There are no longer explicit rules for the translation of part
of a business where previously FA1993/S93A applied (
CFM10513). That rule, in any case,
followed the normal accounting treatment.
These rules applied where
Usually in these cases, the company kept part of its books in
one currency and consolidated the results into its accounts
(prepared in another currency) using the closing rate/net
investment method. The tax rules at FA93/S93A essentially
incorporated these accounting rules in legislation for the
avoidance of doubt (
CFM15103).
Under IAS 21 (or FRS 23), where a company has a branch
operating in a different functional currency, the results of that
branch are translated into the reporting entity’s
presentation currency. The balance sheet of the foreign currency
branch is also re-translated each year. Any exchange differences
arising on the re-translation will be taken to the statement of
changes in equity and disregarded for tax purposes by FA96/S84A
(3)(b).
Kanweb Ltd is a company operating in the UK that keeps books in
different currencies for various discrete parts of its business.
Its functional currency is the Euro but it also keeps a US dollar
book and a Swiss Franc book. Accounts for the entity as a whole are
prepared in Euros. The accounting date is 31 December. The company
has adopted IAS 21. In accounting period ended 31 December 2006
there are the following results
The Euro accounts show a profit before adjustments of
€1.98m made up as follows: -
| € | ||
| Main business | 1,200,000 | |
| US dollar results translated into Euros | 495,360 | (translated from $600k at $1:€ 0.8256) |
| Swiss Franc results translated into Euros | 290,835 | (translated from SFr 450k at SFr 1:€0.6463) |
| Total result | 1,986,195 |
There is disallowable expenditure of $75,000 in the US dollar
book and capital allowances of SFr 25,000 on the Swiss Franc book.
There are also capital allowances on the main business of
€80,000.
As the entity as a whole has a functional currency of Euros
and accounts in that currency, FA93/S92C applies. The profit is
therefore calculated for tax purposes in Euros and then translated
into sterling.
The company should therefore take the US dollar result and
the Swiss Franc result, adjust for any unallowable expenditure,
deduct capital allowances and then translate it into Euros for tax
purposes. As follows
| Main business
€1.2m less €80,000 |
€1,120,000 |
| Dollar book
$600,000 plus $75,000 = $675,000 |
$675,000 @ 0.8256 =557,280 |
| Swiss Franc Book
SFr 450,000 less SFr 25,000 = SFr 425,000 |
SFr 425,000 @ 0.6463 = €274,677 |
| Total Euro Case I | € 1,951,957 |
| Translate into sterling at average rate for year 0.68 | £1,327,330 |
The second category is covered by FA1993/S92C if the return
of accounts is made in a currency other than sterling (
CFM10570). If, on the other hand the
return is in sterling, those figures are used for tax purposes in
accordance with FA93/S92 provided they are prepared in line with
generally accepted accounting practice.