Förslag till fortsatt forskning

Studien bygger endast på fråga åtta i utkastet ifrån IASB. I sin helhet bestod utkastet

av tio huvudfrågor som berör koncernredovisningens olika delar. En annan intressant

frågeställning som ingick i utkastet var förbudet mot poolningsmetoden, där det finns

möjlighet att undersöka vilken inställning de olika intressenterna hade mot detta

förbud. Generellt finns det en hel del forskning kring lobbying och normsättning i

helhet, men majoriteten av dessa studier baseras på nationella processer. Vår

uppfattning är att den internationella normgivningsprocessen är ett mer outforskat

område som implicerar andra element som kan vara intressanta att studera, som till

exempel de nationella normsättarnas delaktighet som en aktör i processen.

Referenslista

Alvesson M, Sköldberg K, Tolkning och reflektion, 1994. Lund

Artsberg K, Redovisningsteori- policy och praxis, 2003. Malmö

Anonym, Setting accounting standars relevant to the concept of control used for consolidated

accounts in the UK: An analysis of lobbying behaviour, sine anno

Combes R.J, Stokes D.J, Standard setters responsiveness to submissions on exposure drafts:

Australian evidence, 1985, Australian Journal of management, December,pp. 32- 44

Currie C, Robinson P, Walker R.G, Political activity and the regulation of accounting: Gaps

in the literature, 1987, Proceedings Accounting association Australia and New Zealand

conference

Deegan C, Morris R Walker, Audit firm lobbying on proposed disclosure requirements, 1990,

Australian journal of management, Vol. 15 No.2

Eriksson L.T, Wiedersheim- Paul F, Att utreda forska och rapportera, 2001, Malmö

Gilje, Grimen, Samhällsvetenskapernas förutsättningar, 1992

Gustavsson, Kunskapande metoder, 2004. Lund

IASB, ED 3 business combination,2002

Nilsson, Goodwill får inte skrivas av, 2004, Balans nr 4

O´keefe T.B, Solomon S.Y, Do managers believe the efficient market hypothesis? Additional

evidence, 1985, Accounting and business research, spring, pp. 67- 79

Siewald, The development of international financial reporting standards, 2005

Smith, Redovisningens språk,, 2006. Lund

Sutton T.G, Lobbying of accounting standard-setting bodies in the UK and USA: A downsian

analysi, 1984, Accounting organizations and society Vol.9 No.1 pp.81-95

Tutticci I, Dunstan K, Holmes S, Respondent lobbying in the australian accounting standard-

setting process: ED 49,1994, Accounting, Auditing & Accountability journal, Vol.7 No.1 pp.

86- 104.

Watts, Zimmerman, towards a positive theory of the determination of accounting standards,

1986, The accounting review, Vol LIII No.1 pp 112- 34

Weetman, Lobbying on accounting issues, 1996

Weetman P, Davie E.S, Collins W Lobbying on accounting issues, 1996, Accounting,

Auditing & accountability journal, Vol.9 No.1 pp. 59- 76

Bilaga 1- 6

Nationella normsättare för avskrivningar

CL 9

We agree that goodwill acquired in a business combination should be recognised as an asset, although we consider that goodwill represents a prepaid premium rather than an identifiable asset. We considered the two alternative methods of accounting for goodwill after initial recognition i.e. testing for impairment and amortisation over the useful life. The first method has as significant advantages that in cases of indefinite useful life of goodwill with no indication of diminution in value of the acquired entity, no amortisation or impairment has to be recognised so that no charge to income has to be made. In addition, this method has been adopted in the U.S.A. and inclusion in IFRS will therefore bring about worldwide convergence. On the other hand the impairment test as proposed has conceptual and practical weaknesses, for example:

- in applying the impairment test acquired goodwill and internally generated goodwill will

be intermingled

- no reversal of the carrying amount of goodwill will take place when the factors that

caused the impairment reverse

- annual impairment testing is an onerous and very judgemental process.

