Blind Freddy – Common errors in accounting for impairment – Part 4 – Not testing impairment at the correct unit of account

The ‘Blind Freddy’ proposition is a term used by Justice Middleton in the case of ASIC v Healey & Ors [2011] (Centro case) to describe glaringly obvious mistakes.

In this month’s Blind Freddy article, we continue our series on errors that can be made in applying the requirements of AASB 136 Impairment of Assets, focusing on errors that can be made by not testing impairment at the correct ‘unit of account’.

When there is an indicator that an asset or group of assets is impaired, that asset (or group of assets) must be tested for impairment. Determining the level at which impairment testing takes place (the ‘unit of account’) involves significant judgement. However, there are clear ‘rules’ set out in AASB 136 Impairment of Assets that, if not followed, can result in ‘Blind Freddy’ errors, such as:

  • Testing impairment as part of a cash-generating unit (CGU), rather than as an individual asset
  • Testing an asset for impairment at the individual asset level, rather than as part of a CGU
  • Incorrectly identifying an entity’s CGUs, including CGUs being too large or too small
  • Incorrectly determining a CGU at too high a level because the outputs from a CGU are consumed by other CGUs within the business
  • Not consistently identifying CGUs from period to period for the same asset (or types of assets) where no change is justified
  • Incomplete disclosure about changes to CGU composition.

It must also be recognised that special rules apply to the impairment testing of goodwill in respect of CGUs and groups of CGUs. The notion of testing impairment at a group of CGUs is specific to goodwill. Again, this can cause confusion in the correct application of AASB 136.

A commonly used term in the application of AASB 136 is ‘top down AND bottom up’ impairment testing. The ‘top down’ refers to the impairment testing of goodwill, the ‘bottom up’ refers to the impairment testing at an individual asset level, working up to a group of assets, then to a CGU.

The resulting Blind Freddy errors are discussed in more detail below.

Testing impairment as part of a cash-generating unit (CGU), rather than as an individual asset

The basic requirement of AASB 136 is that impairment testing should be performed at the individual asset level. If there is any indication that an asset may be impaired, that asset’s recoverable amount shall be determined.

If there is any indication that an asset may be impaired, recoverable amount shall be estimated for the individual asset. If it is not possible to estimate the recoverable amount of the individual asset, an entity shall determine the recoverable amount of the cash-generating unit to which the asset belongs (the asset’s cash-generating unit).

AASB 136, paragraph 66

Only where it is not possible to estimate the recoverable amount of the individual asset, can an entity switch to determine the recoverable amount of the CGU to which the asset belongs, i.e. this is the ‘bottom up’ approach, starting at the individual asset and working up to the CGU. The main reason for it not being possible to determine an individual asset’s recoverable amount is where ‘the asset does not generate cash inflows that are largely independent of those from other assets’ (AASB 136, paragraph 67(e)).

One of the specified indicators of impairment in AASB 136, paragraph 12(e), is ‘evidence is available of obsolescence or physical damage of an asset’. A Blind Freddy error is therefore ignoring the impairment of an obsolete or damaged asset when it is being used in a profitable CGU. 

Example 1

Company A operates a profitable bus route, bus route A. It uses five buses to service bus route A, each with a carrying value of $50,000. One bus is found to have major problems with its motor failing to pass the State’s revised safety standards for buses. The bus is therefore not being used.

Company A tests for impairment at the CGU level, being the bus route, as follows:

 

Route A

 

$

Assets – Five buses @ $50,000 each

250,000

NPV of cash flows on bus route A

300,000

 

 

Surplus

50,000

Company A incorrectly concludes that there is no impairment charge to recognise because the recoverable amount of the CGU ($300,000) exceeds its carrying amount ($250,000).

The impairment test should have been performed at the asset level, with the bus that is not being used being impaired, and its recoverable amount likely to be determined using its fair value less costs of disposal (FVLCD).

Blind Freddy Error 1

Failing to test individual assets with impairment indicators before testing the whole CGU for impairment.

Testing an asset for impairment at the individual asset level, rather than as part of a CGU

A mirror of Blind Freddy Error 1 is the case where an asset’s recoverable amount cannot be determined, but is tested at the individual asset level.

Example 2

A mining company owns a private railway to support its mining activities. The private railway could be sold only for scrap value, and it does not generate cash inflows that are largely independent of the cash inflows from the other assets of the mine.

The mining company concludes that because the railway does not generate cash, it is impaired and it is written down to its scrap value (FVLCD).

