AASB 13 Fair Value Measurement Confidential Implications for the not for profit and public sectors October 2013 AASB 13 Fair Value Measurement October 2013 Table of contents 1. 2. 3. 4. 5. 6. 7. 8. 9. 6.1 6.2 6.3 9.1 9.2 9.3 9.4 10. 11. 12. i Introduction .................................................................................................................. 1 Background ................................................................................................................... 1 Principal impacts ........................................................................................................... 2 The definition of fair value .............................................................................................. 2 Comparison with IVSC requirements ................................................................................ 3 The concept of highest and best use ................................................................................ 5 Assessment ............................................................................................................. 5 Valuing the highest and best use — alternative use and asset modifications.................... 7 Highest and best use and impairment testing .............................................................. 7 Unit of account and the valuation premise ........................................................................ 8 Assessing whether an appraisal complies with AASB 13 .................................................... 8 Appropriate valuation techniques .................................................................................... 9 Market approach .................................................................................................... 10 Income approach ................................................................................................... 10 Cost approach ....................................................................................................... 11 Other valuation concepts not compatible with fair value under AASB 13 ..................... 11 Applying the fair value hierarchy ................................................................................... 11 Expanded disclosure requirements ................................................................................ 13 Final thoughts ............................................................................................................. 14 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 1. Introduction AASB 13 Fair Value Measurement establishes a single, principles-based framework for fair value measurement when it is required or permitted by another Australian Accounting Standard (AAS). The purpose of this publication is to focus on the implications of AASB 13 for the not for profit (NFP) and public sectors. It includes a discussion of the critical issues regarding fair value measurement for non-financial assets held by entities in these sectors and illustrative examples of the valuation techniques and other considerations that will be required in practice. Public sector entities will need to pay particular attention to the new standard given the significant use of fair values in their financial statements. AASB 13 at a glance: ► AASB 13 does not change when an entity is required to use fair value. Instead, AASB 13 describes how to measure fair value when it is required or permitted by AAS. ► The definition of fair value in AASB 13 is consistent with market value as defined in International Valuation Standards (IVS). But, perhaps confusingly, it differs from the IVS definition of fair value. ► AASB 13 includes concepts of highest and best use, valuation premise and requires application of a fair value hierarchy. ► Management does need to be aware of the conceptual differences between AASB 13 and IVS or other valuation guidance to ensure any values used for financial reporting that are obtained from appraisals, whether external or internal, are consistent with the objective of fair value measurement in accordance with AASB 13. ► A challenge for any entity is to produce financial statements with disclosures that are useful for decision-making. AASB 13 significantly expands disclosure requirements – and the extent and nature of AASB 13 disclosures will rely heavily on the judgement of management. ► AASB 13 is effective for annual reporting periods commencing on or after 1 January 2013. The standard must be applied prospectively from the beginning of the annual period to which it is initially applied. In the first year of application, disclosures for comparative periods are not required. 2. Background International Financial reporting Standard IFRS 13 Fair Value Measurement was issued by the International Accounting Standards Board (IASB) in May 2011 and adopted by the Australian Accounting Standards Board (AASB) in September 2011 as AASB 13 Fair Value Measurement. The principles in AASB 13 are intended to increase the consistency and comparability of fair value estimates in financial reporting. The standard applies to all fair value measurements, when fair value is required or permitted by another AAS, with some limited exceptions. AASB 13 does not change when an entity is required to use fair value rather how it should be applied. It also sets out detailed requirements for disclosures related to fair value. 