International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards
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for any renewal commissions that are required to be capitalised under IFRS 15 in a
similar manner. See 10.3.3.A and 10.3.3.B below for the FASB TRG’s discussion of how
an entity should determine the amortisation period of an asset recognised for the
incremental costs of obtaining a contract with a customer.
The revenue standard requires a significant change in practice for entities that have
historically amortised sales commissions over the non-cancellable term of the initial
contract. Under IFRS 15, entities are required to evaluate whether the period of benefit
is longer than the term of the initial contract. As discussed above, it is likely that an
entity would be required to amortise the capitalised sales commission cost over a period
longer than the initial contract if a renewal commission is not paid or a renewal
commission is paid that is not commensurate with the original commission.
It is important for entities to document the judgements they make when determining
the appropriate amortisation period and disclose the same in their financial statements.
IFRS 15 disclosure requirements (see 11.4.3 below) include judgements made in
determining the amounts of costs that are capitalised, the amortisation method chosen
and other quantitative disclosures.
10.3.3.A
Determining whether a commission on a renewal contract is
commensurate with the commission on the initial contract
At their November 2016 meeting, FASB TRG members generally agreed that the
commissions would have to be reasonably proportional to the contract values (e.g. 5%
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of both the initial and renewal contract values) to be considered commensurate. The
FASB TRG members also generally agreed that it would not be reasonable for an entity
to use a ‘level of effort’ analysis to determine whether a commission is commensurate.
For example, a 6% commission on an initial contract and a 2% commission on a renewal
would not be commensurate even if the declining commission rate corresponds to the
level of effort required to obtain the contracts.143
As discussed at 10.3.3 above, if the renewal commission is considered to be
commensurate with the commission on the initial contract, it would not be appropriate
to amortise any asset for the initial commission over a longer period than the initial
contract. In contrast, it likely would be appropriate to amortise the asset over a longer
period than the initial contract if the commissions are not considered to be
commensurate (such as in the example above). See 10.3.3.B below for discussion of how
an entity determines this longer amortisation period.
Although the TRG did not discuss this, entities would also need to evaluate whether any
expected subsequent renewal commissions are commensurate with prior renewal
commissions to determine the appropriate amortisation period for any renewal
commissions that are required to be capitalised under IFRS 15. Continuing the above
example, assume the original three-year contract (for which a 6% commission is paid)
and each subsequent renewal contract (for which a 2% renewal commission is paid) is
for a one-year term. If the entity expects to renew the contract in years two through
four and continue to pay a constant 2% commission upon each renewal, each renewal
commission would be considered commensurate. As a result, it is likely that the
appropriate amortisation period for each renewal required to be capitalised would be
one year. See 10.3.3.E below for discussion of when an entity would begin to amortise
an asset recognised for the incremental cost of obtaining a renewal contract.
10.3.3.B
Determining the amortisation period of an asset recognised for the
incremental costs of obtaining a contract with a customer
The FASB TRG members generally agreed that when an entity determines an amortisation
period that is consistent with the transfer to the customer of the goods or services to which
the asset relates, it must determine whether the capitalised contract costs relate only to
goods or services that will be transferred under the initial contract, or whether the costs
also relate to goods or services that will be transferred under a specific anticipated contract.
For example, if an entity only pays a commission based on the initial contract and does not
expect the customer to renew the contract (e.g. based on its past experience or other
relevant information), amortising the asset over the initial term would be appropriate.
However, if the entity’s past experience indicates that the customer is likely to renew
the contract, the amortisation period would be longer than the initial term if the renewal
commission is not ‘commensurate’ with the initial commission. See 10.3.3.A above for a
discussion of commensurate.
The FASB TRG members generally agreed that an entity needs to evaluate its facts and
circumstances to determine an appropriate amortisation period if it determines that the
period should extend beyond the initial contract term, because the commission on the
renewal contract is not commensurate with the commission on the initial contract. An
entity might reasonably conclude that its average customer term is the best estimate of
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the amortisation period that is consistent with the transfer of the goods or services to
which the asset relates (e.g. if the good or service does not change over time, such as a
health club membership). However, FASB TRG members generally agreed that this
approach is not required and that entities should not use this as a default. The FASB
TRG members noted that entities would use judgement that is similar to judgement used
historically when estimating the amortisation period for intangible assets (e.g. a
customer relationship intangible acquired in a business combination) and could consider
factors such as customer loyalty and how quickly their products and services change.144
Consider a technology entity that capitalises a commission earned on the sale of
software, which the entity estimates it will maintain and support for only the next five
years, and the estimated customer life is seven years. In evaluating the period of benefit,
the entity may reasonably conclude the capitalised commission should be amortised
over the five-year life of the software to which the commission relates.
