BIM74215 - Revenue recognition and service contracts: UITF 40: calculating adjustment income

General rules

The new accounting policy described at BIM74270 will give rise to a one-off taxable transitional adjustment in the first year in which it is adopted.

The adjustment is calculated in accordance with FA02/S64 and Schedule 22 for CT purposes and ITTOIA05/S226 onwards (Part 2 Chapter 17) for income tax purposes. An adjustment under these rules can be positive or negative – taxable or relievable. If taxable, the adjustment is called a ‘positive adjustment’ for CT and ‘adjustment income’ for income tax. This legislation is known as the ‘change of basis’ legislation.

For further guidance on how to calculate the adjustment see BIM34000 onwards and in particular BIM34130. Although there must be an accounting prior period adjustment to trigger the application of the change of basis rules, the adjustment income or expense is not necessarily the same as the accounting prior period adjustment – it depends on how the various components of the adjustment are treated for tax.

For income tax purposes the adjustment income arises on the last day of the first period of account in which the new accounting policy is adopted. It is earned income and although it is charged separately from trading profits it is treated as profits of the trade, profession or vocation for certain loss reliefs (ITTOIA05/S232).

For CT, for periods of account beginning on or after 1 January 2005, the positive adjustment arises on the first day of the period of account; for earlier periods the situation is the same as for income tax (FA02/SCH22/PARA4). A positive adjustment is chargeable for corporation tax as a receipt of the trade (see BIM34070 – last section for more on this subject).

If the old accounting policy does not comply with GAAP the adjustment will not be within the change of basis legislation - see BIM34020. The relevant figures will have to be recalculated to comply with GAAP following the guidance on invalid to valid changes – see BIM34025.

Where UITF 40 applies

In the case of a taxpayer adopting UITF 40, providing there are no other tax adjustments (for example, disallowances for capital expenditure) and no other changes in accounting policy, the adjustment is normally the same as the accounting prior period adjustment.

The accountancy is as follows:

The prior period adjustment resulting from the change to a new accounting policy restates the opening balance sheet to what it would have been had the new accounting policy been in place in the previous period. In the case of UITF 40 the business needs to calculate what the accrued income figure would have been at the end of the previous period had the new policy been in place then. The business also needs to revisit the work-in-progress figure, if any, to remove any contracts for which the new policy would have recognized accrued income and released work-in-progress to the profit and loss account to match the revenue recognition.

For further information on calculating prior period adjustments speak to an HMRC Compliance Accountant.

Example

The following simple example sets out what might happen in practice.

Serge is a self employed consultant. He draws up his accounts to 31 December each year. He has no work in progress (see BIM33170).

At 31 December 2004 he was half way through writing a report. He estimated the report would take him 200 hours and it would be finished in February 2005. His time records show that he had spent 100 hours on the report at 31 December 2004 and his contract shows he will be paid £60,000 for the completed report.

In his accounts for 31 December 2005 he must include both opening and closing figures for work to which UITF 40 applies. He must restate the opening figures to increase sales and debtors by £30,000 (half the value of the contract).

The prior period adjustment for accountancy purposes will be £30,000. This figure is not credited to the profit and loss account but is taken to the capital account (or profit and loss reserve account).

As noted above the adjustment income for tax purposes on the adoption of UITF 40 is normally the same as the prior period adjustment - here the adjustment income is also £30,000.