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International Journal of Business and Management Invention
ISSN (Online): 2319 – 8028, ISSN (Print): 2319 – 801X
www.ijbmi.org Volume 3 Issue 2ǁ February. 2014ǁ PP.10-17
www.ijbmi.org 10 | Page
COMPARATIVE ANALYSIS-- A STUDY OF ACCOUNTING
STANDARDS ON INTANGIBLE ASSETS OF FIVE
COUNTRIES
1,
Manpreet Sharma , 2,
Neha
1,
Assistant Professor Department of Commerce Shri Ram College of Commerce
Delhi University
2,
Research Scholar Department of Commerce Delhi School of Economics University of Delhi
Delhi-110007
ABSTRACT: The aim of this study is to prepare the comparative analysis of standards of five different
countries on Intangible assets namely FRS-10(United Kingdom), AASB-138(Australia), FAS-142 (United States
of America), AS-26 (India) and IAS-38 (International). The analysis has been done broadly on the following
basis – accounting treatment of different types of goodwill, internally generated goodwill, internally generated
intangible assets, how to subsequently recognize the intangible assets (amortization method, amortization
period) and how to treat impairment loss.After each topic a comparative table has been prepared to have a
quick view of differences between the standards. This difference analysis has helped in ascertaining the degree
of harmonization of standards under discussion with respect to IAS-38 the international standard.
KEY WORDS: AASB- 138, AS-26, FAS-142, FRS-10, IAS-38, Intangible Assets.
I. INTRODUCTION
An asset is an economic resource tangible or intangible that is being owned by an individual, company
or country with the expectation of future benefits. The monetary value of the owned assets is depicted by the
balance sheet of the firm. Two major classes of assets are tangible assets and intangible assets. Tangible assets
include current assets (inventory, cash) and fixed assets (buildings). Intangible assets are non-physical resources
and rights that have a value to the firm and give an additive advantage to the firm. Examples of Intangible
Assets are patents, copyrights, goodwill, trademarks, human capital and computer programs. These Intangible
Assets are rapidly capturing the center stage.
The presence of Intangible Assets can be traced even to the Stone Age. The invention of fire by
rubbing two stones is an apt example. This invention could have been patented if laws of patent would have
been there at that time. All this shows that the presence of Intangible Assets is not new rather it is the awareness
and development of laws that has increased over time. In today’s competitive world, Intangible Assets play an
imperative role for the business in having competitive edge. They have become an indispensable part of the
Balance sheet of the company’s these days.Research (Nakamura, 2003) indicated that the annual US
investment in Intangibles was almost equal ($ 1 trillion) to the total investment of the manufacturing sector in
physical assets. This data points out that they have become an indispensable part of the balance sheet of the
company’s in today’s world.
The revolution from industrial economy to the current knowledge economy started and demanded
incessant innovation, buyer centricity and eminent customer services. This required companies to invest more
and more in operative activities, brand building, strong customer relationship building and workforce training
instead of execution assets. Besides, investment in intangibles which enables firms to innovate generated returns
extensively elevated in comparison to the cost of capital and returns on fixed assets investments. All this arise
the need of proper accounting and disclosure of intangible assets. The increasing importance and share of
intangible assets in the balance sheet has increased the need of accurate accounting and disclosure of Intangible
assets. Every country especially those with major amount of Intangible Assets have issued accounting standards
for the accounting and disclosure of these assets on the basis of their economic and accounting environment. In
India, accounting and disclosure of intangible assets is taken care by Accounting Standard -26. In United
States of America, it is Financial Accounting Standard-142 which takes care about this issue. In Australia, it
is Financial Reporting Standard-10 which is issued for the treatment of Intangible Assets. The international
accounting body- International Accounting Standard Board issued International AccountingStandard-38
for Intangible assets. At the international level World Intellectual Property Organization (WIPO) was
Comparative Analysis A Study Of Accounting Standards…
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established in 1967 to administer intellectual property rights. All the members of WIPO are required to bring
their intellectual property laws in compliance with WIPO laws. Also at the international level Agreement on
Trade Related IntellectualProperty Rights (TRIPS) was included in the Act of the Uruguay Round to give
more importance to intellectual property rights.
II. RATIONAL OF THE PAPER
This paper tries to bring out the difference between the standards under discussion (FRS-10(United
Kingdom), AASB-138(Australia), FAS-142 (United States of America), AS-26 (India) and IAS-38
(International) majorly on the basis of the following points:-
1) Goodwill Treatment
a. Positive Goodwill
b. Negative Goodwill
c. Internally Generated Goodwill
2) Internally generated assets
a. Research Cost
b. Development Cost
3) Amortization Period
4) Amortization Method
5) Impairment Loss
III. DEFINING ACCOUNTING STANDARD
Accounting standard is a statement that provides guidelines for preparing standardized financial
statements by a firm. It provides rules of accounting and disclosure of incomes, expenses, assets and liabilities
in financial statements. It helps in comparing financial statements of different companies as it brings uniformity
in preparing financial statements.In the field of accounting, the group of widely accepted accounting standards is
known as GAAP (Generally Accepted Accounting principle).
IV. COMPARATIVE ANALYSIS
Goodwill Treatment
There are different types of goodwill. Acquired goodwill is the goodwill generated due to acquisition. It can be
positive (acquired price>net value of the assets) or negative (acquired price< net value of the assets). Internally
generated goodwill is the goodwill generated by the business on its own. It is the excess of the market value of
the business over the book value of the business. Accounting treatment of each type of goodwill is different
from each other and from standard to standard. The accounting treatment of each type of goodwill is discussed
below on the basis of five standards under discussion.
