which has been measured based on the year end share price of €2.00. This is lower than the share price
on which the IFRS 2 charge has been based. Therefore there is no requirement to allocate any deferred
tax to equity, and the balance of deferred tax in equity is reduced to nil. The balance of the total €69
movement in the deferred tax balance is allocated to profit or loss.
The net tax credit in profit or loss in year 2 of €72 (current tax credit €90, less deferred tax charge €18) can
be seen as representing:
Credit relating to IFRS 2 expense recognised in the period5
105
Charge relating to remeasurement of prior year deferred tax6
(33)
Total
72
5
In this case the tax credit recognised in profit or loss is not the ‘expected’ credit of €138 (IFRS 2 charge
of €460 @ 30%). This is because the current tax deduction for the shares vesting in year 2 and the
deferred tax deduction for the shares expected to vest in year 3 are based on the year-end share price of
€2.00, which is lower than the share values used to calculate the IFRS 2 charge (€2.80 and €2.50).
During the year, an IFRS 2 expense has been recognised for 75 ‘whole share equivalents’ in respect of
the shares vesting in year 2 (150 shares × 1/2) and 100 ‘whole share equivalents’ in respect of the shares
expected to vest in year 3 (300 shares × 1/3), a total of 175 ‘whole share equivalents’. Accordingly the
credit for the year is €105 (175 × €2.00 × 30%).
6
In year 1 the deferred tax credit (based on the year 1 year end share price of €3.60) recognised in profit
of loss in respect of the shares expected to vest in years 2 and 3 was €138. If this had been based on the
year 2 year end share price of €2.00 this would have been only €105. [150 × 1/2 × €2.00] + [300 × 1/3
× €2.00] = €350 × 30% = €105. €138 – €105 = €33.
Debit
Credit
Year 3
Current tax (statement of financial position)
540
Current tax (profit or loss)
225
Current tax (equity)7 315
Deferred tax (profit or loss)
120
Deferred tax (statement of financial position)8
120
7
The current tax deduction relates to the 300 shares vesting in year 1, for which the cumulative charge to
profit or loss is €750 (300 shares × €2.50). The tax deduction accounted for in profit or loss is therefore
restricted to 30% of €750 = €225.
8
The deferred tax asset, all of which was – on a cumulative basis – recognised in profit or loss, is
derecognised in profit or loss.
The net tax credit in profit or loss in year 3 of €105 (current tax credit €225, less deferred tax charge €120)
can be seen as representing:
Income
taxes
2471
Credit relating to IFRS 2 expense recognised in the period9
75
Credit relating to remeasurement of prior year deferred tax10
30
Total 105
9
€250 @ 30%.
10
The opening balance deferred tax asset of €120 is based on the year 2 share price of €2.00. If this had
been based on the year 3 share price of €6.00 it would have been €360. However, the amount recognised
in profit or loss would have been restricted to €150 – 30% of the cumulative expense at the end of year 2
of €500 (300 shares × €2.50 × 2/3). €150 – €120 = €30.
10.8.3
Allocation when more than one award is outstanding
As noted above, IAS 12 requires that, ‘where the amount of any tax deduction ... exceeds
the amount of the related cumulative remuneration expense, the current or deferred tax
associated with the excess should be recognised directly in equity’. Some have therefore
argued that, as drafted, IAS 12 requires the cumulative expense for all outstanding share
schemes to be compared in aggregate with the aggregate tax deduction for all share
schemes. Others argue that the comparison should be made for each scheme separately.
The effect of each treatment is illustrated in Example 29.51 below.
Example 29.51: Tax deductions for share-based payment transactions – more
than one award
An entity that pays tax at 30% has two outstanding share schemes, Scheme A and Scheme B. The entity receives
tax deductions for share-based payment transactions based on their intrinsic value at the date of exercise.
At the end of the reporting period, the cumulative expense charged for each scheme is £1 million. Scheme A
has a negative intrinsic value at the end of the reporting period, and is not expected to recover its value to the
extent that employees will exercise their options. Accordingly no deferred tax asset is recognised for Scheme A.
Scheme B has an intrinsic value of £1.5 million. The entity will therefore record a deferred tax asset of £450,000
(30% of £1.5 million), subject to the recognition criteria for deferred tax assets being satisfied.
