Common errors when accounting for investment property (IAS 40) – Part 2

When preparing financial statements, it is easy to get confused between what is an investment property and what is property, plant and equipment (PPE). This distinction is important because if we incorrectly classify a property at the outset, the accounting that follows will also be wrong. IAS 16 Property, Plant and Equipment is the standard to follow for PPE but it is important to remember that investment property is a special type of PPE and has its own standard that drives the accounting, IAS 40 Investment Property.

In August 2018 Accounting News, we identified six common errors where preparers could mistakenly classify investment properties as PPE, and vice versa. This article highlights another five.

Error 1 – Dual purpose properties

Investment properties sometimes have a dual purpose, i.e. they can be used partly as an investment property and partly as owner-occupied property (PPE).

The definitions of PPE and investment property suggest an ‘all or nothing’ approach to classifying properties and this principal is reinforced in IAS 40, paragraph 10, which only permits splitting one property between investment properties and PPE if the parts used for different purposes could be:

• Sold separately, or
• Leased out separately under a finance lease.

A common error is to assume that the property can automatically be split for classification purposes if the separate area is physically identifiable.

Example:

Property Co owns a 20-floor commercial building in the CBD which it rents out to tenants. However, it occupies the first floor of the building for its administration department.

In this example, it is unlikely that the property could be split between PPE and investment property because:

• There is no indication that the office or floor used for administrative purposes could be sold separately (e.g. as would be the case if each floor was on a separate strata title), and
• While the separate floor could be leased out separately under an operating lease, paragraph 10 requires that it be leased out separately under a finance lease.

Except in specific circumstances, it would be unlikely for a tenant to enter into a finance lease (i.e. a very long lease) for office premises. However, there could be cases for specialised buildings where a portion of the property could be leased separately as a finance lease.

Note:

In this example, only one floor of the 20-floor building is used for administrative purposes. Therefore, despite the floor not being capable of being sold or leased separately under a finance lease, IAS 40, paragraph 10 would nevertheless permit this property to be classified as investment property in its entirety because only an ‘insignificant portion’ is being used as PPE.

Because ‘insignificant portion’ is not defined in IAS 40, entities need to set a threshold for determining what they consider an ‘insignificant portion’ and this threshold should be disclosed as a significant judgement in the financial statements.

Error 2 – Extent of ancillary services provided

Another common classification error occurs because preparers fail to give adequate consideration to the level of services provided to tenants when deciding whether a property is an investment property or PPE.

Investment properties are generally passive investments and involve little, if no services to tenants other than the provision of rental space. On the other hand, PPE are used in the production or supply of goods or services to customers, and therefore involves the provision of significantly more services than for investment properties.

In order for a property to be classified as investment property, IAS 40, paragraph 11 is clear that ancillary services provided to tenants must be insignificant to the arrangements as a whole, otherwise the property is considered owner-occupied PPE.

The following examples illustrate how judgment is required in relation to the classification of investment property due to the extent of ancillary services provided.

Example 1

ILU Co owns a property comprising 100 independent living units which it rents outs to residents.

All units have a fully equipped kitchen.

As part of the rental agreement with residents, ILU Co provides:

• Cleaning services for all common areas
• Landscaping of common areas
• 24-hour security staff.

ILU Co could classify the independent living units as investment property because the services provided to residents (cleaning, maintenance, landscaping, and security) are ancillary services and appear to be insignificant to the arrangement as a whole.

Example 2

Aged Care Co owns an aged care facility comprising 100 apartments which it rents outs to residents.

As part of the rental agreement with residents, Aged Care Co:

• Provides daily cleaning services for all areas of facility
• Employs 15 nurses/carers at the facility, 24/7 to look after the residents
• Provides security staff
• Provides on-site maintenance services & staff
• Provides all meals for residents
• Organises and provides entertainment and other activities for residents.

Aged Care Co is effectively using the property in the supply of nursing home services to residents, and as such, could classify the apartments as PPE because the services provided to residents (cleaning, permanent carers, security, meals, maintenance, etc.) appear to be significant to the arrangement as a whole.

Example 3

Aged Care Co owns an aged care facility comprising 100 independent living units which it rents outs to residents.

Units have one bedroom, one bathroom and only a bar fridge (no freezer), a microwave and a toaster. There is no full kitchen or laundry in each unit.

As part of the rental agreement with residents, Aged Care Co provides:

• Cleaning services for all common areas
• Landscaping of common areas
• Maintenance of common areas and individual units
• 24-hour security staff
• Daily meal package for three meals a day (stated to be at a $5 a day)
• Free laundry services.

Providing daily meal packages at a stated $5 a day does not represent arm’s length prices and because units do not have a fully equipped kitchen, most residents would be expected to use the daily meal service. Most residents would also be expected to take advantage of the free laundry service. This means that the services provided by Aged Care Co are unlikely to be considered to be ancillary (insignificant to the arrangement as a whole) and the more appropriate classification would be PPE.

However, Aged Care Co must apply judgement before making a final determination, and details of the criteria used to distinguish investment property from PPE are required to be disclosed by IAS 40, paragraph 75(c).

Error 3 – Outsourcing services to third parties under a management contract

Investment properties are generally ‘passive investments’ with few services provided to tenants. Properties failing the ‘insignificant services’ test as described in Error 2 above should therefore be classified as PPE, with fair value movements recognised in OCI.