The second method of systematic amortisation with additional impairment testing (as currently mandated by IAS 22 Business Combinations) acknowledges that the factors that constitute the goodwill paid at acquisition generally diminish in value over time and that the ensuing costs are charged to income systematically over its useful life. In practice this method is easy to apply, which makes it particularly attractive for small and medium sized companies and those entities that have no cross-border listings in the U.S.A. Although we are generally not in favour of options in accounting standards, we strongly recommend the Board in this case to retain the current IAS 22 Business Combinations treatment as an allowed alternative, in addition to non- amortisation and impairment testing, the latter regarded as the benchmark treatment.

CL 30

No, we do not agree with the Board’s proposal. We are of the opinion that the factors that constitute the goodwill paid at acquisition generally diminish in value over time. We believe this is also true where there is no loss in the overall value of the acquired business, based on the fact that external goodwill will be replaced by internally generated goodwill in due time. We therefore believe that goodwill should be amortised systematically over its useful life. The impairment test as proposed has conceptual and practical weaknesses, for example: • in applying the impairment test acquired goodwill

and internally generated goodwill will be intermingled;

• no reversal of the carrying amount of goodwill will take place when the factors that

caused the impairment reverse; and

• annual impairment testing is an onerous and very judgemental process.

We believe that the proposed impairment test will prove insufficiently robust to measure any decline in the value of goodwill with a reasonable degree of reliability and objectivity. Our objective is not to seek international convergence at any price, but primarily to improve the quality of accounting. In our opinion the objective of qualitative good accounting can only be achieved by recognising goodwill as an asset and amortising the goodwill over the useful life. Therefore, we believe that IAS 22 should be retained in this respect.

CL 32

We agree that goodwill acquired in a business combination should be initially recognized as an asset. After initial recognition, we don’t believe it is always appropriate that goodwill should be accounted for at cost less any accumulated impairment losses, because in many cases impairment test result is not very reliable. We suggest that goodwill should be amortized in certain period, for example, 10 years, and subject to impairment test periodically.

CL 36

We agree that goodwill acquired in a business combination should be recognised as an asset. We do not agree that goodwill should be accounted for after initial recognition at cost less accumulated impairment losses, without amortisation, as proposed in ED 3. We recommend the Board to retain the principles in the current IAS 22 Business Combinations as the only alternative for the accounting for goodwill after intitial recognition. However, we believe that IAS 22 should be improved, as indicated below. Our rejection of the proposal in ED 3 is based on deficiencies in the proposed impairment test:

• The test, as drafted, is not appropriate as it makes no distinction between goodwill acquired in a business combination and internally generated goodwill. As a consequence, the test does not measure what it should measure, namely, acquired goodwill, but, instead, measures the cash-generating unit’s total goodwill. This deficiency could easily lead to the recognition of internally generated goodwill, which is in conflict with IAS 38. In fact, this will probably normally be the case.

• The test has not been sufficiently tested and proven in practice.

• The reliability of the estimates on which the cash flow projections in the test are based,can vary considerably between different industries and entities.

• The test is complex, expensive and time-consuming. • The application of the test requires that the entities

must provide information that may be sensitive from a business point of view.

We, therefore, believe that the test cannot be used as the only measurement tool without serious consequences as regards the quality of the financial information provided concerning goodwill. On the other hand, we believe that the impairment test is a valuable complement to amortisation. This application of the impairment test puts

fewer requirements on the test. In this case, the sensitive information mentioned above may not be required. We believe that the alternative ”amortisation combined with impairment tests” has merits that are not fully expressed in the Basis for Conclusions (except in the ”alternative views” of the two dissidents). Amortisation of goodwill is a well-established and well-understood practice. It is transparent and targeted only on acquired goodwill and, therefore, prevents acquired goodwill from being retained in the balance sheet for an undetermined number of years, which may happen with the alternative ”impairment tests only”, by which internally generated goodwill acts as a ”cushion” against write-downs of goodwill which would have otherwise been made. The main criticism, in the Basis for Conclusions (BC107), of amortisation is that the useful life of acquired goodwill, and the pattern in which it diminishes, generally are not possible to predict. We note, however, that IAS 22 contains, in fact, some guidelines for the estimation of the useful life of goodwill. We believe that these guidelines could be improved, e.g. by examples illustrating the determination of useful lives in different situations. Even before the introduction of such improvements, and still to a greater degree after their introduction, we believe that the alternative ”amortisation combined with impairment tests” would not be less precise than the alternative ”impairment tests only”, given the deficiencies in the tests as commented upon above.