This is a ‘Blind Freddy’ error because it is not possible to estimate the recoverable amount of the private railway by itself because it does not generate its own cash flows (therefore value in use is nil). The mining company should therefore estimate the recoverable amount of the CGU to which the private railway belongs, i.e. the mine as a whole.

Blind Freddy Error 2

Impairing individual assets with no independent cash flows, rather than allocating them to a relevant CGU.

Incorrectly determining the CGU, including CGUs being too large or too small

A cash-generating unit is the smallest identifiable group of assets that generates cash inflows that are largely independent of the cash inflows from other assets or groups of assets.

Definition of ‘cash-generating unit’ in AASB 136

This basic definition can lead to two Blind Freddy errors as follows:

  • CGUs being too small (the group of assets are not independent) - likely to result in impairment charges being excessive, or
  • CGUs being too large - likely to result in impairment charges being understated.

When considering the use of CGUs in impairment testing under AASB 136, confusion arises from the special rules on impairment testing for goodwill in paragraph 80 (to be discussed in next month’s Blind Freddy article) and the testing of individual assets (other than goodwill) for impairment. Impairment testing for goodwill introduces the concept of testing impairment at a level of a ‘group of CGUs’. This is a special rule for goodwill, and impairments of assets other than goodwill must be performed at the CGU level (not for a group of CGUs).

It is worth considering Illustrative Example, IE1, in AASB 136.

Background

Store X belongs to a retail store chain M. X makes all its retail purchases through M’s purchasing centre. Pricing, marketing, advertising and human resources policies (except for hiring X’s cashiers and sales staff) are decided by M. M also owns five other stores in the same city as X (although in different neighbourhoods) and 20 other stores in other cities. All stores are managed in the same way as X. X and four other stores were purchased five years ago and goodwill was recognised.

What is the cash-generating unit for X (X’s cash-generating unit)?

AASB 136, Illustrative Example IE1

The analysis in IE2 – IE4 states:

In identifying X’s cash-generating unit, an entity considers whether, for example:

(a) internal management reporting is organised to measure performance on a store-by-store basis; and (b) the business is run on a store-by-store profit basis or on a region/city basis.

AASB 136, Illustrative Example IE2

All M’s stores are in different neighbourhoods and probably have different customer bases. So, although X is managed at a corporate level, X generates cash inflows that are largely independent of those of M’s other stores. Therefore, it is likely that X is a cash-generating unit.

AASB 136, Illustrative Example IE3

CGU too small

If the impairment test is performed at a level such that the CGU is too small, it is likely that the entity will recognise excessive impairment charges. This can arise when the group of assets are not independent of other assets in generating cash, for example, where various services are bundled to derive revenue or income from a customer.

Example 3

A bus company provides services under a contract with a municipality that requires minimum service on each of five separate bus routes.

Assets devoted to each route, and the cash flows from each route, can be identified separately.

One of the routes operates at a significant loss.

 

Route 1

Route 2

Route 3

Route 4

Route 5

Total

 

$

$

$

$

$

$

Assets

100,000

100,000

100,000

100,000

100,000

500,000

NPV of cash flows from each route

20,000

110,000

110,000

110,000

150,000

500,000

 

 

 

 

 

 

 

Surplus

(80,000)

10,000

10,000

10,000

50,000

Nil

The entity tests the assets associated with the loss making route for impairment and incorrectly recognises an impairment loss of $80,000. Although separate cash flows can be identified with each bus route, the requirement in the contract to provide a minimum service on each route means that the CGU (smallest identifiable group of assets that generates cash inflows that are largely independent of the cash inflows from other assets or groups of assets) is the total of all bus routes because the cash flows for loss-making route 1 are dependent on the cash flows of the sum of all routes.

Blind Freddy Error 3

CGUs being tested at a level that is too low, resulting in excessive impairment charges.

CGU too large

If the impairment test is performed at a level such that the CGU is too large, it is likely that the entity will understate its impairment charge. This can arise when the group of assets are independent of other assets in generating cash, and the entity wrongly combines cash flows instead of disaggregating them.

When CGUs are too large, this Blind Freddy error typically results in:

  • Cash flows from profitable operations supporting the carrying amounts of assets from unprofitable operations, or
  • Cash flows from fully depreciated assets, or assets with low carrying amounts on the balance sheet, supporting the carrying amount of significant assets that generate minimal cash flows.

Example 4

A bus company provides services under contract with a municipality.

