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Dataline A look at current financial reporting issues - PwC

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lessee. Clearly both parties are entering into the lease with an expect<strong>at</strong>ion of<br />

payments being made, so should some amount of the contingent payment be<br />

considered an "in-substance" fixed lease payment? If so, wh<strong>at</strong> amount? Some factors<br />

to consider may be whether this arrangement is consistent with usual business terms<br />

offered by the lessor, whether a minimum level of sales or output is required under<br />

the contract, how the arrangement terms compare with standard industry practice,<br />

and why the contract pricing terms have been structured in this manner. It is not<br />

clear whether this issue will be addressed in the revised ED or will be discussed as<br />

part of redeliber<strong>at</strong>ions th<strong>at</strong> take place after comments are received on the revised ED.<br />

.46 "Term option penalties" would be included or excluded in the measurement of lease<br />

assets and lease liabilities in a manner th<strong>at</strong> is consistent with the accounting for options<br />

to extend or termin<strong>at</strong>e a lease. For example, if a lessee would be required to pay a<br />

termin<strong>at</strong>ion penalty if it does not renew the lease and the renewal period is excluded<br />

from the lease term, then th<strong>at</strong> penalty should be included in the recognized lease<br />

payments.<br />

.47 Variable lease payments will require reassessment as r<strong>at</strong>es and indices change, which<br />

may be as often as each <strong>reporting</strong> period. Reassessing lease payments based on a r<strong>at</strong>e or<br />

index will require lessees to re-measure their right-of-use asset and lease oblig<strong>at</strong>ion each<br />

time r<strong>at</strong>es and indices change. Lessees would account for this change in the income<br />

st<strong>at</strong>ement when it rel<strong>at</strong>es to a past or <strong>current</strong> accounting period and as an adjustment to<br />

the right-of-use asset when it rel<strong>at</strong>es to a future period. Lessors would account for all<br />

changes in the right to receive lease payments due to changes in a r<strong>at</strong>e or an index<br />

immedi<strong>at</strong>ely in the income st<strong>at</strong>ement.<br />

<strong>PwC</strong> observ<strong>at</strong>ion:<br />

The requirement for lessors to immedi<strong>at</strong>ely account for in the income st<strong>at</strong>ement all<br />

changes in the right to receive lease payments due to movements in a r<strong>at</strong>e or an index<br />

represents a significant change from the <strong>current</strong> models — irrespective of whether the<br />

lessor is using an approach similar to existing oper<strong>at</strong>ing lease accounting or the<br />

receivable and residual approach. For example, in a 20-year real est<strong>at</strong>e lease with<br />

rents th<strong>at</strong> increase with changes in the Consumer Price Index annually over the base<br />

year, a change in the index after year 1 impacts years 2-20 and the present value of<br />

the differential hits the income st<strong>at</strong>ement in one lump sum. This is not symmetrical<br />

to lessee accounting and could result in significant vol<strong>at</strong>ility in, and front loading of,<br />

earnings rel<strong>at</strong>ive to the contract rents.<br />

Definition of a lease<br />

.48 The initial ED carried forward the definition of a lease in existing guidance, subject to<br />

some rel<strong>at</strong>ively minor amendments. Perhaps the most surprising issue to the boards th<strong>at</strong><br />

came out of the comment letters was the level of concern raised about carrying this<br />

forward into the proposals and the extent of applic<strong>at</strong>ion <strong>issues</strong> in applying the <strong>current</strong><br />

lease definition th<strong>at</strong> respondents identified.<br />

.49 The boards acknowledged during redeliber<strong>at</strong>ions th<strong>at</strong> there may be many more<br />

multiple-element arrangements th<strong>at</strong> contain an embedded lease than originally expected,<br />

which could have substantially increased the complexity and cost of applying the initial<br />

ED. Some common agreements th<strong>at</strong> may contain an embedded lease are:<br />

N<strong>at</strong>ional Professional Services Group | CFOdirect Network – www.cfodirect.pwc.com <strong>D<strong>at</strong>aline</strong> 18

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