Positive Goodwill
 FRS-10 – According to this standard positive goodwill is to be capitalized and classified as an asset in the
balance sheet. This standard has specified 20 years for which the goodwill is regarded as having a limited
useful economic life. Beyond 20 years, goodwill is considered as having infinite life. Goodwill with limited
life (not more than 20 years) is to be amortized on a systematic basis (depicting expected pattern of
depletion) over its useful life. Also, standard has given conditions for impairment. Goodwill with life up to
20 years along with amortization should also be tested for impairment at the end of the first financial year
and later only when the circumstances indicates that carrying value may not be recoverable. Goodwill with
infinite life (more than 20 years) should not be amortized but only be tested for impairment at the end of
each reporting period.
 FAS-142 – Goodwill is to be capitalized and presented as a separate item in the statement of financial
position. This standard has not divided the goodwill on the basis of useful economic life for subsequent
recognition. According to this standard, goodwill is not to be amortized. It should be tested annually (after
every reporting period) for impairment and be tested between annual tests depending on circumstances.
 IAS-38 – Under this standard, goodwill is to be capitalized and shown on the asset side of the balance sheet
as a separate item. This standard has also classified goodwill in two categories- one with limited useful
economic life and one with infinite useful life. Goodwill with limited useful life is to be amortized on a
systematic basis (reflecting the expected future economic benefits) over its useful life. The standard has
specified that straight line method should be adopted unless it can be justified that other method is better
Comparative Analysis A Study Of Accounting Standards…
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than this method. The goodwill with infinite useful life is required to be tested for impairment according to
IAS-36 “Impairment of Assets” annually or when there are indications.
 AS-26 – Goodwill is to be capitalized and shown as an asset in the balance sheet. Under this standard,
goodwill is to be tested for impairment annually with an exception of goodwill arising due to
amalgamation. This goodwill is to be amortized over 3-5 years (AS-14, Accounting for Amalgamation).
 AASB-138– This standard does not cover accounting treatment for the purchased goodwill. The treatment
is given by AASB-1013 “Accounting for Goodwill”. According to AASB-138, at the time of acquisition
the positive goodwill is required to be recognized as a non-current asset. For subsequent recognition,
goodwill is required to be amortized. The useful life of the goodwill shall not exceed twenty years from the
date of acquisition.
The table depicting difference in accounting treatment of positive goodwill between the five under discussion
standards is shown by table 1:
Table 1: Accounting Treatment of Positive Goodwill
Accounting Standard Amortization Impairment
FRS-10
Amortized if useful life is up to 20
years
Tested for impairment if useful life
is more than 20 years.
FAS-142 Not amortized
Only to be tested for impairment
annually and in-between the year if
required.
IAS-38 Amortized when useful life is finite.
Tested for impairment when useful
life is infinite annually or when
there are indications.
AS-26
Not to be amortized with the
exception of goodwill arising in
amalgamation in which case is to be
amortized in 3-5 years.
To be tested for impairment
annually or when required.
AASB-138* Amortized
Also to be tested for impairment at
each reporting date.
* Does not cover accounting treatment for the purchased goodwill. It is provided by AASB-1013
Negative Goodwill
 FRS-10 – It is to be recognized and disclosed in the balance sheet immediately below the goodwill heading.
At the end, the net amount of positive and negative goodwill/ is shown. If there is no positive goodwill
present in the balance sheet then negative goodwill is to be shown on the liability side of the balance sheet.
Negative goodwill which is up to the fair value of the non-monetary assets acquired should be credited in
the profit and loss account in the recovery period of those assets whether the recovery is through
depreciation or sale. Negative goodwill in excess of this fair value of the non-monetary assets should be
credited in the profit and loss account up to the expected period of its benefit.
 FAS-142 – Under this standard, negative goodwill is allocated on the pro-rata basis to reduce the value
assigned to non-current assets. Any excess of negative goodwill left after reducing these assets to zero is to
be considered as an extraordinary gain and recorded in the period in which the business combination is
completed.
 IAS-38 - Negative goodwill is not covered by this standard. Its treatment comes under IFRS-3. As per this
standard, negative goodwill should be recognized in profit and loss account immediately.
 AS-26 – Under this standard, negative goodwill is simply credited to the capital reserve account which is a
part of shareholder’s equity.
 AASB-138 – Under this negative goodwill shall be eliminated by reducing proportionately the fair values
of the acquired non-monetary assets. If after reducing non-monetary assets negative goodwill balance still
exist then the remaining balance is to be recognized as revenue in the profit and loss account.
Comparative Analysis A Study Of Accounting Standards…
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The table depicting difference in accounting treatment of negative goodwill between the five under
discussion standards is shown by table 2:
Table 2: Accounting Treatment of Negative Goodwill
Accounting
standard
Negative
goodwill up to
non-monetary
assets
Negative
goodwill in
excess of non-
monetary
assets
Other
Treatment
FRS-10
To be credited
in the profit and
loss account in
the recovery
period of those
assets.
To be credited
in the profit and
loss account up
to the expected
period of its
benefits.
─
FAS-142
Allocated on a
pro-rata basis to
reduce the value
assigned to non-
current assets
up to zero.
Considered as
an extra-
ordinary gain in
the period of
completion of
business
combination.
─
IAS-38* ─ ─
Immediately
recognize in
the profit
and loss
account.
AS-26 ─ ─
Credit the
whole
amount to
the capital
reserve
account.
AASB-138
Eliminated by
reducing
proportionately
the fair value of
the acquired
non-monetary
assets.
Recognized as
revenue in the
profit and loss
account. ─
*Does not provide accounting treatment of negative goodwill. It is provided by IFRS-3.
Internally Generated Goodwill
 FRS-10 – It should not be capitalized.
 FAS-142 – Internally generated goodwill is to be recognized as an expense.
 IAS-38 – It is not to be recognized.
 AS-26 – It is not to be recognized.
 AASB-138 – It is not to be recognized as an asset.