It operates five key arterial routes. Assets devoted to each route, and the cash flows from each route, can be identified separately.

One of the routes operates at a significant loss.

Because the entity has the option to curtail any one bus route, the lowest level of identifiable cash inflows that are largely independent of the cash inflows from other assets (or groups of assets), is the cash inflows generated by an individual route. For the purpose of impairment testing, it would be therefore wrong to aggregate all five routes into a single CGU.

Example 5

A retailer operates five separate stores in a particular city.

The assets which are dedicated to each store, and the cash flows from each store, can be identified separately.

One of the stores operates at a significant loss.

For the purpose of impairment testing, it would be wrong to aggregate all five stores into a single CGU. The assets associated with the loss making store should be tested for impairment against the cash flows generated from that store.

 

Store 1

Store 2

Store 3

Store 4

Store 5

Total

 

$

$

$

$

$

$

Assets

100,000

100,000

100,000

100,000

100,000

500,000

NPV of cash flows from each store

20,000

110,000

120,000

120,000

150,000

520,000

 

 

 

 

 

 

 

Surplus

(80,000)

10,000

20,000

20,000

50,000

20,000

The entity performs the impairment test at the group of CGUs level (each store is a CGU and records no impairment loss, having determined the recoverable amount to be $520,000 compared to a carrying amount of $500,000).

Application of AASB 136 would require the recording of an impairment loss of $80,000 for Store 1.

Blind Freddy Error 4

CGUs being tested at a level that is too high, resulting in understated impairment charges.

Incorrectly determining a CGU at too high a level because the outputs from a CGU are consumed by other CGUs within the business

Another Blind Freddy error arises where an entity is a vertically integrated business, and it incorrectly views the vertically integrated operation as a single CGU. If the operation is capable of producing outputs that can be consumed by third parties, this is likely to represent a separate CGU, regardless of whether all of its output is consumed internally.

Examples of such situations might include:

  • Vertical integration of producing oil wells with a refining operation - most likely the production activity is a separate CGU from the refining operation
  • A refining operation and a retail chain of service stations - most likely these are two separate CGUs
  • A package tour operator, operating aircraft and hotels
  • A steel producer operating coal mines to provide material to be consumed in its steel furnaces, and
  • A retail operation having its own farms or manufacturing facilities.

If an active market exists for the output produced by an asset or group of assets, that asset or group of assets shall be identified as a cash-generating unit, even if some or all of the output is used internally. If the cash inflows generated by any asset or cash-generating unit are affected by internal transfer pricing, an entity shall use management’s best estimate of future price(s) that could be achieved in arm’s length transactions in estimating:

  1. the future cash inflows used to determine the asset’s or cash-generating unit’s value in use; and
  2. the future cash outflows used to determine the value in use of any other assets or cash-generating units that are affected by the internal transfer pricing.

AASB 136, paragraph 70

Example 6

Company B is a steel manufacturer that operates one steel mill and also owns two coal mines, one produces coking coal, the other thermal coal. All of the mines’ output is consumed in the steel mill.

 

Coal mine 1

Coal Mine 2

Steel Mill

Steel business (Total)

 

$’m

$’m

$’m

$’m

Assets

100

10

200

310

 

 

 

 

 

Recoverable amount using internal transfer pricing

101

60

189

350

Recoverable amount using standalone market prices for coal

71

30

249

350

 

 

 

 

 

Impairment using internal transfer pricing

Nil

Nil

11

Nil

Impairment using market price of coal

29

Nil

Nil

Nil

If Company B determined the CGU to be the steel business as a whole, it would result in Company B incorrectly recognising no impairment charge, rather than the impairment charge of $29 million, using arm’s length prices, required by AASB 136, paragraph 70.

Similarly, if Company B determined that the steel mill should be impaired, and an impairment loss of $11 million was recognised based on internal transfer pricing, this would not comply with AASB 136, paragraph 70.

This example illustrates the need to determine a CGUs recoverable amount using arm’s length prices, rather than internal transfer prices that can be used to ‘share’ profits around the entity’s various CGUs.

Blind Freddy Error 5

Identifying vertically integrated businesses as one CGU because output is only sold internally.

Blind Freddy Error 6

Using internal transfer pricing to determine recoverable amount instead of arm’s length prices.

Not consistently identifying CGUs from period to period for the same asset (or types of assets) where no change is justified

Cash-generating units shall be identified consistently from period to period for the same asset or types of assets, unless a change is justified.