1 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 3. Principal impacts For NFP and public sector entities, the adoption of AASB 13 could result in significant changes to processes and procedures for determining fair value and significantly increase existing disclosures. Specifically, the cost and time of complying with these expanded qualitative and quantitative disclosure requirements by NFP and public sector entities are likely to increase. This is especially the case for public sector entities which are often required to carry their property, plant and equipment at fair value. While the requirement to determine fair value by reference to market participants is not new, the definition of fair value in AASB 13 now clarifies that fair value is a current exit price and the standard provides a framework for measuring fair value for financial reporting. The fair value framework set out in AASB 13 contains specific requirements relating to highest and best use, valuation premise, and the principal (or, in its absence, the most advantageous) market. This may require NFP and public sector entities and their appraisers to re-evaluate and reconsider their methods, assumptions, processes and procedures for determining fair value. It should be noted that the use of the Valuer General as an appraiser, as is common for public sector entities, or other external appraisers does not reduce management’s ultimate responsibility for the fair value measurements and related disclosures in the entity’s financial statements. Therefore, regardless of whether valuations are performed externally or internally, management must understand the methodologies and assumptions used in the valuations and determine whether the assumptions are reasonable and consistent with the requirements of AASB 13. NFP and public sector entities may be affected by AASB 13 in various aspects of their business as follows: ► Measuring the fair value of specialised public service assets ► Changes to valuation methods and their application ► Understanding valuations provided by valuation agents ► Compiling and disclosing information on the fair value of assets and liabilities including but not limited to significant assumptions, adjustments to unobservable inputs and qualitative and quantitative sensitivity analysis The principal elements of AASB 13 that may affect NFP and public sector entities are dealt with in the following sections. 4. The definition of fair value In AASB 13, fair value is defined as “the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement 1 date.” While the concepts are generally consistent with previous fair value measurement requirements, AASB 13’s framework provides additional clarification and application guidance. However, AASB 13 does not attempt to remove the judgment that is involved in estimating fair value. 1 2 AASB 13 Appendix A Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 AASB 13’s definition and its guidance in the fair value framework, clarify that: ► The definition of fair value in AASB 13 is a current exit price, not an entry price. ► The exit price for an asset or liability is conceptually different from its transaction price (an entry price). While exit and entry prices may be identical in many situations, the transaction price is not presumed to represent the fair value of an asset or liability on its initial recognition as measured in accordance with AASB 13. ► The exit price objective of a fair value measurement applies regardless of the reporting entity’s intent and/or ability to sell the asset or transfer the liability at the measurement date. ► Fair value is the exit price in the principal market (or in the absence of a principal market, the most advantageous market in which the reporting entity would transact). However, the price in the exit market should not be adjusted for transaction costs. ► In addition, fair value is a market-based measurement, not an entity-specific measurement, and, as such, is determined based on the assumptions that market participants would use in pricing the asset or liability. ► The objective of a fair value measurement does not change based on the level of activity in the exit market or the valuation technique(s) used. That is, fair value remains a market-based exit price that considers the current market conditions as at the measurement date, even if there has been a significant decrease in the volume and level of activity for the asset or liability. How we see it: On adoption of AASB 13, NFP and public sector entities will need to reconsider their previous fair value measurement practices in light of these clarifications. The effect of applying AASB 13 is likely to vary by entity. In some cases, it may only lead to a refinement of previous practice. However, in other cases, the change may be more significant. For example, if an entity previously did not consider a market participants assumptions when determining the fair value when revaluing its property, plant and equipment, adopting AASB 13 could result in a different fair value than it would have previously determined. The exit price concept may be difficult to apply when no active market exists for an asset or liability which would be common within NFP and public sector entities. 5. Comparison with IVSC requirements In late 2012, the International Valuation Standards Council (IVSC) released an exposure draft for Valuations of Specialised Public Service Assets (IVSC Specialised Public Service Assets Valuation ED) to provide guidance on the valuation of public sector assets given the use of different approaches in practice. The types of assets that are covered by this IVSC project include; buildings, structures, equipment and land used to provide transport, utilities and social, cultural and recreational services. The IVSC invited comments on the exposure draft up until 1 March 2013 and are currently undergoing re-deliberation. Management needs to be aware that there is a conceptual difference between the definition of fair value under AASB 13 and under the International Valuation Standards (IVS) which are often used by valuation agents. Accordingly, any values used for financial reporting that are obtained from appraisals, whether external or internal, should be consistent with the objective of a fair value measurement in accordance with AASB 13 (Further detail is provided in Section 8). 