Comparative Analysis A Study Of Accounting Standards…
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The table depicting difference in accounting treatment of internally generated goodwill between the
five under discussion standards is shown by table 3:
Table 3: Accounting Treatment of Internally Generated Goodwill
Accounting Standard Accounting Treatment
FRS-10 Should not be capitalized.
FAS-142
Shall be recognized as an expense
when incurred.
IAS-38 Should not be capitalized.
AS-26 Should not be capitalized.
AASB-138 Should not be capitalized.
Internally Generated Intangible Assets
Internally generated intangible assets are those assets which are created by the entity by undertaking
the two phase process of research and development. In this process two types of costs are incurred- research
cost and development cost. Now the question is about the accounting treatment of these two costs i.e. which
cost to be capitalized and represented as an asset in the balance sheet and which cost to be charged from profit
and loss account.
 FRS-10 - This standard does not provide accounting treatment for research and development cost. It is
provided by Statement of Standard Accounting Practice No.13 (SSAP-13) - “Accounting for Research
and Development”. According to this standard, Research Cost is to be written off as they are incurred i.e.
to be charged as an expense. Development Cost shall be capitalized up to the amount which satisfies the
conditions of technical feasibility, commercial viability, clearly defined project, adequate resources exist
etc. given in this statement.
 FAS-142 - The treatment given by this standard is different from other standards. As per this standard, all
research anddevelopment cost shall be charged to profit and loss account as when incurred. No cost is to
be capitalized.
 IAS-38 – According to this standard, Research Cost is not to be recognized as an asset rather it is to be
debited to profit and loss account (treating as an expense). Development Cost can be capitalized and
recognized as an intangible asset if it satisfies the conditions of technical feasibility, intention to complete
the project, availability of adequate resources for the project, demonstrate the existence of market for the
output to be generated by this intangible asset. If all the conditions and recognition criteria’s given in the
standard (same as given under SSAP-13) are satisfied then development cost can be capitalized and
recognized as an internally generated intangible asset. If development cost does not satisfy the recognition
criteria then it is to be write-off from earnings immediately. The standard has not specified the maximum
amortization period. The enterprise has to apply judgement for the selection of amortization period on the
basis of the existing circumstances.
 AS-26 - According to this standard Research Cost cannot bestated as an intangible assets as no asset come
into physical existence i.e. such cost to be charged from profit and loss account as and when it is incurred.
As in case of Development Cost, accounting treatment is same as given in IAS-38. If all the conditions
and recognition criteria’s (same as under SSAP-13) are satisfied then development cost is to be recognized
an internally generated cost. Amortization period is to be fixed by the enterprise by applying judgement on
the basis of existing circumstances.
 AASB-138 – Under this standard alsono Research Cost shall be recognized as an intangible asset. Such
expenditure shall be recognized as an expense when it is incurred. The treatment of Development Cost is
same as in case of IAS-38 and AS-26. Development cost is to be capitalized as an internally generated
Intangible Asset if it satisfies all conditions and recognition criteria (same as under SSAP-13). Here also
amortization period is to be decided by the enterprise on the basis of the existing circumstances.
Comparative Analysis A Study Of Accounting Standards…
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The table depicting difference in accounting treatment of research and development cost between the five
under discussion standards is depicted by table 4:
Table 4: Accounting Treatment of Research and Development Cost
1) Amortization period
It is the estimated useful life of an intangible asset over which its depreciable amount (cost-scrap value)
is to be allocated. Each accounting standard makes a presumption about the useful life of an intangible asset
keeping in mind the factors like- the expected usage of an asset, technical obsolescence, expected actions by
competitors, period of control over the asset, international trend etc. But useful life of those intangible assets
which is determined by law shall not exceed the period of the contractual or legal rights. This section provides
information about the amortization period assumed by the five under discussion standards.
o FRS-10 – This standard has taken 20 years amortization period. Intangible Assets with life up to 20 years
are considered as Intangible Assets withlimited useful life. Intangible Assets with life more than 20 years
are considered as Intangible Assets with unlimited useful life.
o FAS-142 – This standard has not made any presumption about the useful life of an intangible asset. The
enterprises themselves have to decide the useful life on the basis of the factors like- the expected usage of
an asset, technical obsolescence, expected actions by competitors, period of control over the asset,
international trend etc.
o IAS-38 – Under this standard also, amortization period is assumed as 20 years. Intangible Assets with
useful life up to 20 years are amortized and those with useful life more than 20 years are tested for
impairment.
o AS-26 – This standard has presumed that amortization period shall not exceed 10 years. However, useful
life will be shorter of the useful life determined by economic and legal factors.
o AASB-138 – This standard has not presumed any limit for the useful life of intangible assets. The enterprise
has to decide on the basis of the factors affecting the useful life like expected usage of the asset, economic
factors, legal factors, technical obsolescence etc. The useful life of those intangible assets which arises from
contractual or other legal rights shall not exceed the period of the contractual or other legal rights.
The table depicting difference in assumption of amortization period between the five under discussion
standards is depicted by table 5:
Accounting
Standard
Research Cost Development Cost
FRS-10 Charge as an expense.
Capitalize if it satisfies all
conditions and recognition
criteria.
FAS-142
Charge from profit and loss
account as an expense.
Charge from profit and
loss account as an
expense.
IAS-38
Charge from profit and loss
account as an expense.
Capitalize if it satisfies all
conditions and recognition
criteria.
AS-26
Charge from profit and loss
account as an expense.
Capitalize if it satisfies all
conditions and recognition
criteria.
AASB-138
Charge from profit and loss
account as an expense.
Capitalize if it satisfies all
conditions and recognition
criteria.
Comparative Analysis A Study Of Accounting Standards…
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Table 5: Assumption of Accounting Period
Accounting Standard Amortization Period
FRS-10 20 years
FAS-142 Not specified. To be based on economic and legal factors.
IAS-38 20 years
AS-26 10 years
AASB-138 Not specified. To be based on economic and legal factors.