Those who argue that comparison of share-based payment expense to tax deduction should be made on an
aggregated basis would conclude that, because the cumulative potential tax deduction of £1.5 million (which
relates only to Scheme B) is lower than the cumulative aggregate expense for both Scheme A and Scheme B
(£2 million), the deferred tax income should be recognised entirely in profit or loss.
However, those who argue that comparison of share-based payment expense to tax deduction should be made
on a discrete basis for each scheme would conclude that, because the cumulative tax deduction for Scheme B
(£1.5 million) is higher than the cumulative aggregate expense for Scheme B (£1 million), only £300,000 of
the deferred tax income (30% of £1 million) should be recognised in profit or loss, with the remaining
£150,000 recognised in equity.
In our view, the comparison must be made on a discrete scheme-by-scheme basis. As
noted at 10.8.2 above, it is clear from IAS 12 and the Basis for Conclusions to IFRS 2
that the IASB’s intention was to exclude from profit or loss any tax deduction that is
effectively given for the growth in fair value of an award that accrues after grant date.
[IAS 12.68C, IFRS 2.BC311-BC329]. This can be determined only on an award-by-award basis.
Moreover, IAS 12 requires the amount of any tax deduction to be accounted for in
equity when it ‘exceeds the amount of the related cumulative remuneration expense’.
In Example 29.51 above, the tax deduction on Scheme B cannot, in our view, be said to
be ‘related’ to the remuneration expense for Scheme A. Accordingly, the expense
relating to Scheme A is not relevant for determining the amount of tax income relating
to Scheme B that is required to be accounted for in equity.
2472 Chapter 29
It may also be that what is regarded as a single scheme may need to be further sub-
divided for the purposes of the comparison for reasons such as the following:
• where the same award is made to regular employees and also to top management,
the fair value of the options granted to each population may nevertheless be
different for the purposes of IFRS 2 given different exercise behaviours (see
Chapter 30 at 8.5.2.A);
• an aw
ard is made to employees which attracts tax deductions in more than one tax
jurisdiction; or
• an award is made in the same tax jurisdiction to employees in different entities,
not all of which are able to recognise a deferred tax asset.
10.8.4
Staggered exercise of awards
The example in IAS 12, the substance of which is included in Example 29.49 at 10.8.1
above, addresses a situation in which all vested awards are exercised simultaneously. In
practice, however, vested awards are often exercised at different dates.
Once an award under a given scheme has vested, and different awards in that scheme
are exercised at different times, the question arises as to whether the ‘cap’ on
recognition of the tax benefit in profit or loss should be calculated by reference to the
cumulative expense recognised in respect of the total number of awards vested, or in
respect only of as yet unexercised vested awards. In our view, where a tax deduction is
received on exercise, the calculation must be undertaken by reference to the
cumulative expense recognised for outstanding unexercised options. This is illustrated
by Example 29.52 below.
Example 29.52: Tax deductions for share-based payment transactions –
staggered exercise of award
At the start of year 1, an entity with a tax rate of 40% grants 20 options each to 5 employees. The options
have a fair value of €5 and vest at the end of year 2. The options vest in full. 25 are exercised at the end of
year 3 and 75 at the end of year 6. The entity is able to support the view that any deferred tax asset arising
before exercise will be recoverable, and may therefore be recognised in full.
Tax deductions are given in the year of exercise, based on the intrinsic value of the options at the date of
exercise. The intrinsic value of options at the end of each reporting period is as follows:
Year
Intrinsic value per option
€
1 3
2 8
3 8
4 1
5 7
6 6
On the basis of the information above:
• there would be an IFRS 2 charge of €250 in years 1 and 2 (20 options × 5 employees × €5 × 1/2 (portion
of vesting period)
• current and deferred tax assets should be recognised at the end of each period as follows:
Income
taxes
2473
Current tax
Number of Intrinsic value per
Total intrinsic
Tax effect
Year options exercised
option
value
at 40%
€
€
€
3 25 8
200
80
6 75 6
450
180
Deferred tax
Number of
Temporary
options
difference per
Total temporary
Tax effect
Year
outstanding
option
difference
at 40%
€
€
€
1 100 1.51
150
60
2 100 8
800
320
3 75 8
600
240
4 75 1
75
30
5 75 7
525
210
6 – 6
–
–
1
Intrinsic value €3 × 1/2 (expired portion of vesting period).
