Submission to IPSASB on Ipsass and Government Finance Statistics Reporting Guidelines

Submission to IPSASB on IPSASs and Government Finance Statistics Reporting Guidelines Consultation Paper.

General Comments

A majority of HoTARAC jurisdictions fully supports the project to harmonise International Public Sector Accounting Standards (IPSASs) and Government Finance Statistics (GFS) reporting. HoTARAC commends the Taskforce for the thorough analysis of the differences between IPSASs and GFS in the consultation paper (CP)and the development of strategies on how these can be reduced.

In the HoTARAC majority view, this project would be facilitated by including the requirements for harmonization in the IPSAS accounting framework. To this end, it strongly supports the option discussed in paragraphs 5.20 and 5.26 of withdrawing IPSAS 22 Disclosure of Financial Information About the General Government Sector and replacing it with the integrated approach taken under the Australian accounting standard AASB 1049 Whole of Government and General Government Sector Financial Reporting.

HoTARAC welcomes the approaches considered in paragraph 5.4 to develop a more systematic approach to minimising IPSAS/GFS differences and a majority of HoTARAC jurisdictions believe this structured approach would besupported by a flexible reporting format to assist the production of harmonized GFS/IPSAS financial reports (as per AASB 1049). This type of joint IPSAS/GFS presentation, subject to the outcome of the IPSASB conceptual framework on presentation, would allow flexibility to take account of jurisdictions’ circumstances and yet allow comparability. Further, the selection of GFS compliant options where these are available and the disclosure of remaining differences between the two frameworks would provide a useful approach to manage other differences. In addition to providing valuable information to users, the HoTARAC majority believes this will also facilitate the comparison with budget amounts required under IPSAS 24Presentation of Budget Information in Financial Statements and the strategy considered in the CP of guidance on integrating the IPSAS/GFS chart of accounts through the preparation of an integrated report.

A minority of HoTARAC jurisdictions does not support harmonising GFS and IPSAS reporting. The HoTARAC minority believes that the Australian experience in preparing harmonised statements under AASB 1049 have not met the needs of accountants or economists and does not see the value in the IPSASB following this approach as, in their view, it does not provide useful information to users.

HoTARAC agrees that SNA 2008 and changes to IPSAS will reduce the differences identified in International Public Sector Accounting Standards (IPSASs) and Statistical Bases of Financial Reporting: An Analysis of Differences and Recommendations for Convergence(the 2005 Research Report). However, consideration should be given to compiling a list of IPSAS/GFS differences that may have emerged since then as result of changes to IPSAS since 2005 to make the table of differences and strategies for their resolution as comprehensive as possible.

A HoTARAC majority recommends consideration of a long term objective, that the convergence projects on IPSAS/IFRS and IPSAS/GFS be integrated where possible and that reduction of IPSAS/GFS differences be considered in addition to converging with IFRS. For example, adoption of a comprehensive income approach for IPSAS 1 Presentation of Financial Statements, aligning with IAS 1 Presentation of Financial Statements, could assist in progressing issue B8 (and B9) by enabling the reinstatement of the IPSAS project to split comprehensive income into two components aligned with transactions and other economic flows. HoTARAC would further recommend that the IPSASB consider opportunities to harmonise IPSAS and GFS where a public sector issue that warrants departure from IFRS under the criteria of the document Process for Reviewing and Modifying IASB Documents is identified, and in the development of IPSASsfor public sector specific projects.

A HoTARAC minority does not fully support this recommendation. The minority is uncertain whether it is practicable for IPSASB to implement this recommendation given that GFS is a tool for macroeconomic assessment of Government performance, rather than the financial performance of individual entities.The HoTARAC minority would prefer the IPSASB to focus more on convergence with International Financial Reporting Standards (IFRS), with GFS harmonisation secondary to this goal.The majority of HoTARAC jurisdictions is of the view that the IPSASB should pursue GFS convergence to the extent this is based on sound conceptual principles for general purpose financial reports and does not see this as impacting on IFRS convergence. At least one jurisdiction consider the convergence of the IPSAS and GFS frameworks complementary.

Specific Matter for Comment 1(See Section 3 and Appendix B)

With respect to the summary in Table 2 of progress on reducing differences and the supporting detail in Appendix B:

(a)Do you agree that the issues categorized as resolved (Category A in Table 2) are indeed resolved?

Subject to below, HoTARAC agrees that the issues are resolved.

