Lease accounting: IFRS® Standards vs US GAAP (2024)

IFRS 16Topic 842Preparer considerationsScope

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IFRS 16 applies to leases of property, plant and equipment (PP&E), and other assets, with limited exclusions. The standard may be applied to leases of intangible assets, other than certain rights held under licensing agreements for items such as motion picture films, video recordings, copyrights, etc.Topic 842 also applies to leases of PP&E. However, its scope exclusions are broader such that leases of inventory, leases of assets under construction (when the lessee does not control the asset before the lease commencement date) and all leases of intangible assets are excluded from the scope of Topic 842.Certain arrangements that are accounted for as leases under IFRS 16 may not be in the scope of Topic 842. Dual reporters therefore need to identify and track any such arrangements. Scope differences between IFRS 16 and Topic 842 can be reduced by electing not to apply IFRS 16 to certain leases of intangible assets, because leases of intangible assets are excluded from the scope of Topic 842.Leases recognizedon balance sheet

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A lessee may elect to apply a recognition exemption for leases of ‘low-value’ assets, even if such leases are material in aggregate.There is no exemption for leases of low-value assets.Electing the IFRS 16 exemption for low-value assets creates a difference with the accounting under Topic 842.3A lessee may elect to apply arecognition exemption for leases with a lease term of 12 months or less (i.e. short-term leases). A lease that contains a purchase option is not a short-term lease.Like IFRS 16, a lessee may elect to apply the recognition exemption to short-term leases. However, unlike IFRS 16, a lease that contains a purchase option may qualify as a short-term lease if the lessee is not reasonably certain to exercise its option.When electing the short-term lease exemption, dual reporters need to be mindful of any differences in the identified populations of short-term leases (e.g. due to the existence of purchase options not reasonably certain to be exercised). Those differences need to be separately tracked.Lease classification4A lessee applies a single on-balance sheet lease accounting model.There is a dualclassification on-balance sheet lease accounting model for lessees: finance leases and operating leases. Leaseclassification affects subsequent measurement of the right-of-use asset, lease expense, and income and cash flow statement presentation.Dual reporters need to separately track Topic 842 operating leases because the accounting treatment differs forthose leases under Topic 842 and IFRS 16.Remeasurement assessment for leaseswith variable payments based on an index or rate5A lessee remeasures the lease liability for changes in variable lease payments based on an index or rate when there is a change in the contractually required cash flows.Adjustments to an index or rate do not constitute a reassessment event. A lessee remeasures variable lease payments based on anindex or rate only when it is required to remeasure the lease payments for another reason (e.g. the lease term changes).Dual reporters need to separately track the remeasurement assessment for leases thatare based on an index or rate.Discount rate6For a lessee, the discount rate for the lease is the rate implicit in the lease or, if that rate cannot be readily determined, the lessee’s incremental borrowing rate. IFRS Standards do not include different guidance for private companies – all lessees therefore apply the discount rate guidance in IFRS 16.When the rate implicit in a lease is not readily determinable, Topic 842 allows a private company lessee to use a risk-free discount rate as a practical expedient. The expedient can be elected by class of underlying asset.³Dual reporters that are private companies under US GAAP can ensure greater consistency between their accounting under US GAAP and IFRS Standards by not availing themselves of this Topic 842 expedient.Lease modifications⁴7When a modification reduces the scope of the lease, a gain or loss is recognized for any difference between the decrease in the lease liability and the proportionate decrease in the right-of-use asset.A modification that reduces the term of a lease is not accounted for as a decrease in the scope of the lease. Therefore, no gain or loss is recognized.Lease modifications that reduce a lease term are accounted for differently under IFRS 16 and Topic 842, thereby requiring dual reporters to separately track the accounting for such modified leases.Sale-leaseback transactions8

If the seller-lessee has a substantive option to repurchase the underlying asset, the transfer is not a sale and sale-leaseback accounting does not apply.

Classification of the leaseback by the lessee does not apply under IFRS 16. Sale-leaseback accounting is not automatically precluded if the leaseback is classified as a finance lease by the buyer-lessor (or would be by the seller-lessee if lease classification were applicable). However, in our experience, only in rare circ*mstances would sale-leaseback accounting apply when the leaseback is classified as a finance lease by the buyer-lessor (or would be by the seller-lessee if lease classification were applicable).

If the seller-lessee has a substantive option to repurchase an underlying asset that is not real estate, the transfer may qualify as a sale under certain circ*mstances.

Further, if the leaseback would be classified as a finance lease by the seller-lessee (or as a sales-type lease by the buyer-lessor), then sale recognition is automatically precluded.

Dual reporters may need to separately track the accounting for sale-leaseback transactions.9The seller-lessee measures the right-of-use asset at the retained portion of the previous carrying amount of the underlying asset. Only the amount of any gain or loss related to the rights transferredto the buyer-lessor is recognized. The gain or loss recognized is adjusted for off-market terms.The seller-lessee measures the right-of-use asset in the same way as the right-of-use asset in any other lease. A gain or loss is recognized for the difference between the sale proceeds and the carrying amount of the underlying asset.Subleases10An intermediate lessor classifies a sublease as a finance or operating lease by reference tothe right-of-use asset arising from the head lease.An intermediate lessor classifies a sublease by reference to the underlying asset.In general, most subleases under Topic 842 are classified as operating leases, while more subleases under IFRS 16 are classified as finance leases by the sublessor.