3 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 The definition in AASB 13 differs from IVS, which states in its revised IVS Framework: "Fair value is the estimated price for the transfer of an asset or liability between identified knowledgeable and willing parties that reflects the respective interests of those parties." And: "For purposes other than use in financial statements, fair value can be distinguished from market value. Fair value requires the assessment of the price that is fair between two identified parties taking into account the respective advantages or disadvantages that each will gain from the transaction. It is commonly applied in judicial contexts. In contrast, market value requires any advantages that would not be available to market participants generally to be disregarded. " How we see it: The definition of fair value in AASB 13 is consistent with market value as defined by the IVSC. But, perhaps confusingly, it differs from the IVS definition of fair value. AASB requires any advantages that would not be available to market participants generally to be disregarded which is different from the IVSC definition of fair value. Management needs to be aware of this conceptual difference to ensure any values used for financial reporting that are obtained from appraisals are consistent with AASB 13. The IVSC Specialised Public Service Assets Valuation ED introduces the concept of specialised public service assets which refer to specialised assets held to provide a public service. Such specialised public service assets may be either cash generating or non-cash generating depending on the specific facts and circumstances. The valuation considerations under the IVSC guidelines vary depending on the purpose of the valuation and the definition of fair value or market value being applied. The valuation considerations under AASB 13 for all assets must be based on the considerations of a market participant. Assets held by NFP and public sector entities to provide a service or other benefit to the general public may often be similar in nature or design to assets held for commercial objectives. Generally these assets are capable of being valued in the same way as an asset held for commercial purposes as there is a market with willing buyers available. An asset which may be noncash generating to an NFP or public sector entity may still have a possible commercial use from the perspective of a market participant. An example of a non-specialised asset held with a potential commercial use would be a building used as an administration office of a charitable organisation whereas an example of a specialised public service asset may be a park or a monument where a commercial benchmark is near impossible to determine. It should be noted that the current use is presumed to be its highest and best use (as discussed below) and as such the entity holding the asset is considered a market participant. Other factors may suggest a different use by other market participants would maximise the value of the asset. Market participants for non-cash generating assets are likely to be entities with similar profit (or not for profit) motives. The impact of AASB 13 in determining fair value of both types of assets used by NFP and public sector entities is included in the discussion below. 4 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 6. The concept of highest and best use The fair value measurement of a non-financial asset under AASB 13 must reflect the highest and best use of the asset from a market participant’s perspective. 6.1 Assessment Under AASB 13 an entity’s current use of an asset is presumed to be its highest and best use, unless market or other factors suggest that a different use of that asset by market participants would maximise its value. If such factors exist, management is required to consider all relevant information in determining whether the highest and best use of an asset is different from its current use at the 2 measurement date. AASB 13 states: “A fair value measurement of a non-financial asset takes into account a market participant’s ability to generate economic benefits by using the asset in its highest and best use or by selling it to another market participant that would use the asset in its highest and best use. The highest and best use of a non-financial asset takes into account the use of the asset that is physically possible, legally permissible and financially feasible, as follows: a. b. c. A use that is physically possible takes into account the physical characteristics of the asset that market participants would take into account when pricing the asset (e.g. the location or size of a property). A use that is legally permissible takes into account any legal restrictions on the use of the asset that market participants would take into account when pricing the asset (e.g. the zoning regulations applicable to a property or an obligation to provide a particular service with the asset). A use that is financially feasible takes into account whether a use of the asset that is physically possible and legally permissible generates adequate income or cash flows (taking into account the costs of converting the asset to that use) to produce an investment return that market participants would require from an investment in that asset put to that use.” Many public service assets or assets used by NFP entities may have uses which appear sub-optimal from a market participant perspective. An example is the use of land as a national park which may have a higher or more optimal use as a mine. However, AASB 13 makes it clear that determination of the highest and best use requires only the consideration of uses that are physically possible, legally permissible and financially feasible. Consequently, although mining in a designated national park may be physically possible and economically feasible, because there are mineral deposits present and a market for them, it may not be legally permissible because of the statutory protection of the natural environment and an obligation to maintain the existing natural state. If it is not legally permissible, the potential for mining would not be considered when determining the highest and best use. On the other hand, a NFP may hold property in a prime location that is being used as a research facility or administration building, which a market participant may consider would be best used as a residential development site. To the extent that there are no zoning or other restrictions on the use of the property, the alternate use of the building as a development site may be considered in the determination of highest and best use by a market participant. If, however, zoning restrictions do exist, re-zoning the land for residential development may require approval from the relevant authority. If that approval is usually given, this alternative use could also be deemed to be legally permissible. 