In respect of item A8: costs associated with R&D and other intangible assets, HoTARAC does not consider that this issue is resolved. While 2008 SNA reduces the nature of the differences between Accounting Standards and GFS, the treatment is not necessarily aligned. This is because IPSAS 31 Intangible assets expenses all research costs, but GFS capitalises strategic basic research. Also, the development costs capitalised under IPSAS 31 will not necessarily align with the 2008 SNA treatment, given that capitalisation under the Accounting Standards is subject to certain conditions, which are not contemplated in the SNA. In practice there may be no material difference if the 2008 SNA definition of an economic asset from which economic benefits are derived are applied as this is similar to the IPSAS asset recognition criteria; however, HoTARAC considers it premature to consider the issue resolved.

(b) Are there further differences between IPSASs and GFS reporting guidelines that should be added to this list? If so, please describe these.

Contractual guarantees and other derivatives financial instruments are recognised on the balance sheet under IPSAS 29: Financial Instruments: Recognition and Measurement, but are only recognised in limited circumstances under GFS. SNA 2008 proposes disclosure as a memorandum item, but reconciling differences remain.

Specific Matter for Comment 2(See paragraphs 4.11 to 4.17)

Do you agree that the IPSASB, in conjunction with the statistical community, should develop guidance on the development of integrated Charts of Accounts, which would include (i) an overview of the basic components of an integrated Chart of Accounts, and (ii) wider coverage such as that listed in paragraph 4.16 of this CP?

HoTARAC agrees that guidance on integrated Charts of Accounts be developed but only at a high level. HoTARAC notes that the requirement of SNA 2008 may be modified by national and regional statistical standard setters and guidance should be flexible enough to incorporate these regional variations. HoTARAC does not support the development of an integrated chart of accounts by IPSASB as it considers this outside the purview of a standard setter. Further itagrees with the disadvantages listed in 4.12 for developing a comprehensive Chart of Accounts for all countries. However, HoTARAC recommends a high level list of GFS/IPSAS divergences be maintained to assist chart of account mapping by governments. This would ensure that a common list is used by governments, hence enhancing report comparability.

Further, HoTARAC does not agree with paragraph 4.16 that the guidance should cover wider issues.

Specific Matter for Comment 3(See paragraphs 5.2 to 5.4)

(a) Do you think that the IPSASB should take a more systematic approach to reducing differencesbetween IPSASs and GFS reporting guidelines?

HoTARAC agrees and supports the overall approach of paragraph 5.4.

(b) If so, are there changes other than those listed in paragraph 5.4, which the IPSASB should consider adopting?

The majority of HoTARAC reiterates its general comments that the strategies listed in paragraph 5.4 would be enhanced by developing an integrated model along the lines of the Australian accounting standard AASB 1049.Aside from this, HoTARAC consider the list complete.

Specific Matter for Comment 4(See paragraphs 5.5 to 5.19)

Are there other areas where IPSAS changes could address GFS differences? Please describe these.

HoTARAC encourages the IPSASB to consider whether Items B2 Currency on Issue/seigniorage and B3Subscriptions to international organisations from Table 2, which provide opportunities to reduce differences through public sector specific changes, can be fast tracked to provide some ‘fast wins’ on the project.

Specific Matter for Comment 5 (See paragraphs 5.20 to 5.28 and page 39)

This CP describe three options concerning IPSAS 22: Option A, revisions to improve IPSAS 22; Option B, withdrawal of IPSAS 22 without replacement; and, Option C, replacement of IPSAS 22 with a new IPSAS.

(a) Are there any further IPSAS 22 options that should be considered? If so, what are these?

The majority of HoTARAC is of the view that the optimum option is C.

(b) Which one of the options do you consider that the IPSASB should consider adopting?

As mentioned above, the majority of HoTARAC supports Option C: adopting an integrated approach along the lines of the Australian accounting standard AASB 1049.

Preliminary View 1(See paragraphs 5.29 to 5.34)

The IPSASB should amend Study 14, Transition to the Accrual Basis of Accounting: Guidance for Governments and Government Entities, to include a chapter on IPSAS options that reduce differences with GFS reporting guidelines.

HoTARAC agrees with the principle of developing guidance on reducing differences with GFS, but recommendsthis guidance not be located in the transition document.The guidance is a useful tool for the ongoing process of governmentsreducing differences with GFS and will evolve as the strategies outlined in this CP are developed by the IPSASB.

Other Comments

Paragraph 6.11 states in respect of item C3: decommissioning/restoration costs, that revisions in the 2008 SNA that include decommissioning/restoration cost as costs incurred on acquisition and disposal removes a difference with IPSAS. HoTARAC agrees that the 2008 SNA revisions bring GFS closer to IPSAS 17 Property, plant and equipment, but notes that the asset and liability are offset under GFS, so the change will not fully resolve the difference. HoTARAC also understands the SNA 2008 does not extend the recognition of decommissioning/makegood cost treatment to other constructive liabilities that may be recognised under IPSAS.

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