The IFRS 9 Financial Instruments new standard has been present for a while now and most audit services in Dubai, UAE have familiarized themselves with the new changes.
Here is a recap:
The IFRS 9 standards require audit firms in Dubai, UAE to recognize an impairment of all financial assets held at amortized cost and fair value via comprehensive income in ECL (expected credit losses).
There are two ways to do this:
1. General Approach
Company audit teams in Dubai must recognize impairment according to the status in which the financial asset is currently in. in life ECL or in 12-month ECL.
2. Simplified Approach
Financial audit specialists recognize the impairment in the amount of lifetime ECL and are not to determine the phase of a financial asset.
According to IFRS 9, there are specific types of assets that auditors can apply a simplified and general approach. That being said, a simplified approach isn’t available for loans, therefore, the general approach remains the most reliable approach. But before calculating ECL, company audit professionals should answer these crucial questions:
1. Should You Apply ECL Model On The Intercompany Loan?
As aforementioned, the ECL model applies to all financial assets held at debt only or amortized cost. As such, two important questions arise:
2. Is The Intercompany Loan A Financial Asset?
Dubai firms within the same group may provide financing to each other in various ways. At times, they agree to a formal agreement arranging a loan, while at times there is no formal agreement. The financing the parent offers to the subsidiary can represent a capital contribution.
So, the first task of the internal or external auditors is to find out whether the intercompany loan is a financial asset in IFRS 19. Or capital contribution recognized according to IAS 27.
If a loan is not a financial asset in IFRS 9, then forget about the ECL model and impairment. On the other hand, if a loan is a financial asset per IFRS 9, then the second option should be approached.
3. Is The Loan Held At FVOCI Or Amortized Cost?
According to IFRS 9, auditing services or company auditors should classify the loan as either at fair value through FVOCI or fair value through profit/loss. If the loan is classified as FVOCI or amortized cost, then the ECL must be calculated and recognized. Similarly, if the loan is at FVPL there is no need to calculate ECL.
Since the majority of loans are recorded as held at amortized cost, it’s not an automatic option. This is because the loan should meet the following criteria for amortized cost category:
Business Model
Here, the loan is held with the intention of gathering contractual cash flows.
Contractual Cash Flows
The loan’s cash flow represents individual payments of principal and interest on principal outstanding. While most intercompany loans meet the first criterion, there could be unique features of intercompany financing that may stop the loan from being regarded as at amortized cost.
For instance, assuming the parent company in Dubai, UAE offers a loan to its subsidiary to fund a construction project of townhouses. The repayable duration of the loan is 5 years. There is an annual interest of LIBOR + 0.2% and 2% of income collected from customers who purchase townhouses.
As such, internal auditors may not classify the loan as held at amortized cost, since 2% of the income of the cash flow does not represent interest or payment of principal.
Therefore, this intercompany loan is considered FVPL, and hence ECL model of impairment will not apply here.
So, if a company audit discovers a suspicious event such as non-recourse loans, prepayment options, or performance-based compensation, then it’s crucial to take note of the implications.
Applying ECL Model to Intragroup Loans in Dubai
Let’s assume an intercompany loan is a financial asset held at an amortized loan is a financial asset, meaning ECL must be calculated. As we mentioned before, we cannot use the simplified method.
Rather auditors must follow the general rule method which can prove difficult. So, the steps are as follows:
Determine the Phase the Loan is Sitting
If the general model is applied, then there needs to be an assessment of the credit risk of the intercompany loans at the end of the reporting period.
The loan can either be in:
- Loan with a considerable increase in credit score since the initial recognition.
- Performing low credit risk.
- Credit-impaired loan
Measure ECL
As soon as you understand the stage of the loan, the next step is to measure:
- 12 month ECL for loans in the first stage.
- Lifetime ECL for loans in the second and the third stage.
The procedure for measuring both ECL types is the same. The only major difference is the probability of default applied at calculation.
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