4) Amortization Method
Amortization method is the method by which the depreciable amount of the intangible asset is allocated over the
amortization period. Amortization method must reflect the pattern in which the asset’s economic benefits are to
be consumed by the enterprise. This will help in matching the revenue earned with the corresponding cost of the
asset. This section discusses various amortization methods permissible under the five under discussion
standards.
 FRS-10 – As per this standard, amortization method must reflect the expected pattern of depletion of
intangible asset. This standard has provided straight line method unless another method demonstrates more
appropriateness. This standard has specifically given that interest methods such as the reverse sum of digits
method are not appropriate methods of amortizing goodwill as they do not reflect the pattern of depletion of
goodwill.
 FAS-142 – According to this standard amortization method must reflect the pattern of economic benefits of
the intangible asset. Under this standard no method has been specified as factors affecting it will differ from
asset to asset and from company to company. If pattern of the future economic benefits cannot be
determined reliably then straight line method shall be used.
 IAS-38 – Under this standard also, no amortization method has been specified but it must reflect the pattern
of future economic benefits arising from intangible asset. If the pattern cannot be determined then straight
line method shall be used.
 AS-26 – This standard has specified the following methods which can be used for amortizing intangible
assets:-
[1] Straight Line Method
[2] Diminishing Balance Method
[3] Production Method
Whatever method selected should be consistent with the pattern of consumption of economic benefits and
should be consistently followed.
 AASB-138 - Under this standard the rule is same as in case of IAS-38 and AS-26. Amortization method
must reflect the pattern of consumption of future economic benefits. But if pattern cannot be determined
reliably then straight line method should be followed.
The table depicting difference between the amortization methods to be followed provided by the five under
discussion standards are depicted by table 6:
Table 6: Amortization Methods
Accounting Standard Amortization Method
FRS-10
Not specified. Use straight line method unless
other is more appropriate.
FAS-142
Not specified. Use straight line method unless
other is more appropriate.
IAS-38
Not specified. Use straight line method unless
other is more appropriate.
AS-26
Straight Line Method, Diminishing Balance
Method, Production Unit Method.
AASB-138
Not specified. Use straight line method unless
other is more appropriate.
Comparative Analysis A Study Of Accounting Standards…
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V. CONCLUSION
With the help of above analysis, points of difference emerged among standards under discussion. The
difference analysis has been done on the basis of first version of the standards under study. Some amendments
have taken place since their issue. Following section discuss those amendments and standards under discussion
status with respect to IAS-38.
Accounting Standard-26
The Institute of Chartered Accountants of India issued AS-26 in 2002. In 2010, ICAI came out with an
exposure draft pointing out the major differences between AS-26 and the proposed AS-26(Considered points for
harmonization with IAS-38) but no amended standard has been issued. Therefore, India has not started
harmonization of AS-26 with IAS-38 (the international standard).
Financial Accounting Standard-142
Financial Accounting Standard Board of United States of America issued FAS-142 in June 2001. Later,
FASB came out with four amendments. All amendments are related with goodwill impairment testing. Other
points of difference between IAS-38 and FAS-142 have not been covered by the amendments.
Australian Accounting Standard -138
Australian Accounting Standard Board issued the first version of AASB-138 in 1996. Board came out
with two amended versions of AASB -138 in 2005 and 2013. With these amendments, AASB-138 is now fully
compliant with IAS-38.
Financial Reporting Standard -10
Accounting Standard Board of United Kingdom issued FRS-10 in 1997. No amendment has been made
in FRS-10 till date.
REFERENCES
[1] http://www.aasb.gov.au/admin/file/content102/c3/AASB1013_6-96.pdf
[2] http://www.aasb.gov.au/admin/file/content105/c9/AASB138_07-04_COMPjun09_07-09.pdf
[3] http://www.aasb.gov.au/admin/file/content105/c9/AASB138_07-04_FP_COMPdec12_07-13.pdf
[4] http://www.fasb.org/cs/BlobServer?blobcol=urldata&blobtable=MungoBlobs&blobkey=id&blobwhere=1175820927971&blobh
eader=application/pdf
[5] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175821919016&blobheader=application%2Fp
df&blobheadername2=Content-Length&blobheadername1=Content-
Disposition&blobheadervalue2=167734&blobheadervalue1=filename%3DASU2010-
28.pdf&blobcol=urldata&blobtable=MungoBlobs
[6] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175822937733&blobheader=application%2Fp
df&blobheadername2=Content-Length&blobheadername1=Content-
Disposition&blobheadervalue2=274798&blobheadervalue1=filename%3DASU_2011-
08.pdf&blobcol=urldata&blobtable=MungoBlobs
[7] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175824275038&blobheader=application%2Fp
df&blobheadername2=Content-Length&blobheadername1=Content-
Disposition&blobheadervalue2=263295&blobheadervalue1=filename%3DASU2012-
02.pdf&blobcol=urldata&blobtable=MungoBlobs
[8] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175828192203&blobheader=application%2Fp
df&blobheadername2=Content-Length&blobheadername1=Content-
Disposition&blobheadervalue2=331329&blobheadervalue1=filename%3DASU_2014-
02.pdf&blobcol=urldata&blobtable=MungoBlobs
[9] https://www.frc.org.uk/Our-Work/Publications/ASB/FRS-10-Goodwill-and-Intangible-Assets/FRS-10-Goodwill-and-Intangible-
Assets.aspx
[10] https://frc.org.uk/Our-Work/Publications/ASB/SSAP-13-Accounting-for-research-and-development-File.pdf
[11] http://icai.org/resource_file/18989as26announ10353.pdf
[12] http://www.ifrs.org/IFRSs/IFRS-technical-summaries/Documents/IAS38-English.pdf
[13] http://www.ifrs.org/IFRSs/IFRS-technical-summaries/Documents/English%20Web%20Summaries%202013/IFRS%203.pdf
[14] http://www.investopedia.com/terms/a/accounting-standard.asp
[15] http://220.227.161.86/27292asb-as-26.pdf
[16] Nakamura Leonard (2003), “A trillion Dollars a Year in Intangible Investment and the New Economy.” Edited by John Hand and
Baruch Lev in Intangible Assets: Value, Measures, and Risks. Oxford: Oxford University Press.