The required accounting entries for income taxes are as follows
Debit
Credit
€
€
Year 1
Deferred tax (statement of financial position)
60
Deferred tax (profit or loss)1 60
Year 2
Deferred tax (statement of financial position)2
260
Deferred tax (profit or loss)3 140
Deferred tax (equity)
120
Year 3
Deferred tax (profit or loss)4 50
Deferred tax (equity)
30
Deferred tax (statement of financial position)5
80
Current tax (statement of financial position)6
80
Current tax (profit or loss)4 50
Current tax (equity)
30
Year 4
Deferred tax (profit or loss)7 120
Deferred tax (equity)
90
Deferred tax (statement of financial position)8
210
Year 5
Deferred tax (statement of financial position)9
180
Deferred tax (profit or loss)10 120
Deferred tax (equity)
60
2474 Chapter 29
Debit
Credit
€
€
Year 6
Deferred tax (profit or loss)11 150
Deferred tax (equity)
60
Deferred tax (statement of financial position)
210
Current tax (statement of financial position)12
180
Current tax (profit or loss)13 150
Current tax (equity)
30
1
The cumulative tax income is based on expected deductions of €150, which is less than the cumulative IFRS 2 charge of
€250 (see above).
2
Year 2 year-end balance of €320 (see table above), less €60 recognised at end of year 1 = €140.
3
Cumulative deferred tax recognised in profit or loss must not exceed 40% × €500 (cumulative IFRS 2 charge) = €200. This
limits the credit for year 2 to €200 less the €60 credited in year 1 = €140.
4
Reversal of deferred tax income previously recognised in profit or loss for the 25 options exercised: 25 × €5 [IFRS 2 charge per option] × 40% = €50. This also represents the limit on the amount of current tax deduction that can be recognised in profit or loss.
5
Year 3 year-end balance of €240 (see table above), less €320 recognised at end of year 2 = €80.
6
25 options × €8 intrinsic value × 40% = €80.
In years 4 to 6, the amount of tax recognised in profit or loss is restricted by the cumulative IFRS 2 expense
of €375 for the 75 options left outstanding (75 options × €5).
7
Cumulative (maximum) tax deduction already recognised in profit or loss is €375 @ 40% = €150. This needs to be reduced
to €30 (year end deferred tax balance), giving rise to a charge of €150 – €30 = €120. This can be seen as representing the fact that, at the start of the period a cumulative potential tax deduction of €5 per award had been recognised in profit or loss.
At the end of the period it is expected that deductions of only €1 per award will be available. Therefore there is a loss to be recognised in profit or loss of 75 awards × (€5 – €1) × 40% = €120.
8
Year 4 year-end balance of €30 (see table above), less €240 recognised at end of year 3 = €(210).
9
Year 5 year-end balance of €210 (see table above), less €30 recognised at end of year 4 = €180.
10 Cumulative maximum tax deduction that can be recognised in profit or loss is €150 (see note 7). €30 cumulative deduction is brought forward, so that credit for period is limited to €150 – €30 =
€120.
11 Reversal of deferred tax previously recognised. The amount previously taken to profit or loss was limited to €150 (see notes 7 and 9).
12 75 options × €6 × 40% = €180.
13 Deduction restricted to €375 [IFRS 2 charge] × 40% = €150.
It will be noted that the cumulative effect of the above entries in profit or loss is as follows (tax income in brackets): Year Deferred
tax Current
tax
Total
€ €
€
1 (60)
(60)
2 (140)
(140)
3 50 (50)
–
4 120
120
5 (120)
(120)
6 150 (150)
–
Total
(200)
The cumulative effect of the above entries in equity is as follows (tax income in brackets):
Year Deferred
tax Current
tax
Total
€ €
€
1
–
2 (120)
(120)
3 30 (30)
–
4 90
90
5 (60)
(60)
6 60 (30)
30
Total
(60)
The overall effect is to take credit in profit or loss for the lower of total tax deductions actually received of
€260 (€80 in year 3 and €180 in year 6) and the tax deductions on the IFRS 2 expense of €200 (40% of €500).
The excess tax deductions of €60 are recognised in equity.
Income
taxes
2475
10.8.5
Replacement awards in a business combination
IFRS 3 contains some detailed provisions on the treatment of share-based payment
awards issued by an acquirer to replace awards made by the acquired entity before the
business combination occurred. These are discussed in Chapter 30 at 11.
IFRS 3 amended IAS 12 to include an illustrative example for the treatment of tax
deductions on such replacement awards, the substance of which is reproduced as
International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards Page 493