2 5 AASB 13, paragraphs 27 and 28 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 In our view, an entity would need to have sufficient evidence to support its assumption about the potential for an alternative use, particularly in light of AASB 13’s presumption that the highest and best use is an asset’s current use. In the example above of re-zoning land for residential development, the entity’s belief that re-zoning was possible (or even likely) is unlikely to be sufficient evidence that the re-zoning is legally permissible. However, the fact that nearby areas had recently been re-zoned for residential use may provide additional evidence as to the likelihood that the land being measured could similarly be re-zoned. If obtaining re-zoning permission is not merely perfunctory, there may be a significant burden on the entity to prove that market participants would consider commercial use of the land ‘legally permissible’ Most often entities providing public services are mandated or directed by government or other legal requirements to continue to provide the services for which the asset is being used. Such restrictions are likely to validate the sub-optimal use of an asset where they are determined to be a restriction on the asset that would pass to market participants in a sale. 6.1.1 Restrictions on assets and liabilities AASB 13 indicates that the effect on fair value of a restriction on the sale or use of an asset will differ depending on whether the restriction is deemed to be a characteristic of the asset or the entity holding the asset. A restriction that would transfer with the asset in an assumed sale would generally be deemed a characteristic of the asset and therefore would likely be considered by market participants in pricing the asset. Conversely, a restriction that is specific to the entity holding the asset would not transfer with the asset in an assumed sale and therefore would not be considered when measuring fair value. Determining whether a restriction is a characteristic of the asset or of the entity holding the asset may be contractual in some cases. In other cases, this determination may require judgment based on the specific facts and circumstances. For example, a donor of land specifies that the land must be used by a sporting association as a playground in perpetuity. The land is also subject to an easement (a legal right that enables a utility 3 to run power lines across the land) . Upon review of relevant documentation, the association determines that the donor’s restriction would not transfer to market participants if the association sold the asset (i.e., the restriction on the use of the land is specific to the association). Furthermore, the association is not restricted from selling the land. Without the restriction on the use of the land, it could be used as a site for residential development. Under these circumstances, the effect of the restriction and the easement on the fair value measurement of the land is as follows: a. b. 3 6 Donor restriction on use of land — The donor restriction on the use of the land is specific to the association and thus would not transfer to market participants. Therefore, the fair value of the land would be measured based on the higher of its indicated value: i As a playground (i.e., the maximum value of the land through its use in combination with other assets) or ii As a residential development (i.e., the fair value of the asset would be maximised through its use by market participants on a stand-alone basis). Easement for utility lines — Because the easement for utility lines is a characteristic of the land, this easement would be transferred to market participants with the land. Therefore, the fair value of the land would include the effect of the easement, regardless of whether the land’s valuation premise is as a playground or as a site for residential development. AASB 13.IE29 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 6.2 Valuing the highest and best use — alternative use and asset modifications When management has determined that the highest and best use of an asset is something other than its current use, certain valuation matters must be considered. Appraisals that reflect the effect of a reasonably anticipated change in what is legally permissible should be carefully evaluated. If the appraised value assumes that a change in use can be obtained, the valuation should reflect market participant assumptions regarding the cost and profit margin associated with obtaining approval for the change in use and transforming the asset, in addition to capturing the risk that the approval might not be granted (i.e., uncertainty regarding the probability and timing of the approval). An entity should also evaluate inputs used in the valuation of similar assets that do not have similar uncertainties, for example, uncertainty related to obtaining a permit. Expectations about future improvements or modifications to be made on an asset to reflect its highest and best use may be considered in the appraisal, e.g., the renovation of a heritage property or the conversion of an administration public service office into residential property development, but only if and when other market participants would also consider making these investments. The cash flows used should reflect only the cash flows that market participants would take into account when assessing fair value. This includes both the type of cash flows (e.g., future capital expenditure) and the estimated amount of cash flows. Only if this hurdle is met would the fair value of the asset be determined on the basis of the expected future cash flows of the renovated or transformed asset. However, as noted above, when this is the case, the fair value measurement needs to also capture the cost and profit margin that market participants would demand for transforming the asset. The fair value measurement assumes that the asset is sold in its current condition with any renovation or transformation being performed by the market participants who acquire the asset. Accordingly, management should evaluate whether transformation costs from the transformation process have been included in the appraised value and if the inclusion of such amounts is appropriate. 