A common error occurs when preparers attempt to structure service arrangements for owner-occupied property via a third party management contract so that the property appears to be a ‘passive investment’ to the investor. These types of structuring arrangements could be entered into for tax or legal reasons, or simply to try and engineer a particular accounting outcome. However, for accounting purposes we look at substance over form. Such arrangements are often incorrectly classified as investment property where the investor has merely outsourced the day-to-day running of the property, but remains exposed to variations in cash flows generated from the property.

The example below indicates the types of services typically required by a hotel operator.

Example: Hotel operation – no outsourcing arrangement 

Hotel Co owns a hotel and is responsible for:

• Performing major refurbishments of the building
• Performing required upgrades to hotel fit-out
• Performing required repairs and maintenance
• Hiring and management of staff
• Management of day-to-day operations, including front desk, room service, etc.
• Performs all marketing and advertising of hotel
• Management of the booking process
• Receiving income and pays expenses associated with operating the hotel
• Either managing hotel restaurants and shops itself or outsourcing such operations under separate agreements.

Hotel Co could classify the hotel as PPE because it is using the hotel building to supply hotel services to guests. It is also bearing all associated risks and rewards of operating the hotel. The hotel could not be classified as an investment property since it is not being held to earn rentals or for capital appreciation.

The analysis in the above Example becomes more complex as the fact pattern is altered for outsourcing arrangements. The following two examples illustrate how judgement needs to be applied to determine the appropriate classification where the property owner of a hotel has outsourced all, or some, services under a management contract.

Example: Investment property

Property Co A owns a hotel. The hotel is managed by Fancy Hotels, a company that operates chains of hotels under management agreements with the owners. 

The management agreement between Property Co A and Fancy Hotels stipulates that:

• Property Co A
  • Provides the hotel building
  • Performs major refurbishments of the building, and
  • Receives a fixed fee for use of the hotel building.
• Fancy Hotels
  • Hires and manages all staff
  • Manages day-to-day operations, including front desk, room service, etc.
  • Manages advertising of hotel
  • Takes bookings and bears risk of non-payment
  • Either runs hotel restaurants and shops itself or outsources them
  • Manages all income and expenses of the hotel. Fancy Hotels bears all risks and rewards of operating the hotel
  • Performs required repairs and maintenance, and
  • Performs required upgrades to hotel fit-out (e.g. rooms, bathroom, restaurants, etc.).

Property Co A could classify the hotel as an investment property because it is being held to earn rentals (i.e. fixed fee for use of the building) and Property Co A does not bear the associated risks and rewards of supplying hotel services to guests.

Example: Hotel

Property Co B owns a hotel. The hotel is managed by Fancy Hotels, a company that operates chains of hotels under management agreements with the owners. 

The management agreement between Property Co B and Fancy Hotels stipulates that:

• Property Co B
  • Provides the hotel building
  • Performs major refurbishments of the building
  • Performs required upgrades to hotel fit-out (e.g. rooms, bathroom, restaurants, etc.)
  • Performs required repairs and maintenance
  • Hires staff based on recommendations from Fancy Hotels
  • Receives income and pays expenses associated with operating the hotel.
• Fancy Hotels
  • Manages staff
  • Manages day-to-day operations, including front desk, room service, etc.
  • Manages advertising of hotel
  • Manages the booking process
  • Either manages hotel restaurants and shops itself or outsources such operations under separate agreements
  • Receives a fixed management fee for operating the hotel
  • Receives a variable management fee for operating the hotel, calculated as 5% of EBITDA of hotel company.

Property Co B could classify the hotel as PPE. Despite outsourcing the day-to-day operations of the hotel to Fancy Hotels, Property Co B has retained the risk of significant variations in the cash flows generated by the operations of the hotel, suggesting that the hotel is still ‘owner managed’ by Property Co B.

Fancy Hotels does not bear the associated risks and rewards of ownership of the hotel since it receives a fixed management fee for operating the hotel, as well as a variable fee based on the overall performance of the hotel. The variable fee is akin to a performance fee, i.e. if Fancy Hotels manages the hotel well, profits increase and the variable fee increases, whereas if management is poor the variable fee decreases.

Error 4 – Different classifications in group and individual entity financial statements

The accounting treatment of items in the separate financial statements and the consolidated financial statements is not always the same.

In some cases, one entity in a group may own a property that it rents out to another group company. In the consolidated financial statements, this property is classified as PPE because it is ‘owner-occupied’ from the perspective of the group.

A common error occurs when preparers fail to change the classification to investment property in the individual financial statements of the property owner, who is merely holding the property to earn rentals. In addition, any accumulated fair value increments recognised in OCI in the consolidated financial statements in relation to the property must be transferred to retained earnings in the financial statements of the property owner, with the current period movement in fair value recognised in profit or loss.

Error 5 – Business combination or asset acquisition

When acquiring a property that meets the definition of ‘investment property’, a common error occurs when preparers assume that the acquisition is an asset acquisition, and fail to assess whether the purchase constitutes a business combination under IFRS 3 Business Combinations.

The implications of this is that the purchase price is allocated entirely to property purchased, whereas in a business combination, the investment property acquired is measured at fair value on acquisition date, any excess consideration is allocated to goodwill, and a deferred tax liability recognised where the fair value of the property exceeds its tax base.