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Comparative Analysis of Intangible Asset Accounting Standards

  • 1. International Journal of Business and Management Invention ISSN (Online): 2319 – 8028, ISSN (Print): 2319 – 801X www.ijbmi.org Volume 3 Issue 2ǁ February. 2014ǁ PP.10-17 www.ijbmi.org 10 | Page COMPARATIVE ANALYSIS-- A STUDY OF ACCOUNTING STANDARDS ON INTANGIBLE ASSETS OF FIVE COUNTRIES 1, Manpreet Sharma , 2, Neha 1, Assistant Professor Department of Commerce Shri Ram College of Commerce Delhi University 2, Research Scholar Department of Commerce Delhi School of Economics University of Delhi Delhi-110007 ABSTRACT: The aim of this study is to prepare the comparative analysis of standards of five different countries on Intangible assets namely FRS-10(United Kingdom), AASB-138(Australia), FAS-142 (United States of America), AS-26 (India) and IAS-38 (International). The analysis has been done broadly on the following basis – accounting treatment of different types of goodwill, internally generated goodwill, internally generated intangible assets, how to subsequently recognize the intangible assets (amortization method, amortization period) and how to treat impairment loss.After each topic a comparative table has been prepared to have a quick view of differences between the standards. This difference analysis has helped in ascertaining the degree of harmonization of standards under discussion with respect to IAS-38 the international standard. KEY WORDS: AASB- 138, AS-26, FAS-142, FRS-10, IAS-38, Intangible Assets. I. INTRODUCTION An asset is an economic resource tangible or intangible that is being owned by an individual, company or country with the expectation of future benefits. The monetary value of the owned assets is depicted by the balance sheet of the firm. Two major classes of assets are tangible assets and intangible assets. Tangible assets include current assets (inventory, cash) and fixed assets (buildings). Intangible assets are non-physical resources and rights that have a value to the firm and give an additive advantage to the firm. Examples of Intangible Assets are patents, copyrights, goodwill, trademarks, human capital and computer programs. These Intangible Assets are rapidly capturing the center stage. The presence of Intangible Assets can be traced even to the Stone Age. The invention of fire by rubbing two stones is an apt example. This invention could have been patented if laws of patent would have been there at that time. All this shows that the presence of Intangible Assets is not new rather it is the awareness and development of laws that has increased over time. In today’s competitive world, Intangible Assets play an imperative role for the business in having competitive edge. They have become an indispensable part of the Balance sheet of the company’s these days.Research (Nakamura, 2003) indicated that the annual US investment in Intangibles was almost equal ($ 1 trillion) to the total investment of the manufacturing sector in physical assets. This data points out that they have become an indispensable part of the balance sheet of the company’s in today’s world. The revolution from industrial economy to the current knowledge economy started and demanded incessant innovation, buyer centricity and eminent customer services. This required companies to invest more and more in operative activities, brand building, strong customer relationship building and workforce training instead of execution assets. Besides, investment in intangibles which enables firms to innovate generated returns extensively elevated in comparison to the cost of capital and returns on fixed assets investments. All this arise the need of proper accounting and disclosure of intangible assets. The increasing importance and share of intangible assets in the balance sheet has increased the need of accurate accounting and disclosure of Intangible assets. Every country especially those with major amount of Intangible Assets have issued accounting standards for the accounting and disclosure of these assets on the basis of their economic and accounting environment. In India, accounting and disclosure of intangible assets is taken care by Accounting Standard -26. In United States of America, it is Financial Accounting Standard-142 which takes care about this issue. In Australia, it is Financial Reporting Standard-10 which is issued for the treatment of Intangible Assets. The international accounting body- International Accounting Standard Board issued International AccountingStandard-38 for Intangible assets. At the international level World Intellectual Property Organization (WIPO) was
  • 2. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 11 | Page established in 1967 to administer intellectual property rights. All the members of WIPO are required to bring their intellectual property laws in compliance with WIPO laws. Also at the international level Agreement on Trade Related IntellectualProperty Rights (TRIPS) was included in the Act of the Uruguay Round to give more importance to intellectual property rights. II. RATIONAL OF THE PAPER This paper tries to bring out the difference between the standards under discussion (FRS-10(United Kingdom), AASB-138(Australia), FAS-142 (United States of America), AS-26 (India) and IAS-38 (International) majorly on the basis of the following points:- 1) Goodwill Treatment a. Positive Goodwill b. Negative Goodwill c. Internally Generated Goodwill 2) Internally generated assets a. Research Cost b. Development Cost 3) Amortization Period 4) Amortization Method 5) Impairment Loss III. DEFINING ACCOUNTING STANDARD Accounting standard is a statement that provides guidelines for preparing standardized financial statements by a firm. It provides rules of accounting and disclosure of incomes, expenses, assets and liabilities in financial statements. It helps in comparing financial statements of different companies as it brings uniformity in preparing financial statements.In the field of accounting, the group of widely accepted accounting standards is known as GAAP (Generally Accepted Accounting principle). IV. COMPARATIVE ANALYSIS Goodwill Treatment There are different types of goodwill. Acquired goodwill is the goodwill generated due to acquisition. It can be positive (acquired price>net value of the assets) or negative (acquired price< net value of the assets). Internally generated goodwill is the goodwill generated by the business on its own. It is the excess of the market value of the business over the book value of the business. Accounting treatment of each type of goodwill is different from each other and from standard to standard. The accounting treatment of each type of goodwill is discussed below on the basis of five standards under discussion. Positive Goodwill  FRS-10 – According to this standard positive goodwill is to be capitalized and classified as an asset in the balance sheet. This standard has specified 20 years for which the goodwill is regarded as having a limited useful economic life. Beyond 20 years, goodwill is considered as having infinite life. Goodwill with limited life (not more than 20 years) is to be amortized on a systematic basis (depicting expected pattern of depletion) over its useful life. Also, standard has given conditions for impairment. Goodwill with life up to 20 years along with amortization should also be tested for impairment at the end of the first financial year and later only when the circumstances indicates that carrying value may not be recoverable. Goodwill with infinite life (more than 20 years) should not be amortized but only be tested for impairment at the end of each reporting period.  