CL 39

We do not agree with the proposed subsequent accounting for goodwill in paragraph 54 of ED 3, that is, non-amortisation and impairment only approach for goodwill. We expressed this position in the letter to IASB and national standard setters in November 2001. We believe that goodwill should be amortised over a certain period and be subject to impairment when necessary. We agree with the rejection of the immediate write-off of goodwill because goodwill includes some components which do not immediately diminish, such as the value of excess earning power of the acquired entity. However, we do not agree with non- amortization of goodwill, since the value of such power usually diminishes as the competition intensifies. Even where the value of excess earnings appears to be sustained, this occurs owing to complementarity by the additional investment or other efforts made by the acquirer after the business combination. Therefore, we believe that non-amortization of goodwill is virtually equal to capitalization of internally generated goodwill and inconsistent with the current accounting model, including the requirement in paragraph 40 of the proposed amendments to IAS 38 “Intangible Assets”. Paragraph BC 107 of Basis for Conclusion of ED 3 states that the straight-line amortisation of goodwill over an arbitrary period fails to provide useful information because it is doubtful about the usefulness of an amortisation charge that reflects the consumption of acquired goodwill, whilst the internally generated goodwill replacing it is not recognised. However, we believe that the amortisation of acquired goodwill properly represents the diminishment of goodwill that is the reflection of value created by the acquired entity prior to the business combination. On the other hand, current expenses are the results of additional expenditure to maintain the excess earning power by the combining entity. Those are entirely different by nature and the usefulness of the information is not lost. If such

expenses were considered as “doubling-up” and meaningless, the current accounting for property, plant and equipment would also need reconsideration, because depreciation costs and expenses for maintenance and repair would also be regarded as “doubling-up” as well. Some also argue against the amortization of goodwill on the ground that users of accounting information, such as analysts, ignore or exclude goodwill amortisation expense in their analysis. However, in similar ways, users often exclude from their analysis some items such as restructuring costs, interest expenses, research and development costs and so on, for their respective purposes. We do not believe it can be a sufficient reason for exclusion from financial statements.

CL 87

The GASB agrees that goodwill qualifies as an asset and therefore must be recognised as such. Given the general heterogeneity of goodwill, it follows therefrom that not all components of goodwill have asset character. While the GASB supports IASB’s impairment-only approach for conceptual reasons, the impairment test as proposed has practical weaknesses (for example, annual impairment testing is a complex process which raises implementation difficulties in many companies) and offers a large degree of judgement (for example, with respect to the projection of future cash flows). Therefore, the GASB proposes to adopt a transitional provision under which companies have the option between systematic amortisation and the impairment-only approach; in case of adopting systematic amortisation the useful life of goodwill should not exceed twenty years from initial recognition. This option should be exercised uniformly for all goodwills of a group irrespective of whether acquired before or after the date the new IFRS is issued. This transitional provision should be limited to five years from the date the new IFRS is issued. During this period efforts should be undertaken to eliminate the implementation difficulties of the impairment test and make it more robust in order to be able to abolish the transitional option.

CL 113

Yes, the MASB agrees that goodwill acquired in a business combination should be recognised as an asset. However, the MASB believes that the issues raised by the alternative views of 2 board members, as indicated in Appendix D, should be given due consideration. There is shortcoming in the impairment approach to goodwill, in particular, due to the inability to eliminate internally generated goodwill accruing after a business combination from the measure of goodwill’s implied value. This shortcoming would provide a “cushion” against the recognition of impairment losses of purchased goodwill by the “indirect” recognition of internally generated goodwill. In this case, it will be inconsistent with IAS 38, Intangible Assets that prohibits recognition of internally generated goodwill.

CL 69

The proposed treatment of a goodwill as of a non- amortized asset being tested annually for impairment was not unanimously supported by the FRC. On the one hand, the proposed treatment corresponds to the general inclination of IAS to fair value accounting. In addition, adoption of the proposed treatment as a part of the convergence between IAS and US GAAP will be useful

for companies listed on different public markets. Though, a whole range of factors exist causing doubtfulness in the appropriateness of the approach proposed.

