3.1 Durchführung der Analyse
3.1.1 Fragestellungen
3.1.2 Untersuchungsgegenstand
3.1.2.1 Unternehmensstellungnahmen und Standardentwürfe als Datenbasis
Discussion Paper
|
Exposure Draft
|
Re-Exposure Draft
|
Clarifications
|
Gesamt
|
|
---|---|---|---|---|---|
Gesamtbeteiligung
|
226
|
974
|
359
|
74
|
1.633
|
Unternehmensbeteiligung
|
65
|
314
|
116
|
17
|
512
|
Unternehmensanteil
|
28,76 %
|
32,24 %
|
32,31 %
|
22,97 %
|
31,35 %
|
3.1.2.2 Regelungen zur Bilanzierung von Mehrkomponentengeschäften als Untersuchungsgegenstand
3.1.2.3 Überblick untersuchter Regelungen zur Bilanzierung von Mehrkomponentengeschäften nach IFRS 15
3.1.2.3.1 Ausnahmen vom Grundsatz der Umsatzerfassung auf Einzelvertragsbasis
3.1.2.3.1.1 Zusammenfassung von Verträgen
3.1.2.3.1.2 Portfolio-Option
3.1.2.3.2 Identifizierung von Leistungsverpflichtungen
3.1.2.3.2.1 Definition von Leistungsverpflichtungen
3.1.2.3.2.2 Abgrenzung von Leistungsverpflichtungen anhand des Kriteriums der Eigenständigkeit
3.1.2.3.3 Aufteilung des Transaktionspreises auf eigenständige Leistungsverpflichtungen
3.1.2.3.3.1 Aufteilung des Transaktionspreises auf Basis der relativen Einzelveräußerungspreise
3.1.2.3.3.2 Methoden zur Schätzung der Einzelveräußerungspreise
3.1.3 Methodik und Vorgehensweise
3.1.3.1 Untersuchungsmethode
3.1.3.1.1 Bedeutungserschließung mithilfe qualitativ-inhaltsanalytischer Verfahren
3.1.3.1.2 Diskursanalyse
3.1.3.2 Kategoriensystem
3.1.3.2.1 Methodisches Vorgehen
3.1.3.2.2 Formale Zuordnung der Stellungnahmen nach Herkunft und Branchenzugehörigkeit
Herkunftseinteilung der Unternehmen
|
---|
• Afrika/Middle East/Indien
|
• Asien
|
• Australien/Neuseeland
|
• Europa
|
• Kanada
|
• Schweiz
|
• US-Amerika
|
• Zentral- und Südamerika
|
Brancheneinteilung der Unternehmen
|
---|
• Fertigungsindustrie (Industrials)
|
• Pharmaindustrie (Pharma & Healthcare)
|
• Software und Informationstechnologie (Information Technology)
|
• Telekommunikation (Telecommunication)
|
• Rohstoffe (Basic Materials)
|
• Verbraucherdienstleistungen (Consumer Services)
|
• Verbrauchsgüter (Consumer Goods)
|
• Versorgungswirtschaft (Utilities)
|
3.1.3.2.3 Kategorienüberblick
3.1.3.2.3.1 Inhaltliche Zielrichtung
Bilanzierungsalternativen für Mehrkomponentengeschäfte
|
---|
• Ausnahmen vom einzelvertragsbasierten Ansatz
• Aufteilung eines Vertrags in mehrere Einzelverträge
• Portfoliobetrachtung
• Zusammenfassung von Verträgen
|
• Aufteilung von Leistungsverpflichtungen
• Anknüpfung an den Erfüllungszeitpunkt
• Distinct-Kriterium
• Einzelveräußerung
• Interdependenz
• Gewinnmarge
• Risiken
• Vertragsübergreifende Beurteilung
|
• Aufteilung des Transaktionspreises
• Alternativer Bewertungsmaßstab
• Contingent-Revenue-Cap-Methode
• Relativer Einzelveräußerungspreis
• Residualwertmethode
|
• Restkategorie
|
Umsetzungsmöglichkeiten im Rahmen der Standardausgestaltung
|
---|
• Determiniertheit der Regelungsvorschriften
|
• Industriespezifische Ausnahmeregelung
|
• Umfang der Guidance
|
• Übernahme alter Regelungsvorschriften
|
3.1.3.2.3.2 Rhetorik
Ethos: Erzeugung von Glaubwürdigkeit
|
---|
• Autorität
• Bezug auf eigenen Vorschlag
• Branchentreffen
• Darstellung der Vermögens- und Ertragslage
• Persönliche Treffen
• Realität
• Verweis auf andere Institutionen
• Verweis auf andere Standards
|
• Erfolgsorientierung
|
• Expertise
|
• Gemeinsamkeiten
|
• Respekt
|
• Selbstkritik
|
Logos: Erzeugung von Rationalität
|
---|
• Beispiele
|
• Konzeptionelle Gründe
• Entscheidungsnützlichkeit
• Glaubwürdige Darstellung
• Konsistenz
• Relevanz
• Vergleichbarkeit
• Verlässlichkeit
• Verständlichkeit
|
• Ökonomische Gründe
• Kosten
• Nutzen
• Praktikabilität
|
Rhetorische Stilmittel
|
---|
• Antithese
|
• Hyperbel
|
• Metapher
|
• Metonymie
• User
• Most/Some
|
• Rhetorische Frage
|
• Wiederholung
|
3.1.4 Datensatzspezifische und methodische Einschränkungen
3.2 Darstellung und Diskussion der Ergebnisse
3.2.1 Deskriptiver Überblick untersuchter Stellungnahmen
3.2.2 Inhaltliche Zielrichtung und Rhetorik im Standardsetzungsprozess von IFRS 15