FAS-142 – Goodwill is to be capitalized and presented as a separate item in the statement of financial position. This standard has not divided the goodwill on the basis of useful economic life for subsequent recognition. According to this standard, goodwill is not to be amortized. It should be tested annually (after every reporting period) for impairment and be tested between annual tests depending on circumstances.  IAS-38 – Under this standard, goodwill is to be capitalized and shown on the asset side of the balance sheet as a separate item. This standard has also classified goodwill in two categories- one with limited useful economic life and one with infinite useful life. Goodwill with limited useful life is to be amortized on a systematic basis (reflecting the expected future economic benefits) over its useful life. The standard has specified that straight line method should be adopted unless it can be justified that other method is better
  • 3. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 12 | Page than this method. The goodwill with infinite useful life is required to be tested for impairment according to IAS-36 “Impairment of Assets” annually or when there are indications.  AS-26 – Goodwill is to be capitalized and shown as an asset in the balance sheet. Under this standard, goodwill is to be tested for impairment annually with an exception of goodwill arising due to amalgamation. This goodwill is to be amortized over 3-5 years (AS-14, Accounting for Amalgamation).  AASB-138– This standard does not cover accounting treatment for the purchased goodwill. The treatment is given by AASB-1013 “Accounting for Goodwill”. According to AASB-138, at the time of acquisition the positive goodwill is required to be recognized as a non-current asset. For subsequent recognition, goodwill is required to be amortized. The useful life of the goodwill shall not exceed twenty years from the date of acquisition. The table depicting difference in accounting treatment of positive goodwill between the five under discussion standards is shown by table 1: Table 1: Accounting Treatment of Positive Goodwill Accounting Standard Amortization Impairment FRS-10 Amortized if useful life is up to 20 years Tested for impairment if useful life is more than 20 years. FAS-142 Not amortized Only to be tested for impairment annually and in-between the year if required. IAS-38 Amortized when useful life is finite. Tested for impairment when useful life is infinite annually or when there are indications. AS-26 Not to be amortized with the exception of goodwill arising in amalgamation in which case is to be amortized in 3-5 years. To be tested for impairment annually or when required. AASB-138* Amortized Also to be tested for impairment at each reporting date. * Does not cover accounting treatment for the purchased goodwill. It is provided by AASB-1013 Negative Goodwill  FRS-10 – It is to be recognized and disclosed in the balance sheet immediately below the goodwill heading. At the end, the net amount of positive and negative goodwill/ is shown. If there is no positive goodwill present in the balance sheet then negative goodwill is to be shown on the liability side of the balance sheet. Negative goodwill which is up to the fair value of the non-monetary assets acquired should be credited in the profit and loss account in the recovery period of those assets whether the recovery is through depreciation or sale. Negative goodwill in excess of this fair value of the non-monetary assets should be credited in the profit and loss account up to the expected period of its benefit.  FAS-142 – Under this standard, negative goodwill is allocated on the pro-rata basis to reduce the value assigned to non-current assets. Any excess of negative goodwill left after reducing these assets to zero is to be considered as an extraordinary gain and recorded in the period in which the business combination is completed.  IAS-38 - Negative goodwill is not covered by this standard. Its treatment comes under IFRS-3. As per this standard, negative goodwill should be recognized in profit and loss account immediately.  AS-26 – Under this standard, negative goodwill is simply credited to the capital reserve account which is a part of shareholder’s equity.  AASB-138 – Under this negative goodwill shall be eliminated by reducing proportionately the fair values of the acquired non-monetary assets. If after reducing non-monetary assets negative goodwill balance still exist then the remaining balance is to be recognized as revenue in the profit and loss account.
  • 4. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 13 | Page The table depicting difference in accounting treatment of negative goodwill between the five under discussion standards is shown by table 2: Table 2: Accounting Treatment of Negative Goodwill Accounting standard Negative goodwill up to non-monetary assets Negative goodwill in excess of non- monetary assets Other Treatment FRS-10 To be credited in the profit and loss account in the recovery period of those assets. To be credited in the profit and loss account up to the expected period of its benefits. ─ FAS-142 Allocated on a pro-rata basis to reduce the value assigned to non- current assets up to zero. Considered as an extra- ordinary gain in the period of completion of business combination. ─ IAS-38* ─ ─ Immediately recognize in the profit and loss account. AS-26 ─ ─ Credit the whole amount to the capital reserve account. AASB-138 Eliminated by reducing proportionately the fair value of the acquired non-monetary assets. Recognized as revenue in the profit and loss account. ─ *Does not provide accounting treatment of negative goodwill. It is provided by IFRS-3. Internally Generated Goodwill  FRS-10 – It should not be capitalized.  FAS-142 – Internally generated goodwill is to be recognized as an expense.  IAS-38 – It is not to be recognized.  AS-26 – It is not to be recognized.  AASB-138 – It is not to be recognized as an asset.
