable profit * nominal tax rate ) is only part of these tax effects

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Deferred taxes (cont.)

Income statement:

(or benefit) complements cost deferred tax cost current tax

Balance sheet: and deferred tax assets deferred tax liabilities reflect future tax consequences of transactions that were not treated identically for taxation and financial reporting purposes

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Income statement perspective on deferred taxes

Cfr. Reconciliation statement - two types of differences:

Permanent differences

Timing differences

Timing differences arise because the timing of income and expenses in the income statement occurs in different period from taxable profit

Timing differences arise in one period and reverse in one or more subsequent periods

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration – Tax deductible accelerated depreciation

Purchase of a fixed asset (€10,000) with tax incentive (accelerated depreciation) in 20X1

Useful life = 2 years and no residual value

Depreciation

Financial statements: 5,000 in 20X1 and in 20X2

Tax calculation: 10,000 in 20X1 and 0 in 20X2

Pre-tax profit of 20,000 in 20X1 and 20X2 and tax rate of 50 per cent

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration – Income tax calculation

20X1

20,000

20X2

20,000 Pre-tax profit

(includes depreciation expense)

Timing difference

(accelerated depreciation)

Taxable profit

Tax due at 50%

- 5,000 + 5,000

15,000 25,000

7,500 12,500

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration – Income statement effect without deferred taxes

Pre-tax profit

Corporate income taxes due

Net profit after tax

20X1

20,000

20X2

20,000

- 7,500 - 12,500

12,500 7,500

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration – Income statement effect including deferred taxes

Pre-tax profit

20X1

20,000

20X2

20,000

Total tax expense:

°Taxes due

°Deferred tax expense

°Deferred tax income

Net profit after tax

-

-

7,500

2,500

-

12,500

+2,500

10,000 10,000

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration – Deferred taxes on the balance sheet

Deferred tax expense => Deferred tax liability

Indicates that profit in the financial statements has in the past been higher than for tax purposes

Liability: reflects future taxation on the difference

– postponement of tax payments to future periods

At reversal of timing difference:

Deferred tax income in income statement

Settlement of deferred tax liability

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Alternative illustration – Provision not accepted for tax purposes

Deferred tax income => Deferred tax asset

Indicates that profit in the financial statements has in the past been lower than for tax purposes

Asset: reflects future tax savings on the difference

– taxes paid, but recoverable in future periods

At reversal of timing difference:

Deferred tax expense in income statement

Use of deferred tax asset

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Balance sheet perspective on deferred taxes

Deferred taxation based on balance sheet values

‘ Temporary differences and liabilities

’: differences between balance sheet values and tax values of assets

Tax value (tax base) = the amount at which the asset or liability is recognised for tax purposes

Temporary differences are broader than timing differences

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

IAS 12

Income taxes

Two types of temporary differences:

Taxable differences that result in deferred tax liabilities – taxable amounts in determining taxable profit of future periods

Deductible differences that result in deferred tax assets – amounts that are deductible in determining taxable profit in future periods

Deferred tax asset / liability is measured as the temporary difference multiplied by the tax rate (applicable when asset is realised or liability is settled)

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration - Tax deductible accelerated depreciation (repeat)

20X1 20X2

(a) Accounting balances

Asset carrying amount 1 January

Additions

Accounting depreciation

Asset carrying amount 31 December

(b) Tax values

Asset tax base 1 January

Additions

Tax depreciation

Asset tax base 31 December

(c) Temporary differences

0

10,000

-5,000

5,000

0

10,000

-10,000

0

5,000

5,000

0

-5,000

0

0

0

0

0

0

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Illustration - Tax deductible accelerated depreciation

 Temporary difference of 5,000 in 20X1

 Taxable or Deductible ?

Tax base of asset < Book value of asset

Future accounting depreciation will be higher than tax depreciation

Future taxes due will be higher than expected on accounting profit

=> Taxable temporary difference

Deferred tax liability of 2,500 (50 per cent tax rate)

Deferred tax expense of 2,500

 Reversal in 20X2

 Settlement of deferred tax liability

 Deferred tax income of 2,500

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Presentation of deferred taxes in financial statements

Separate presentation of deferred tax assets

(liabilities) in balance sheet

Classified as non-current balance sheet items

Tax expense (income) related to ordinary activities presented on the face of the income statement

Additional disclosures in the notes:

Details on major components of tax expense

Numerical explanation of relationship between tax expense and accounting profit

Details on temporary differences and related deferred tax assets and liabilities

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

International taxation

Taxation is administered on a company-bycompany basis and calculated on individual subsidiaries’ accounts

International taxation presents both threats and opportunities

Structuring of international transactions in the most tax efficient way

Avoiding double taxation (double tax treaties)

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Transfer pricing

Transfer prices are the prices at which goods and services change hands between subsidiaries of a group

Artificially fixing transfer prices is a way of determining where profits are taxed

Double tax treaties usually state that transfer prices must be “at arms’ length” or at market rates

Intra-group charges (like royalties for use of intellectual property and interest charges) are also usually structured according to a tax treaty

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Tax havens

Tax havens typically offer low tax or flat rate tax for companies which are resident but whose activities are external to the haven

(‘off-shore’)

Frequently used by a MNC to provide international services (like finance, insurance) to the group

Do not generally benefit from tax treaties with other countries

Costs are not negligible and substantial throughout is needed to create tax savings

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Offshore financial centres

Near relatives of a tax haven, but benefit from double tax treaties with major trading countries

The corporate tax they levy is sufficiently high for developed countries not to treat them as a tax haven, but sufficiently low so as still to be attractive to companies

Use with Global Financial Accounting and Reporting ISBN 1-84480-265-5

© 2005 Peter Walton and Walter Aerts

Download