6.3 Highest and best use and impairment testing The highest and best use concept is not only relevant for assets carried at fair value. It is also relevant to the impairment testing of assets carried at cost and other non-financial assets held by public sector or NFP entities when impairment is measured on the basis of fair value less costs of disposal. AASB 136 Impairment of Assets (AASB 136) stipulates that impairment arises if the recoverable amount of an asset is lower than its carrying value. The recoverable amount is determined as the higher of an asset’s or cash generating unit’s fair value less costs of disposal and its value in use. It is not necessary to determine both values. If either exceeds an asset’s carrying amount, it is not considered impaired. Fair value, measured as part of an impairment test, must be measured in accordance with AASB 13. Therefore, assumptions must reflect what market participants would use when pricing the asset, including assumptions about the highest and best use of the asset. Determining value in use requires an assessment of the future cash inflows and outflows of an asset, which is clearly problematic for assets held by NFP entities or which do not generate cash flows. Consequently, AASB 136 includes an exception by permitting NFP entities to determine value in use based on the depreciated replacement cost of the asset. Depreciated replacement cost (DRC) is defined in AASB 136 as the current replacement cost less accumulated depreciation to reflect the already consumed future economic benefits of the asset. It cannot be assumed that DRC can be applied to other fair value measurements under AASB 13. 7 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 7. Unit of account and the valuation premise In valuing non-financial assets under AASB 13, the concepts of unit of account and valuation premise are distinct, even though both concepts deal with determining the appropriate level of aggregation (or disaggregation) for assets and liabilities. The unit of account identifies what is being measured for financial reporting and drives the level of aggregation (or disaggregation) for presentation and disclosure purposes (e.g., whether categorisation within the fair value hierarchy is determined at the individual asset level or for a group of assets). Valuation premise is a valuation concept that addresses how a non-financial asset derives its maximum value to market participants, either on a stand-alone basis or through its use in combination with other assets and liabilities. The highest and best use of an asset establishes the valuation premise used to measure the fair value of an asset. Depending on its highest and best use, the fair value of the non-financial asset will either be measured based on the value it would derive on a stand-alone basis or in combination with other assets or other assets and liabilities under the asset’s valuation premise. If the fair value of an asset for which highest and best use is its use in combination with other assets and/or liabilities, fair value is determined assuming the asset is sold for use by market participants in combination with those other complementary assets and/or liabilities. Market participants are assumed to hold those complementary assets and/or liabilities already. In contrast, the fair value of an asset that provides maximum value on a stand-alone basis is measured based on the price that would be received to sell that asset on a stand-alone basis. To illustrate, the valuation premise of a specialised piece of equipment used in a research facility may be that its value is derived in combination with another complementary piece of equipment. In this case the fair value of the specialised piece of equipment would be determined based on a buyer having access to or being able to obtain the complementary piece of equipment. AASB 13 contains guidance on the treatment of specialised non-financial assets that may have a significant value when used together with other assets and little value if considered without the complementary asset. If considered in isolation, such an asset might be valued at scrap value (particularly if observable market transactions show no value), but this would not reflect the value an entity expects to generate. AASB 13 clarifies that, in such a situation, the scrap value of an asset would be irrelevant since the valuation premise assumes the asset would be used in combination with other assets. Therefore, the exit price value should reflect the sale to a market participant that has or can obtain the complementary assets. In effect, the market participant steps into the shoes of the entity that holds the specialised asset. 8. Assessing whether an appraisal complies with AASB 13 An assessment should be undertaken by management of any third party appraisals, including any appraisals by the Valuer General, to determine that the appraised value is an appropriate measure of fair value for financial reporting (i.e., the appraisal has been performed in accordance with the principles of AASB 13). As a result, management may conclude that an adjustment to the valuation is necessary to comply with AASB 13. Assessing compliance with AASB 13 would include, but is not limited to, determining whether: ► 8 The appraisal value contemplates that the asset is sold in an orderly transaction as at the measurement date, taking into consideration current market conditions (i.e., a fair value measurement inherently assumes that as of the measurement date market participants have the knowledge and awareness of the asset that would be customary in a market transaction, despite the fact that in actuality this process may not have yet begun). Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 ► The principal market (or, in its absence, the most advantageous market) has been appropriately considered. ► Appropriate market participants (or characteristics of market participants) have been identified and the assumptions that market participants would utilise in pricing the asset have been used. ► Adjustments to valuation input data are (a) based on observable or unobservable inputs, or (b) significant to the overall fair value measurement. ► All appropriate valuation approaches and techniques have been used; if multiple valuation techniques are used, the merits of each valuation technique and the underlying assumptions embedded in each of the techniques should be considered in evaluating and assessing the results. ► Appropriate judgement has been applied in determining the highest and best use; in situations where the highest and best use is not its current use, whether the expected future cash flows associated with this use are appropriately adjusted for the cash out flows associated with the transformation or renovation costs adjusted for a normal profit margin. ► All relevant disclosures have been provided. 