  • 5. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 14 | Page The table depicting difference in accounting treatment of internally generated goodwill between the five under discussion standards is shown by table 3: Table 3: Accounting Treatment of Internally Generated Goodwill Accounting Standard Accounting Treatment FRS-10 Should not be capitalized. FAS-142 Shall be recognized as an expense when incurred. IAS-38 Should not be capitalized. AS-26 Should not be capitalized. AASB-138 Should not be capitalized. Internally Generated Intangible Assets Internally generated intangible assets are those assets which are created by the entity by undertaking the two phase process of research and development. In this process two types of costs are incurred- research cost and development cost. Now the question is about the accounting treatment of these two costs i.e. which cost to be capitalized and represented as an asset in the balance sheet and which cost to be charged from profit and loss account.  FRS-10 - This standard does not provide accounting treatment for research and development cost. It is provided by Statement of Standard Accounting Practice No.13 (SSAP-13) - “Accounting for Research and Development”. According to this standard, Research Cost is to be written off as they are incurred i.e. to be charged as an expense. Development Cost shall be capitalized up to the amount which satisfies the conditions of technical feasibility, commercial viability, clearly defined project, adequate resources exist etc. given in this statement.  FAS-142 - The treatment given by this standard is different from other standards. As per this standard, all research anddevelopment cost shall be charged to profit and loss account as when incurred. No cost is to be capitalized.  IAS-38 – According to this standard, Research Cost is not to be recognized as an asset rather it is to be debited to profit and loss account (treating as an expense). Development Cost can be capitalized and recognized as an intangible asset if it satisfies the conditions of technical feasibility, intention to complete the project, availability of adequate resources for the project, demonstrate the existence of market for the output to be generated by this intangible asset. If all the conditions and recognition criteria’s given in the standard (same as given under SSAP-13) are satisfied then development cost can be capitalized and recognized as an internally generated intangible asset. If development cost does not satisfy the recognition criteria then it is to be write-off from earnings immediately. The standard has not specified the maximum amortization period. The enterprise has to apply judgement for the selection of amortization period on the basis of the existing circumstances.  AS-26 - According to this standard Research Cost cannot bestated as an intangible assets as no asset come into physical existence i.e. such cost to be charged from profit and loss account as and when it is incurred. As in case of Development Cost, accounting treatment is same as given in IAS-38. If all the conditions and recognition criteria’s (same as under SSAP-13) are satisfied then development cost is to be recognized an internally generated cost. Amortization period is to be fixed by the enterprise by applying judgement on the basis of existing circumstances.  AASB-138 – Under this standard alsono Research Cost shall be recognized as an intangible asset. Such expenditure shall be recognized as an expense when it is incurred. The treatment of Development Cost is same as in case of IAS-38 and AS-26. Development cost is to be capitalized as an internally generated Intangible Asset if it satisfies all conditions and recognition criteria (same as under SSAP-13). Here also amortization period is to be decided by the enterprise on the basis of the existing circumstances.
  • 6. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 15 | Page The table depicting difference in accounting treatment of research and development cost between the five under discussion standards is depicted by table 4: Table 4: Accounting Treatment of Research and Development Cost 1) Amortization period It is the estimated useful life of an intangible asset over which its depreciable amount (cost-scrap value) is to be allocated. Each accounting standard makes a presumption about the useful life of an intangible asset keeping in mind the factors like- the expected usage of an asset, technical obsolescence, expected actions by competitors, period of control over the asset, international trend etc. But useful life of those intangible assets which is determined by law shall not exceed the period of the contractual or legal rights. This section provides information about the amortization period assumed by the five under discussion standards. o FRS-10 – This standard has taken 20 years amortization period. Intangible Assets with life up to 20 years are considered as Intangible Assets withlimited useful life. Intangible Assets with life more than 20 years are considered as Intangible Assets with unlimited useful life. o FAS-142 – This standard has not made any presumption about the useful life of an intangible asset. The enterprises themselves have to decide the useful life on the basis of the factors like- the expected usage of an asset, technical obsolescence, expected actions by competitors, period of control over the asset, international trend etc. o IAS-38 – Under this standard also, amortization period is assumed as 20 years. Intangible Assets with useful life up to 20 years are amortized and those with useful life more than 20 years are tested for impairment. o AS-26 – This standard has presumed that amortization period shall not exceed 10 years. However, useful life will be shorter of the useful life determined by economic and legal factors. o AASB-138 – This standard has not presumed any limit for the useful life of intangible assets. The enterprise has to decide on the basis of the factors affecting the useful life like expected usage of the asset, economic factors, legal factors, technical obsolescence etc. The useful life of those intangible assets which arises from contractual or other legal rights shall not exceed the period of the contractual or other legal rights. The table depicting difference in assumption of amortization period between the five under discussion standards is depicted by table 5: Accounting Standard Research Cost Development Cost FRS-10 Charge as an expense. Capitalize if it satisfies all conditions and recognition criteria. FAS-142 Charge from profit and loss account as an expense. Charge from profit and loss account as an expense. IAS-38 Charge from profit and loss account as an expense. Capitalize if it satisfies all conditions and recognition criteria. AS-26 Charge from profit and loss account as an expense. Capitalize if it satisfies all conditions and recognition criteria. AASB-138 Charge from profit and loss account as an expense. Capitalize if it satisfies all conditions and recognition criteria.
