International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards

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  foreign exchange forward contracts, but applies equally to forward contracts with

  respect to other risks, such as commodity or interest rate. [IFRS 9.BC6.416]. We would also

  expect the treatment to apply to a fixed-for-fixed currency swap as arguably that is no

  more than a series of forward contracts applying a blended rate.

  Just like for the accounting for the time value of an option, the accounting for the

  forward element as a cost of hedging applies only to the extent of the so-called ‘aligned’

  forward element (i.e. only to the extent that the forward element relates to the hedged

  item – see 7.1.2 above). [IFRS 9.B6.5.37]. We believe it is acceptable for the type of aligned

  instrument to match that of the actual instrument where that makes sense, for example

  if a fixed-for-fixed cross currency swap is the hedging instrument it is likely to be

  acceptable for the aligned instrument to also be a fixed-for-fixed cross currency swap.

  The above discussion focuses on the costs of hedging accounting where the forward

  element is excluded from the hedging instrument. It should be noted that most foreign

  exchange instruments also include foreign currency basis spreads which can also be

  excluded from hedging instruments (see 7.5.3 below).

  7.5.2.A

  Forward element of forward contracts in a net investment hedge

  It is possible to designate the forward rate as the hedged risk in a net investment hedge

  (see 7.3.3 above), but for some entities it may be preferable to designate only the spot

  rate, so a question arises as to the accounting treatment of the excluded forward element

  in a net investment hedge. The costs of hedging guidance (see 7.5 above) is not specific

  to a particular type of hedge relationship, accordingly it can be applied to fair value,

  cash flow and net investment hedges (see 5 above). In fact, the application guidance to

  IFRS 9, includes a net investment hedge as an example of a fact pattern for which the

  costs of hedging accounting could be applied. The example given is of a time-related

  hedge: a net investment that is hedged for 18 months using a foreign-exchange option,

  which would result in allocating the time value of the option over that 18 month period.

  [IFRS 9.B6.5.29(b)]. This guidance also confirms that for the purposes of accounting for the

  costs of hedging, a hedge of a net investment would ordinarily be treated as time-period

  related hedge, in particular as in most cases there is no expectation of a hedged

  transaction (see 7.5.1 above).

  4116 Chapter 49

  The application of the costs of hedging guidance to the excluded forward element of a

  forward contract is not an accounting policy choice, but an election for each

  designation. [IFRS 9.6.5.16]. If the costs of hedging guidance is not applied, designating the

  spot element of a forward contract in a net investment hedge results in the forward

  element being accounted for at fair value through profit or loss (see 3.6.5 above).

  The costs of hedging accounting can only be applied to the extent that it relates to the

  hedged item, this is achieved by comparison with an ‘aligned hedging instrument’

  (see 7.5.1.A above). [IFRS 9.6.5.15]. The aligned hedging instrument should match the

  critical terms of the hedged item. [IFRS 9.B6.5.36]. Where the hedged item is a financial

  instrument or a forecast transaction for which specific terms exist, determining the

  aligned hedging instrument is relatively straight forward. However given that a net

  investment hedge is largely an accounting concept, identifying appropriate terms for an

  aligned hedging instrument is more judgemental. Given that it is possible to designate

  the forward rate as the hedged risk in a net investment hedge and assess effectiveness

  using a hypothetical forward contract (see 7.3.3.A above), it is relatively easy to conclude

  that an aligned hedging instrument for a net investment hedge could similarly be a

  simple forward. It is harder to conclude that a cross currency swap for which there are

  periodic settlements is an aligned instrument that matches the critical terms of the

  hedged net investment (see 7.3.3.B above).

  Although the above analysis focuses on accounting for any excluded forward element in a

  net investment hedge, it is also relevant to foreign currency basis spreads (see 7.5.3 below).

  7.5.3

  Foreign currency basis spreads in financial instruments

  The foreign currency basis spread, a phenomenon that became very significant during

  the financial crisis, is a charge embedded in financial instruments that compensates for

  aspects such as country and liquidity risk as well as demand and supply factors. This

  charge only applies to transactions involving the exchange of foreign currencies at a

  future point in time (as, for example, in currency forward contracts or cross currency

  interest rate swaps (CCIRS)).

  Historically, the difference between the spot and forward prices of currency forward

  contracts and CCIRS represented the differential between the interest rates of the two

  currencies involved. However, basis spreads increased significantly during the financial

  crisis and during the subsequent sovereign debt crisis, and have become a significant

  and volatile component of the pricing of longer term forward contracts and CCIRS.

  The standard cites currency basis spread as an example of an element that is only

  present in the hedging instrument, but not in a hedged item that is a single currency

  instrument. Consequently, this would result in some ineffectiveness even when using a

  hypothetical derivative for measuring ineffectiveness (see 7.4.4.A above). [IFRS 9.B6.5.5].