9. Appropriate valuation techniques AASB 13 does not prescribe which valuation technique must be used in a particular circumstance. The valuation technique used to measure fair value should be appropriate for the circumstances, and one for which sufficient data is available considering highest and best use and the valuation premise. In addition, AASB 13 does not prioritise the use of one valuation technique over another or require the use of only one technique. Instead, the standard establishes a hierarchy for the inputs used in those valuation techniques, requiring an entity to maximise observable inputs and minimise the use of unobservable inputs (the fair value hierarchy). The decision to use more than one valuation technique, or place more weight on one indication of value over another, depends on the specific facts and circumstances. But, in all cases, a fair value measurement should maximise the use of observable market inputs. When available, observable market transactions should be considered in the determination of fair value, unless these transactions are determined not to be orderly. The objective is to use the valuation technique (or combination of valuation techniques) that is appropriate in the circumstances and for which there is sufficient data. The determination of the valuation technique(s) to be used requires significant judgement and will be dependent on the specific characteristics of the asset or liability being measured and the principal (or most advantageous) market in which market participants would transact for the asset or liability. AASB 13 recognises three valuation approaches to measure fair value: ► Market approach: based on market transactions involving identical or similar assets or liabilities. ► Income approach: based on future amounts (e.g., cash flows or income and expenses) that are converted (discounted) to a single present amount. ► Cost approach: based on the amount required to replace the service potential of an asset. 9 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 9.1 Market approach Extract from AASB 13 B5. The market approach uses prices and other relevant information generated by market transactions involving identical or comparable (ie similar) assets, liabilities or a group of assets and liabilities, such as a business. Valuation techniques consistent with the market approach use prices and other market data derived from observed transactions for the same or similar assets. Assets used by NFP and public sector entities, which also have a commercial use, are likely to be valued based on observable market values considering the highest and best use requirements of AASB 13. For example, an office building used for a public service or as an administration building by a government agency in close proximity to other offices used for commercial purposes would be competing with commercial users for that office space within the market. As a result the office building’s fair value could be determined based on sales of comparable buildings. On the other hand, specialised assets are rarely, if ever, exchanged between willing sellers and willing buyers. In the public sector, such assets are normally only transferred between public sector entities as part of restructure of administrative arrangements or transferred to the private sector as part of a privatisation. The specialised features, whether they be the design, specification or location of the asset mean that reliable comparisons can rarely be made with the prices of similar assets in the market. 9.2 Income approach Extract from AASB 13 B10. The income approach converts future amounts (eg cash flows or income and expenses) to a single current (ie discounted) amount. When the income approach is used, the fair value measurement reflects current market expectations about those future amounts. B11. Those valuation techniques include, for example, the following: (a) present value techniques... (b) option pricing models... A fair value measurement using the income approach will reflect current market expectations about future cash flows or income and expenses. For non-cash generating specialised public service assets, the valuation implication of the asset being held or operated to provide a public service is that public services often either do not generate income to the owner of the asset or if they do, that income is subsidised by public funds. As such, application of an income approach to fair valuation may not be appropriate. However certain specialised public service assets held by NFP and public service entities may be operated and compete in a commercial environment (such as certain transport and utilities infrastructure) and in those cases an income approach to valuation may be an appropriate valuation approach as the assets are cash generating and a market participant could derive cash-flows from the asset. The most common method under the income approach for assets held by NFP and public service entities that generate cash flows is discounted cash flow (DCF). A government owned business enterprise such as a power station held by a public sector entity would typically be valued using the DCF approach. However, such an approach values, by default, the underlying tangible and intangible assets and liabilities used as part of that business enterprise. The underlying tangible assets such as land, buildings and plant & equipment could be valued using either the market or cost approach as alternate methods if income is not generated from the asset. 