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IFRS 16 High divergence

Leases

Treatment under IFRS

Lessees apply a single on-balance-sheet model and recognise almost all leases as a right-of-use asset and a corresponding lease liability. The only exemptions are short-term leases and leases of low-value underlying assets.

  • At commencement, the right-of-use asset is measured at cost (the present value of the lease payments).
  • After initial recognition the lease liability is measured at amortised cost using the effective interest method.
  • The right-of-use asset is measured at cost less accumulated depreciation and accumulated impairment losses.
  • Recognition exemptions (election): short-term leases (≤ 12 months) and low-value assets; the related payments are then expensed on a straight-line basis.
  • Lessors continue to classify leases as either finance or operating leases.

Treatment under German GAAP (HGB)

§ 246 HGB§ 247 HGB§ 266 HGB§ 285 HGB

German GAAP contains no dedicated leasing standard. Recognition follows beneficial (economic) ownership: the leased asset is recognised by the lessee if substantially all risks and rewards are attributed to it. In practice the assessment follows the tax leasing decrees; operating leases stay off-balance-sheet.

  • § 246 (1) HGB: assets are attributed according to beneficial (economic) ownership.
  • § 247 (2) HGB: recognition within non-current assets only where the lessee is the beneficial owner.
  • Leases are classified as finance or operating leases; the attribution follows the tax leasing decrees and may differ from the IFRS assessment.
  • Operating lease payments are expensed on a straight-line basis by the lessee; other financial commitments are disclosed in the notes under § 285 No. 3 HGB.

Key differences

  • Under German GAAP operating leases remain off-balance-sheet (no right-of-use asset and no lease liability for the lessee).
  • No single lease definition; attribution follows the tax leasing decrees rather than a control-based concept.
  • IFRS 16 typically increases total assets and changes EBITDA/EBIT as well as leverage ratios.
  • Considerably lower transparency under German GAAP; essentially only a note disclosure under § 285 No. 3 HGB.

Example

Example – 5-year office lease, annual rent €100,000: Under IFRS 16 the lessee capitalises a right-of-use asset and a lease liability equal to the present value of the rentals; the income statement then shows depreciation (on the asset) and interest expense (on the liability). Under German GAAP this is normally an operating lease: nothing is recognised on the balance sheet, the €100,000 rent is expensed on a straight-line basis, and the remaining commitment appears only in the notes.

Worked example

Assumptions: 5-year office lease, no extension or purchase option, no residual-value guarantee. Annual payment €100,000 in arrears (at each year-end). Incremental borrowing rate (IBR) 5%. No initial direct costs and no lease incentives. The HGB case is an operating lease. Note: payment is made in arrears (at year-end); if paid in advance (at the start of the year) the amounts shift accordingly. All amounts in euros, rounded to whole euros; due to rounding, figures may differ by ±€1.

Step 1 – Initial measurement at commencement (IFRS)

The right-of-use asset and the lease liability are recognised at the present value of the five lease payments. The annuity present-value factor at 5% over 5 years is 4.32948.

  • Lease liability = right-of-use asset = €100,000 × 4.32948 = €432,948
  • Straight-line depreciation of the right-of-use asset: €432,948 ÷ 5 ≈ €86,590 p.a. (€86,589–86,590 due to rounding)

Under HGB (operating lease) there is no balance-sheet recognition; the rent is expensed on a straight-line basis over the term.

Step 2 – Lease liability amortisation schedule (effective-interest method, IFRS)

Movement of the lease liability
YearOpeningInterest (5%)PaymentClosing
1432,94821,647−100,000354,595
2354,59517,730−100,000272,325
3272,32513,616−100,000185,941
4185,9419,297−100,00095,238
595,2384,762−100,0000
Σ67,052−500,0000

Step 3 – Right-of-use asset depreciation schedule (IFRS)

Movement of the right-of-use asset
YearOpeningDepreciationClosing
1432,94886,590346,358
2346,35886,589259,769
3259,76986,590173,179
4173,17986,58986,590
586,59086,5900
Σ432,9480

Step 4 – Balance-sheet effect (at each year-end)

Right-of-use asset versus lease liability under IFRS. A negative net figure means a net lease liability (the liability exceeds the asset). Under HGB nothing appears on the balance sheet.

Year-endRoU assetLiabilityNet (IFRS)HGB
1346,358354,595−8,2370
2259,769272,325−12,5560
3173,179185,941−12,7620
486,59095,238−8,6480
50000

Step 5 – Income-statement effect (expense per year)

Under IFRS the expense comprises depreciation (constant) and interest (decreasing); under HGB a constant rent expense. The total expense over the term is identical in both systems (€500,000), but IFRS is front-loaded – higher in the early years, lower later.

YearIFRS depr.IFRS interestIFRS totalHGB rentDifference
186,59021,647108,237100,000+8,237
286,58917,730104,319100,000+4,319
386,59013,616100,206100,000+206
486,5899,29795,886100,000−4,114
586,5904,76291,352100,000−8,648
Σ432,94867,052500,000500,0000

Step 6 – Journal entries (Year 1)

IFRS – commencement (start of the lease):

AccountDebitCredit
Right-of-use asset432,948
Lease liability432,948

IFRS – at the end of Year 1:

AccountDebitCredit
Depreciation expense86,590
Right-of-use asset (accum. depreciation)86,590
Interest expense21,647
Lease liability (principal)78,353
Bank100,000

HGB – operating lease: no entry at commencement; the future commitment is disclosed in the notes (§ 285 No. 3a HGB). At the end of Year 1:

AccountDebitCredit
Rent expense100,000
Bank100,000

Key takeaway

The total expense is the same under both frameworks (€500,000). IFRS, however, recognises it on a front-loaded basis: higher in the early years (depreciation plus high initial interest) and lower later. The cumulative additional IFRS expense equals the net lease liability in every year from Step 4 (Year 1: €8,237; Year 2: €12,556; Year 3: €12,762; Year 4: €8,648; Year 5: €0). IFRS 16 also increases total assets and shifts expense from rent to depreciation and interest – with a corresponding effect on EBITDA and EBIT.

Related standards