1. The proposed treatment of goodwill seems to be relevant when assets and liabilities of entities are measured at fair value, but the existing IAS offer so- called ‘mixed measurement model’, including fairvaluing assets and liabilities along with measuring them at cost/amortized cost. Under these circumstances the change to accounting for goodwill at costs minus accumulated impairment losses, in substance very close to fair value accounting, looks a premature step. A logical question arises concerning other assets and liabilities, which are more ‘tangible’ than goodwill, but are accounted for at amortized cost.

2. Another problem which follows the conceptual weakness of the proposed treatment is complications of the practical use of this treatment. The goodwill is proposed to be tested for impairment annually. The whole concept of impairment when applying to goodwill may cause some uncertainties, including those associated with determining an impairment loss. And then, impairment test is quite a painstaking job, and objectivity of its output may be cause doubts. On the whole, the FRC expresses concern with respect a certain prematurity of the approach proposed for the goodwill accounting comparing to the one for all other assets and lia bilities measured at cost/amortizedcost. The FRC believes that the existing accounting treatment for goodwill is more consistent with the existing IAS concepts

Nationella normsättare mot avskrivningar

CL 21

We agree that goodwill should be recognized as an asset and subsequently measured at cost less accumulated impairment losses. We also support the definition of goodwill and the requirement to disclose a description of the factors that contribute to the recognition of goodwill. These have the potential to help demystify goodwill, provided that preparers can and do provide meaningful disclosures rather than boilerplate. Some fieldwork may be appropriate on how these disclosures can be

developed. Examples of appropriate disclosure would be useful.

CL 40

The IASRC agrees that goodwill acquired in a business combination should be recognised as an asset and should be accounted for after initial recognition at cost less any accumulated impairment losses without amortisation, except for the following minority opinion:

Goodwill should also be amortized over time. Impairment test requires many assumptions, which also cannot be assured easily. Therefore it should be encouraged to reduce a goodwill balance quickly, even if it is not easy to estimate the useful life of economic benefits.

CL 51

We agree that goodwill acquired in a business combination should be recognised by the acquirer as an

asset even though it is arguable that goodwill does not fulfil the definition in the framework. We believe accounting for goodwill at cost less any impairment losses is an acceptable method, if not conceptually well founded. In order to achieve convergence, the US GAAP solution should be implemented.

CL 102

The CCDG is of the view that the proposal is appropriate, but to the extent that theimpairment test is carried out with the rigour that the IASB has intended. There are some concerns about the practical problems associated with the proposed impairment tests. The results of impairment tests depend largely on management’s projections and assertions. This process could be abused and may result in goodwill remaining on balance sheets indefinitely or longer than it should be. Furthermore, the subjectivity of the impairment test would make it more difficult for users to assess the reasonableness of estimates, even with disclosure. This could lead to information being less comparable across companies and across different jurisdictions. The IASB may wish to consider proposing certain guidelines to minimise these practical difficulties.

CL 114 Ingaargument

Individer för avskrivningar

CL 92 ( flera individer)

We agree that goodwill meets the conceptual definition of an asset. We also agree that the measurement problems associated with estimation of the fair value of net assets and of overpayment at the time of the acquisition are not so severe that the goodwill should not be reflected on the balance sheet. We do not agree with the Board’s prohibition of periodic goodwill amortization. The Board argues that amortization does not provide useful information when firms are prohibited from recognizing the internally generated goodwill that replaces the amortized goodwill. We note, however, that the board does not permit explicit recognition of internally generated goodwill. The combined effect of the board’s rulings is that internally generated goodwill may be recognized for firms that have acquired subsidiaries, but not otherwise.

To resolve this inconsistency, the board would have to permit recognition of internally generated goodwill, or require systematic amortization of acquired goodwill. If the board believes that valuation of goodwill subsequent to acquisition is sufficiently reliable to perform impairment tests, then valuation methods should be sufficiently reliable to value internally generated