10 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 9.3 Cost approach Extract from AASB 13 B8. The cost approach reflects the amount that would be required currently to replace the service capacity of an asset (often referred to as current replacement cost). B9. From the perspective of a market participant seller, the price that would be received for the asset is based on the cost to a market participant buyer to acquire or construct a substitute asset of comparable utility, adjusted for obsolescence. That is because a market participant buyer would not pay more for an asset than the amount for which it could replace the service capacity of that asset. Obsolescence encompasses physical deterioration, functional (technological) obsolescence and economic (external) obsolescence and is broader than depreciation for financial reporting purposes (an allocation of historical cost) or tax purposes (using specified service lives). In many cases the current replacement cost method is used to measure the fair value of tangible assets that are used in combination with other assets or with other assets and liabilities. AASB 13 refers to current replacement cost which uses various valuation methods based on cost as the primary input and should not be confused with actual or historic cost. From the perspective of a market participant seller, the price that would be received for the asset is based on the cost to a market participant buyer to acquire or construct a substitute asset of comparable utility, adjusted for physical deterioration and all forms of obsolescence. This concept is broader than depreciation for accounting or tax and considers physical deterioration, functional (which is generally internal to the asset) or economic obsolescence (which is generally external to the asset). The value of specialised public service assets are often measured using the cost approach. It is normally used when there is no evidence of comparable assets or no identified income stream generated by the asset. Examples could include fair valuations of hospitals, roads or libraries. 9.4 Other valuation concepts not compatible with fair value under AASB 13 The IVSC Specialised Public Service Assets Valuation ED discusses the valuation concepts of investment value and social services value. Investment value measures the benefits the NFP entity can derive from an asset whilst social value refers to the potential economic impact of a public service asset. These valuation concepts may be used by NFP entities for various purposes such as management reporting and feasibility analysis, although they should not be included in the determination of fair value under AASB 13. For example, an office space used as a soup kitchen provides an immense value to the community although this value cannot be considered in the valuation of the office space in its current use. Investment value would be a measure used by an entity, such as target return on capital invested or various measures of the benefit the entity can derive from the service provided. Such valuation techniques are not representative of a market participant’s perspective and thus would not be used to measure fair value under AASB 13. 10. Applying the fair value hierarchy When measuring fair value, an entity is required to maximise the use of relevant observable inputs and minimise the use of unobservable inputs. AASB 13 includes a fair value hierarchy that prioritises the inputs in a fair value measurement. The inputs used in measuring fair value drive categorisation of the fair value measurement (as a whole) within the fair value hierarchy. Significant differences in disclosure requirements apply to fair value measurements categorised within each level of the hierarchy in order to provide users with insight into the reliability of the fair value measurement. 11 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 Table 1: Fair value hierarchy Level 1 Quoted prices, which are not adjusted, in an active market for identical assets and liabilities that the entity can access at the measurement date Level 2 Inputs, other than quoted prices in Level 1, that are observable, either directly or indirectly Level 3 Unobservable inputs Regardless of whether the valuation was compiled internally or externally, management should review and understand the inputs used in the valuation to determine the appropriate classification of those inputs in the fair value hierarchy. A quoted price will not be considered to be level 1 unless the market for the asset is active and the quoted price is for an identical asset to that being valued. In most cases, fair value measurements of non-financial assets, would be categorised as level 2 or 3 on the basis that it is rare for identical assets to be actively traded. Level 2 inputs include quoted prices (in non-active markets or in active markets for similar, but not identical assets or liabilities), observable inputs other than quoted prices and inputs that are not directly observable, but are corroborated by observable market data. However, when an observable input is adjusted to reflect differences between the asset being valued and the observed transaction, depending on the significance of the adjustment it may cause the measurement to be categorised as a Level 3 measurement instead of a Level 2 measurement. Possible examples of fair value measurements categorised within Level 2 might include: ► A building used by a NFP entity where a sufficient number of comparable buildings (considering architectural style, property size, location, permissible use) and a sufficient volume of recent sales transactions prices could be observed ► Equipment used in a research facility for which comparable equipment is available in the market and there is a sufficient volume of recent sales transactions for which prices could be observed Where the valuation is based on unobservable inputs, categorisation will be in level 3 of the fair value hierarchy. Examples of such assets may include transport and utility infrastructure such as electricity, gas and ports which could be valued based on the income approach using a discounted cash flow method. Other examples would be a hospital or prison which could be valued using the cost approach with appropriate adjustments to reflect the asset’s service potential. When selecting the most appropriate inputs to a fair value measurement from multiple available values, those that maximise the use of observable data, rather than unobservable data, must be selected. Care should, therefore, be taken in using a cost approach to measure fair value without appropriate consideration of the available observable inputs. Even in a market that is inactive, a NFP or public sector entity should not presume that the transactions in that market do not represent fair value or that the market is not orderly. Entities will need to consider the individual facts and circumstances in making this assessment. 