  • 7. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 16 | Page Table 5: Assumption of Accounting Period Accounting Standard Amortization Period FRS-10 20 years FAS-142 Not specified. To be based on economic and legal factors. IAS-38 20 years AS-26 10 years AASB-138 Not specified. To be based on economic and legal factors. 4) Amortization Method Amortization method is the method by which the depreciable amount of the intangible asset is allocated over the amortization period. Amortization method must reflect the pattern in which the asset’s economic benefits are to be consumed by the enterprise. This will help in matching the revenue earned with the corresponding cost of the asset. This section discusses various amortization methods permissible under the five under discussion standards.  FRS-10 – As per this standard, amortization method must reflect the expected pattern of depletion of intangible asset. This standard has provided straight line method unless another method demonstrates more appropriateness. This standard has specifically given that interest methods such as the reverse sum of digits method are not appropriate methods of amortizing goodwill as they do not reflect the pattern of depletion of goodwill.  FAS-142 – According to this standard amortization method must reflect the pattern of economic benefits of the intangible asset. Under this standard no method has been specified as factors affecting it will differ from asset to asset and from company to company. If pattern of the future economic benefits cannot be determined reliably then straight line method shall be used.  IAS-38 – Under this standard also, no amortization method has been specified but it must reflect the pattern of future economic benefits arising from intangible asset. If the pattern cannot be determined then straight line method shall be used.  AS-26 – This standard has specified the following methods which can be used for amortizing intangible assets:- [1] Straight Line Method [2] Diminishing Balance Method [3] Production Method Whatever method selected should be consistent with the pattern of consumption of economic benefits and should be consistently followed.  AASB-138 - Under this standard the rule is same as in case of IAS-38 and AS-26. Amortization method must reflect the pattern of consumption of future economic benefits. But if pattern cannot be determined reliably then straight line method should be followed. The table depicting difference between the amortization methods to be followed provided by the five under discussion standards are depicted by table 6: Table 6: Amortization Methods Accounting Standard Amortization Method FRS-10 Not specified. Use straight line method unless other is more appropriate. FAS-142 Not specified. Use straight line method unless other is more appropriate. IAS-38 Not specified. Use straight line method unless other is more appropriate. AS-26 Straight Line Method, Diminishing Balance Method, Production Unit Method. AASB-138 Not specified. Use straight line method unless other is more appropriate.
  • 8. Comparative Analysis A Study Of Accounting Standards… www.ijbmi.org 17 | Page V. CONCLUSION With the help of above analysis, points of difference emerged among standards under discussion. The difference analysis has been done on the basis of first version of the standards under study. Some amendments have taken place since their issue. Following section discuss those amendments and standards under discussion status with respect to IAS-38. Accounting Standard-26 The Institute of Chartered Accountants of India issued AS-26 in 2002. In 2010, ICAI came out with an exposure draft pointing out the major differences between AS-26 and the proposed AS-26(Considered points for harmonization with IAS-38) but no amended standard has been issued. Therefore, India has not started harmonization of AS-26 with IAS-38 (the international standard). Financial Accounting Standard-142 Financial Accounting Standard Board of United States of America issued FAS-142 in June 2001. Later, FASB came out with four amendments. All amendments are related with goodwill impairment testing. Other points of difference between IAS-38 and FAS-142 have not been covered by the amendments. Australian Accounting Standard -138 Australian Accounting Standard Board issued the first version of AASB-138 in 1996. Board came out with two amended versions of AASB -138 in 2005 and 2013. With these amendments, AASB-138 is now fully compliant with IAS-38. Financial Reporting Standard -10 Accounting Standard Board of United Kingdom issued FRS-10 in 1997. No amendment has been made in FRS-10 till date. REFERENCES [1] http://www.aasb.gov.au/admin/file/content102/c3/AASB1013_6-96.pdf [2] http://www.aasb.gov.au/admin/file/content105/c9/AASB138_07-04_COMPjun09_07-09.pdf [3] http://www.aasb.gov.au/admin/file/content105/c9/AASB138_07-04_FP_COMPdec12_07-13.pdf [4] http://www.fasb.org/cs/BlobServer?blobcol=urldata&blobtable=MungoBlobs&blobkey=id&blobwhere=1175820927971&blobh eader=application/pdf [5] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175821919016&blobheader=application%2Fp df&blobheadername2=Content-Length&blobheadername1=Content- Disposition&blobheadervalue2=167734&blobheadervalue1=filename%3DASU2010- 28.pdf&blobcol=urldata&blobtable=MungoBlobs [6] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175822937733&blobheader=application%2Fp df&blobheadername2=Content-Length&blobheadername1=Content- Disposition&blobheadervalue2=274798&blobheadervalue1=filename%3DASU_2011- 08.pdf&blobcol=urldata&blobtable=MungoBlobs [7] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175824275038&blobheader=application%2Fp df&blobheadername2=Content-Length&blobheadername1=Content- Disposition&blobheadervalue2=263295&blobheadervalue1=filename%3DASU2012- 02.pdf&blobcol=urldata&blobtable=MungoBlobs [8] http://www.fasb.org/cs/BlobServer?blobkey=id&blobnocache=true&blobwhere=1175828192203&blobheader=application%2Fp df&blobheadername2=Content-Length&blobheadername1=Content- Disposition&blobheadervalue2=331329&blobheadervalue1=filename%3DASU_2014- 02.pdf&blobcol=urldata&blobtable=MungoBlobs [9] https://www.frc.org.uk/Our-Work/Publications/ASB/FRS-10-Goodwill-and-Intangible-Assets/FRS-10-Goodwill-and-Intangible- Assets.aspx [10] https://frc.org.uk/Our-Work/Publications/ASB/SSAP-13-Accounting-for-research-and-development-File.pdf [11] http://icai.org/resource_file/18989as26announ10353.pdf [12] http://www.ifrs.org/IFRSs/IFRS-technical-summaries/Documents/IAS38-English.pdf [13] http://www.ifrs.org/IFRSs/IFRS-technical-summaries/Documents/English%20Web%20Summaries%202013/IFRS%203.pdf [14] http://www.investopedia.com/terms/a/accounting-standard.asp [15] http://220.227.161.86/27292asb-as-26.pdf [16] Nakamura Leonard (2003), “A trillion Dollars a Year in Intangible Investment and the New Economy.” Edited by John Hand and Baruch Lev in Intangible Assets: Value, Measures, and Risks. Oxford: Oxford University Press.