AASB 136, paragraph 72

As described above, there is a degree of professional judgement involved in both determining:

  • Whether an asset should be tested for impairment at the asset level or CGU level, and
  • The allocation of assets to CGUs and the determination of what represents a CGU.

It is essential that these judgements are applied consistently, and if not, that fact is disclosed. There is a tendency for allocation of assets to drift towards those CGUs that are generating the most cash flows. This can arise as business models and markets evolve over time.

Example 7

Media Co operates three CGUs, namely a hard print newspaper, an online news subscription website, and a monthly lifestyle magazine.

The print business is more asset intensive, involving printing presses, warehousing and distribution equipment. Each business has its own sales and marketing teams, as well as a standalone editorial team.

Performance of the CGUs in 2010 was as follows.

 

Print Newspaper

Online news service

Lifestyle Magazine

Total

Assets

$’m

$’m

$’m

$’m

Acquired mastheads / titles

2

Nil

2

4

Printing presses

5

Nil

1

6

Warehouse

2.5

Nil

0.5

3

Distribution equipment

1

Nil

Nil

1

Sundry equipment

1

0.5

0.5

2

Share of head office fit-out

5

0.5

0.5

6

Total assets attributable to the CGU

16.5

1

4.5

22

 

 

 

 

 

Recoverable amount in 2010

20

2

5

27

The nature of the media industry has changed significantly over the past six years, with a significant increase in online business, and a significant retraction in the print business (both newspapers and magazines). As a result, the workforce has been rationalised to one back office, reducing the workforce by 60%. The organisation still produces financial results for each of the three businesses based on the achieved sales and advertising revenue.

Had a consistent method of allocating assets been applied to the CGUs, the following recoverable amounts in 2016 would be:

 

Print Newspaper

Online news service

Lifestyle Magazine

Total

Assets

$’m

$’m

$’m

$’m

Acquired mastheads / titles

2

Nil

2

4

Printing presses

5

Nil

1

6

Warehouse

2.5

Nil

0.5

3

Distribution equipment

1

Nil

Nil

1

Sundry equipment

1

0.5

0.5

2

Share of head office  fitout 

5

0.5

0.5

6

Total assets attributable to the CGU

16.5

1

4.5

22

 

 

 

 

 

Recoverable amount in 2016

10

15

2

27

Media Co proposes to re-determine the allocation of assets as follows:

 

Print Newspaper

Online news service

Lifestyle Magazine

Total

Assets

$’m

$’m

$’m

$’m

Acquired mastheads / titles

1

2

1

4

Printing presses

5

Nil

1

6

Warehouse

2

1

Nil

3

Distribution equipment

1

Nil

Nil

1

Sundry equipment

Nil

2

Nil

2

Share of head office  fitout 

1

5

Nil

6

Total assets attributable to the CGU

10

10

2

22

 

 

 

 

 

Recoverable amount in 2016

10

15

2

27

A Blind Freddy error would be to conclude, based on this inconsistent allocation of assets to the three CGUs, that there is no impairment charge to recognise. Based on the consistent allocation of assets, an impairment charge of $9 million would be recognised ($6.5 million for print newspaper and $2.5 million for magazines).

Blind Freddy Error 7

Changing asset allocations in CGUs to mirror business performance where the change is not justified.

As an alternative, Media Co now determines that it only has one CGU, being its media business, and determines that there is no impairment charge as the recoverable amount of $27 million exceeds the carrying value the CGU of $22 million.

Blind Freddy Error 8

Merging CGUs after a business rationalisation to avoid impairment losses where independent businesses are still being operated and separate results tracked.

Incomplete disclosure about changes to CGU composition

Where the composition of a CGU has changed since the previous reporting period (e.g. certain assets moved from one CGU to another), and an impairment loss has been recognised or reversed for that CGU during the current reporting period, all the detailed impairment disclosures in AASB 136, paragraph 130 must be included.

If an entity determines that an asset belongs to a cash-generating unit different from that in previous periods, or that the types of assets aggregated for the asset’s cash-generating unit have changed, paragraph 130 requires disclosures about the cash-generating unit, if an impairment loss is recognised or reversed for the cash-generating unit.

AASB 136, paragraph 73

Blind Freddy Error 9

Lack of disclosure about changes in the composition of CGUs.

Next month

In next month’s article we look at common errors made when testing goodwill for impairment, including ‘the top down’ issue when not applying the appropriate unit of account.