12 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 11. Expanded disclosure requirements The IASB significantly expanded the required disclosures related to fair value measurement to enable users of financial statements to understand the valuation techniques and inputs used to develop fair value measurements. For each of the disclosure requirements under AASB 13, Table 2 below indicates whether it is currently required under AAS. Although the table below focuses on a comparison between the disclosure requirements in AASB 116 and AASB 13 and does not consider any other standards where fair value disclosures may be currently required, it is important to note that, in most cases where fair value is used or disclosed, the disclosure requirements have been significantly expanded as compared to current requirements. Table 2: Disclosure requirements Disclosures AASB 116 AASB 13 Fair value at the end of the reporting period The methods and significant assumptions applied in estimating fair value Note: The requirements included in AASB 116 have been expanded in AASB 13 Level of the fair value hierarchy within which the fair value measurement in its entirety is categorised For Level 2 and Level 3 measurements, valuation technique and the inputs used, and changes in the valuation technique, if applicable, and the reasons for those changes For Level 3 measurements, quantitative information regarding the significant unobservable inputs Amount of transfers between Level 1 and Level 2, the reasons and related accounting policies For Level 3 measurements, reconciliation from the opening balances to the closing balances (including gains and losses, purchases, sales, issues, settlements, transfers in and out of Level 3 and reasons and policies for transfer and where all such amounts are recognised) For Level 3 measurements, the total gains or losses included in profit or loss that are attributable to the change in unrealised gains or losses relating to those assets and liabilities held at the reporting date, and a description of where such amounts are recognised For Level 3 measurements, a description of the valuation processes used by the entity For Level 3 measurements, a narrative description of the sensitivity of the fair value measurement to changes in unobservable inputs if a change in those inputs might result in a significantly different amount and, if applicable, a description of interrelationships between those inputs and other unobservable inputs and of how they might magnify or mitigate the effect of changes in the unobservable inputs If the highest and best use of a non-financial asset differs from its current use, disclose that fact and the reason for it Given the specialised nature of many assets used in the NFP and public sector, it is considered that fair value measurements categorised within level 3 of the hierarchy will be more prevalent and will, therefore, require disclosure of a sensitivity analysis and a description of the interrelationship between inputs of the fair value amount measured. In addition, AASB 13 disclosures are required for each class of assets (and liabilities). AASB 13 requires these classes of assets (and liabilities) be determined based on: a. The nature, characteristics and risks of the asset or liability b. The level of the fair value hierarchy within which the fair value measurement is categorised 13 Implications for the not for profit and public sectors AASB 13 Fair Value Measurement October 2013 The determination of the appropriate class of assets for the purposes of disclosure will require significant judgment. The number of classes may need to be greater for fair value measurements categorised within Level 3 of the fair value hierarchy because those measurements have a greater degree of uncertainty and subjectivity. As such, a class of assets and liabilities may require greater disaggregation for the purposes of AASB 13 disclosure than the line items presented in the statement of financial position or in the notes to the financial statements. For example, a public sector entity may disclose buildings as a single class of asset in its property, plant and equipment note, however the AASB 13 disclosures may be required for individual properties or groups of properties if the level of the fair value hierarchy within which their fair value was measured is level 2 for some and level 3 for others. However, the entity will be required to provide information sufficient to permit reconciliation to the line items presented in the statement of financial position. 12. Final thoughts While many of the concepts in AASB 13 are consistent with current practice, certain principles and disclosure requirements could have a significant impact on NFP and public sector entities. Careful consideration is required to identify situations in which there may be a significant change to current practice. NFP and public sector entities may be affected by AASB 13 in various aspects of their business as detailed above in determining the fair value of specialised public service assets. ► Implications of the ‘highest and best use’ concept ► Measuring the fair value of specialised public service assets ► Changes to valuation methods and their application ► Understanding valuations provided by valuation agents ► Compiling and disclosing information on the fair value of assets and liabilities including but not limited to significant assumptions, adjustments to unobservable inputs and qualitative and quantitative sensitivity analysis Key contacts National Michael Wright Oceania Managing Partner Assurance Tel: +61 2 8295 6450 Lynda Tomkins Australian IFRS Leader Tel: +61 7 3243 3711 Adelaide Mark Phelps Tel: +61 8 8417 1660 Brisbane Mark Hayward Tel: +61 7 3011 3385 Canberra James Palmer Tel: +61 2 6246 1520 Melbourne Glenn Carmody Tel: +61 3 9288 8467 14 Implications for the not for profit and public sectors Sydney John Robinson Tel: +61 2 8295 6536 Perth Greg Meyerowitz Tel: +61 8 9429 2225 EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organisation, please visit ey.com. © 2013 Ernst & Young, Australia. All Rights Reserved. APAC no. AUNZ00000383 ED MMYY This communication provides general information which is current at the time of production. The information contained in this communication does not constitute advice and should not be relied on as such. 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