  When using a foreign currency forward contract or a CCIRS in a hedge, the foreign currency

  basis spread is an unavoidable ‘cost’ of the hedging instrument. Hence IFRS 9 permits the

  accounting for foreign currency basis spreads as a ‘cost of hedging’, similar to the time value

  of options and the forward element of forward contracts.17 This means that, when

  designating a hedging instrument, an entity may exclude the foreign currency basis spread

  and account for it separately in the same way as the accounting for time value of options or

  the forward element of the forward rate, as described in 7.5.1 and 7.5.2 above. [IFRS 9.6.5.16].

  Financial instruments: Hedge accounting 4117

  Consistent with the approach to designation of the forward element as a cost of hedging,

  designation of foreign currency basis as a cost of hedging is not an accounting policy

  choice, but an election for each designation. However, if an entity designates the entire

  hedging instrument, fair value changes due to changes in the foreign currency basis

  spread would result in some ineffectiveness.

  It may be the case for some hedging instruments that contain both a forward element

  and foreign currency basis that it is more operationally efficient to designate only the

  spot risk and calculate the combined cost of hedging, rather than the forward element

  and foreign currency basis individually or designating the forward rate and excluding

  only the foreign currency basis spread. The standard does not explicitly permit a

  combined treatment, but for many scenarios the aggregate of the individual costs of

  hedging accounting will equate to the costs of hedging accounting calculated on a

/>   combined basis.

  7.5.3.A

  Measurement of the costs of hedging for foreign currency basis spread

  Although the standard is clear that the ‘costs of hedging’ accounting method can be applied

  to the foreign currency basis spread within hedging instruments, it is less clear as to how to

  identify the foreign currency basis spread for this purpose. This is an area where we expect

  practice to evolve. We outline below two possible approaches for the identification of the

  foreign currency basis spread; other acceptable approaches may exist:

  Approach 1: Based on the difference between the fair value of the actual foreign

  currency hedging instrument and the value of a hypothetical instrument derived and

  valued using market data excluding foreign currency basis spread.

  Approach 2: Based on the difference between the fair value of the actual foreign

  currency hedging instrument and its value calculated using market data excluding

  foreign currency basis spread.

  Example 49.76: Calculation of the value of foreign currency basis spread

  Entity A has functional currency of GBP and issued three year USD100m fixed rate debt on 31/12/19, paying

  a semi-annual coupon of 3.75%. In order to eliminate variability in the fair value of the debt with respect to

  interest rate and foreign currency risk, Entity A transacted a foreign currency swap (Swap A) on the same

  day as follows:

  Pay leg – GBP 64.2m paying 6m LIBOR +2.757% (semi-annual) maturing on 31/12/22

  Receive leg – USD100m paying 3.75% (semi-annual) maturing on 31/12/22

  The spread of 2.757% on the GBP floating leg includes an amount of –0.103% that represents the foreign

  currency basis spread priced into the swap contract. (Quoted prices for foreign currency basis spreads for

  many currency pairs are widely available.)

  Entity A designates the debt and Swap A in a fair value hedge of foreign currency and interest rate risk, and

  wishes to apply the costs of hedging approach to the foreign currency basis spread. The hedge appears to be

  a time-period related hedge (see 7.5.1 above).

  The receive leg of Swap A matches the cash flows from the debt exactly. As the critical terms of the foreign

  currency basis swap are aligned with the hedged debt, there is no need to create an aligned foreign currency

  basis swap (see 7.5.1.A above). For the purposes of this example no other valuation sources of ineffectiveness

  arise, although this is unlikely to be the case in practice.

  Below are two possible approaches to calculating the value of the foreign currency basis spread to be

  recognised in other comprehensive income as part of the costs of hedging:

  4118 Chapter 49

  Approach 1 – Swap B

  Entity A creates hypothetical Swap B. The receive leg of Swap B should exactly match the receive leg of

  Swap A (which also matches the debt). The pay leg of Swap B should be derived to achieve an overall zero

  fair value for Swap B on designation, based on market curves, excluding foreign currency basis spread.

  Accordingly, Swap B might look like the following:

  Pay leg – GBP 64.2m paying 6m LIBOR +2.86% (semi-annual) maturing on 31/12/22

  Receive leg – USD100m paying 3.75% (semi-annual) maturing on 31/12/22

  (The spread of 2.86% on the GBP floating leg does not include an amount representing foreign currency basis spread.)

  The accounting for the hedge relationship would be as follows:

  Instrument

  Fair value on Accounting

  designation

  Debt

  nil

  Value changes due to foreign currency and interest rate risk (using

  discount curves that do not reflect foreign currency basis spread) are

  recognised in profit or loss, and adjust the carrying value of the debt.

  (The recognised changes in value of the debt will be offset by changes

  in the fair value of Swap B’s receive leg.)