10.3.3.C
Can an entity attribute the capitalised contract costs to the individual
performance obligations in the contract to determine the appropriate
amortisation period?
We believe an entity can attribute the capitalised contract costs to the individual
performance obligations in the contract to determine the appropriate amortisation
period, but it is not required to do so. Paragraph 99 of IFRS 15 states that the asset
recognised is amortised on a systematic basis ‘that is consistent with the transfer to the
customer of the goods or services to which the asset relates’. [IFRS 15.99]. An entity may
meet this objective by allocating the capitalised contract costs to performance
obligations on a relative basis (i.e. in proportion to the transaction price allocated to
each performance obligation) to determine the period of amortisation.145
Example 28.93: Allocation
of capitalised contract costs
A technology entity executes a contract for $600,000 for a perpetual software licence and one year of post-
contract support (PCS). Based on the stand-alone selling prices, the entity allocates $500,000 (83%) of the total
transaction price to the licence and $100,000 (17%) to the PCS. The entity pays a 4% commission to the sales
representative and has determined that the commission is required to be capitalised under IFRS 15 because it is
an incremental cost of obtaining the contract. The entity concludes that the $24,000 sales commission needs to
be allocated between the licence and the PCS and amortised over the expected period of benefit associated with
each of those performance obligations. The entity allocates $20,000 (83%) to the licence and $4,000 (17%) to
the PCS, consistent with the relative value of the performance obligations to the transaction price.
Other methods for allocating capitalised contract costs may be appropriate. For
example, an entity may also meet the objective by allocating specific capitalised
contract costs to individual performance obligations when the costs relate specifically
to certain goods or services.
An entity needs to have objective evidence to support a conclusion that a specified
amount of the costs relates to a specific performance obligation and consistently apply
any methods used for allocating capitalised contract costs to performance obligations.
In addition, as discussed above, an entity that attributes capitalised contract costs to
individual performance obligations needs to consider whether the amortisation period
for some or all of the performance obligations should extend beyond the original
contract (see 10.3.3 above).
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10.3.3.D
Over what period would an entity amortise a sales commission (that is
only paid once a threshold is met) that is determined to be an
incremental cost to obtain a contract?
The January 2015 TRG agenda paper indicated that two of the alternatives discussed
might meet the objective of amortising the costs on a systematic basis that is consistent
with the transfer to the customer of the goods or services to which the asset relates.
However, either alternative must be applied consistently to similar circumstances. In
one alternative, an entity allocated the capitalised costs to all of the contracts that
cumulatively resulted in the threshold being met and amortised the costs over the
expected customer relationship period of each of those contracts. In the other
alternative, an entity allocated the capitalised costs to the contract that resulted in the
threshold being met and amortised the costs over the expected customer relationship
period of that contract. The TRG agenda paper noted that the second alternative may
result in a counterintuitive answer if the commission paid upon obtaining the contract
that resulted in the threshold being met was large in relation to the transaction price for
only that contract. While the first alternative may be easier to apply and result in a more
intuitive answer than the second alternative in some situations, the TRG agenda paper
noted that either approach is acceptable. The TRG agenda paper did not contemplate
all possible alternatives. Consider the following example in the TRG agenda paper:146
Example 28.94: Amortisation of capitalised commission payments subject to a
threshold
An entity has a commission programme that increases the amount of commission a salesperson receives based
on how many contracts the salesperson has obtained during an annual period. In this example, the first
commission is paid when the first contract is signed. Subsequently, once a cumulative threshold number of
contracts is reached, a commission is paid on that threshold contract as a fixed escalating amount, taking into
account any commission already paid, as follows:
1 contract
£3,000 commission
10 contracts
£5,000 cumulative commission (including £3,000 already paid)
15 contracts
£10,000 cumulative commission (including £5,000 already paid)
Assume 11 new contracts are signed by a specific employee in that period.