  Swap B

  nil

  Changes in fair value due to foreign currency and interest rate risk

  (hypothetical

  (using discount curves that do not reflect foreign currency basis

  swap)

  spread) are recognised in profit or loss.

  Swap A

  nil

  Changes in fair value of Swap A (i.e. using discount curves that

  (actual swap)

  reflect foreign currency basis spreads) LESS the calculated changes

  in the fair value of Swap B, are recognised in other comprehensive

  income as the costs of hedging.

  In the statement of financial position, Swap A is recognised at its fair

  value at all times.

  Other

  As the fair value of the foreign currency basis spread is zero at

  comprehensive

  inception, there is no requirement for a systematic and rational

  income

  amortisation of the costs of hedging from other comprehensive

  income into profit or loss. [IFRS 9.6.5.15(c)].

  The value of the foreign currency basis spreads at inception (nil)

  equals the initial fair value of Swap A (nil) less the initial fair value

  of Swap B (nil).

  Approach 2 – Swap C

  Entity A creates hypothetical Swap C. The terms of Swap C exactly match the terms of Swap A, but Swap C

  would be fair valued based on market curves excluding foreign currency basis spread. (It should be noted that

  the receive leg of Swap C in this example also matches the debt). Swap C will have a fair value on designation

  which is equal to the net present value of the foreign currency basis spread included within the GBP pay leg

  (e.g. a negative spread of 0.103% in this example). Accordingly Swap C will look like the following:

  Pay leg – GBP 64.2m paying 6m LIBOR +2.757% (semi-annual) maturing on 31/12/22.

  Receive leg – USD100m paying 3.75% (semi-annual) maturing on 31/12/22

  The fair value of Swap C on designation is an asset of £132k, this is calculated using market curves excluding

  foreign currency basis spread.

  Financial instruments: Hedge accounting 4119

  The accounting for the hedge relationship would be as follows:

  Instrument

  Fair value on Accounting

  designation

  Debt

  nil

  Value changes due to foreign currency and interest rate risk (using

  discount curves that do not reflect foreign currency basis spread) are

  recognised in profit or loss, and adjust the carrying value of the debt.

  (The recognised changes in value of the debt will be offset by

  changes in the fair value of Swap C’s receive leg.)

  Swap C

  £132k DR

  Changes in fair value due to foreign currency and interest rate risk

  (hypothetical

  (using discount curves that do not reflect foreign currency basis

  swap)

  spread) are recognised in profit or loss.

  Swap A

  nil

  Changes in fair value of Swap A (i.e. using discount curves that

  (actual swap)

  reflect foreign currency basis spreads) LESS the calculated changes

  in the fair value of Swap C, are recognised in other comprehensive

  income as the costs of hedging.

  In the statement of financial position, Swap A is recognised at its fair

  value at all times.

  Other

  The value of the foreign currency basis spread at inception must be

  comprehensive

&
nbsp; amortised from other comprehensive income into profit or loss on a

  income

  systematic and rational basis. [IFRS 9.6.5.15(c)].

  The value of the foreign currency basis spread at inception (GBP

  132k CR) is the initial fair value of Swap A (nil) less the initial fair

  value of Swap C (GBP 132k DR).

  Over the life of the hedge relationship the cumulative amortisation

  will result in the following:

  DR other comprehensive income GBP 132k

  CR profit or loss GBP 132k

  The above fact pattern assumes that there are no sources of ineffectiveness and that the

  hedging derivative exactly matches the critical terms of the hedged item. In reality this

  is unlikely to always be the case, therefore additional complexity may need to be

  incorporated into the chosen approach for identifying the foreign currency basis spread.

  In particular where the critical terms of the hedging derivative do not match those of

  the hedged item, it is the aligned foreign currency basis spread which is eligible for the

  costs of hedging treatment. In that case swap A, B and C (above) should be based on an

  aligned foreign currency derivative, i.e. one that would perfectly match the hedged item.

  Differences in fair value changes between the actual foreign currency derivative and the

  aligned foreign currency derivative will be an additional source of ineffectiveness

  (see 7.5.2 above). [IFRS 9.B6.5.37].

  Although quoted prices for foreign currency basis spreads for many currency pairs are

  widely available, entities should not underestimate the complexities involved in

  eliminating the effect of foreign currency basis spreads from market forward foreign

  currency rates which generally do reflect foreign currency basis spreads.

  4120 Chapter 49

  7.6

  Hedges of a firm commitment to acquire a business

  A firm commitment to acquire a business in a business combination cannot be a hedged

  item, except for foreign exchange risk (see 2.6.4 above).

  Consider the situation where an entity with euro as its functional currency enters into a

  binding agreement to purchase a subsidiary in six months. The subsidiary’s functional

  currency is the US dollar. The consideration is denominated in US dollars and is payable

  in cash. The entity decides to enter into a forward contract to buy US dollars for euros

 

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