As discussed in 10.3.1.B above, FASB TRG members generally agreed that commission payments subject to
a threshold are incremental costs of obtaining a contract with a customer and, therefore, the costs should be
capitalised when the entity incurs a liability to pay these commissions.
In one acceptable alternative, an entity estimates the total amount of commission that is expected to be paid for
the period and capitalises an equal amount as each contract is signed. In this example, because the entity estimates
that the employee will sign 11 new contracts during the period, it expects the total amount of commission to be
paid will be £5,000. The entity would capitalise £455 when each contract is signed (i.e. £5,000 cumulative
commission divided by the 11 contracts). The capitalised amount would be amortised over the expected customer
relationship period of each of those contracts. That is, the £455 capitalised for the first contract would be amortised
over the expected customer relationship period of the first contract and the £455 capitalised for the second contract
would be amortised over the expected customer relationship period of the second contract.
In the other acceptable alternative, an entity capitalises £3,000 in commission costs upon signing the first
contract. This amount would be amortised over the expected customer relationship period of that contract
(i.e. the first contract). The entity would not capitalise any additional costs upon signing the second contract
through to the ninth contract because the next commission ‘tier’ has not been met. Once the tenth contract is
signed, the entity capitalises an additional £2,000 in commission costs. This amount would be amortised over
the expected customer relationship period for that contract (i.e. the tenth contract).
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10.3.3.E
Determining when to begin to amortise an asset recognised for the
incremental cost of obtaining a renewal contract
As discussed in
10.3.3.A above, assets recognised for commensurate renewal
commissions paid are amortised over the term of the contract renewal with the expense
recognised as the entity transfers the related goods or services to the customer.
We believe that the amortisation of the renewal commission should not begin earlier
than the beginning of the renewal period. Consider the following illustration:
Example 28.95: Amortisation of a capitalised contract costs
On 1 January 2018, an entity enters into a three-year service contract with a customer that ends on
31 December 2020. Upon the customer signing the contract, the entity pays a sales employee a €50,000 sales
commission for obtaining the contract. On 30 September 2020, the entity negotiates a three-year renewal term
that will begin on 1 January 2021 and pays the sales employee a renewal commission that is commensurate
with the initial sales commission paid. Since the entity does not begin to transfer services under the contract
renewal until 1 January 2021, the entity would not begin amortising the asset related to the renewal
commission until 1 January 2021.
10.3.3.F
Presentation of capitalised c
ontract costs and related amortisation in the
statement of financial position and statement of profit and loss and other
comprehensive income
As discussed at 10.3.1 – 10.3.3 above, IFRS 15 requires incremental costs of obtaining a
contract and certain costs to fulfil a contract to be recognised as an asset and that asset
to be amortised on a systematic basis. Paragraph 128 of IFRS 15 requires separate
disclosure of closing balances and the amount of amortisation and impairment losses
recognised during the period (see 11.4.3 below). However, the standard is silent on the
classification of that asset and the related amortisation.
Under legacy IFRS, IAS 2 included the notion of work in progress (or ‘inventory’) of a
service provider. However, this was consequentially removed from IAS 2 and replaced
with the relevant requirements in IFRS 15. Furthermore, while these capitalised
contract cost assets are intangible, in nature, IAS 38 specifically excludes from its scope
intangible assets arising from contracts with customers that are recognised in
accordance with IFRS 15. [IAS 38.3(i)]. In the absence of a standard that specifically deals
with classification and presentation of contract costs, management would need to apply
the requirements in IAS 8 to select an appropriate accounting policy. [IAS 8.10-12].
In developing such an accounting policy, we believe that costs to obtain a contract and
costs to fulfil a contract need to be considered separately for the purpose of
presentation in financial statements.
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• Considering the nature of costs to obtain a contract and the lack of guidance in
IFRS, we believe an entity may choose to present these costs as either:
• a separate class of intangible assets in the statement of financial position and
its amortisation in the same line item as amortisation of intangible assets
within the scope of IAS 38 – this accounting treatment would be similar to
the previous practice of accounting for certain subscriber acquisitions costs
in the telecommunications industry; or
• a separate class of asset (similar in nature to work in progress, or ‘inventory’)
in the statement of financial position and its amortisation within cost of goods