3.2.2.1 Unternehmenseinfluss auf die inhaltliche Zielrichtung
3.2.2.1.1 Häufigkeit kommentierter Bilanzierungsalternativen und Kookkurrenz der Umsetzungsmöglichkeiten
3.2.2.1.2 Anknüpfung an alte Regelungsvorschriften und praxisorientierte Regelungen bei den Ausnahmen vom einzelvertragsbasierten Ansatz
Ausnahmen vertragsbasierter Ansatz
|
DP
|
ED
|
Re-ED
|
CL
|
---|---|---|---|---|
Aufteilung eines Vertrags in mehrere Einzelverträge
|
–
|
14,65 %*
|
0,86 %*
|
–
|
Portfoliobetrachtung
|
6,15 %
|
2,55 %
|
7,76 %*
|
–
|
Zusammenfassung von Verträgen
|
21,54 %*
|
24,52 %*
|
2,59 %*
|
–
|
„We believe combining contracts […] is appropriate and the guidance in SOP 81-1 should be retained.“ (Boeing)280„In addition, we believe there should be a provision allowing the aggregation of a group of E&C contracts as provided by SOP 81‐1.“ (Kiewit)281
„The terminology used here should potentially be amended so that it refers to substance of two contracts and that if the goods or services of one contract are linked in terms of delivery and customer usage.“ (EasyJet)286
„However, we question the necessity of this additional step and whether the accounting result would be different in most cases than if an entity simply identified separate performance obligations.“ (IBM)290„We believe that the two-step process of segmenting a contract and then identifying separate performance obligations is unnecessarily complex and provides little incremental benefit. Accordingly, we recommend that the Boards merge the two-step process into a single one based on the identification of distinct performance obligations.“ (Lockheed Martin)291
„In their re-deliberations on the 2010 exposure draft, the boards decided to eliminate the step of segmenting a contract into separate (hypothetical) contracts because that step is unnecessary. The boards noted that the proposed requirement to identify the separate performance obligations in a contract achieves the same result as accounting for the separate components of a contract.“ (IASB/FASB)293
„Recognising assets and liabilities using a portfolio basis would be easier to implement and we do believe that the information provided in the financial statements would not be different.“ (Deutsche Telekom)295„For industries similar to ours, we believe that an option to use a portfolio based approach for homogeneous transactions would make this standard easier to implement while not materially changing the financial statements.“ (Sprint Nextel)296
„Although we appreciate the Board’s clarification on the application of a portfolio approach, we are still firmly convinced that applying this practical expedient would not be feasible.“ (Deutsche Telekom)299„While the portfolio approach could provide some relief (while also introducing another element of aggregation risk which could reduce comparability) from the cost and complexity of implementation, this would still be a significant task for many entities both at implementation and prospectively on an ongoing basis.“ (Sprint Nextel)300
3.2.2.1.3 Anwendungsorientierte Konkretisierung der Regelungen zur Aufteilung von Leistungsverpflichtungen
Aufteilung Leistungsverpflichtungen
|
DP
|
ED
|
Re-ED
|
CL
|
---|---|---|---|---|
Anknüpfung an den Erfüllungszeitpunkt
|
36,92 %*
|
1,27 %*
|
–
|
–
|
Distinct-Kriterium
|
–
|
23,57 %*
|
22,41 %*
|
94,12 %*
|
Interdependenz
|
9,23 %
|
26,11 %*
|
7,76 %*
|
17,65 %*
|
Gewinnmarge
|
10,77 %
|
24,20 %*
|
–*
|
–
|
Einzelveräußerung
|
33,85 %*
|
4,46 %*
|
1,72 %*
|
–
|
Risiken
|
–
|
24,84 %*
|
–*
|
|
Vertragsübergreifende Beurteilung
|
36,92 %
|
36,94 %*
|
0,86 %
|
–
|
„Furthermore it seems to us that the definition for separating performance obligation is not clear enough.“ (Swatch Group)305„The Discussion Paper does not address how performance obligations should be aggregated or disaggregated, other than to state that performance obligations that are transferred to customers at different times should be separated. We believe additional guidance is necessary.“ (Intel)306
„We believe the inclusion of elements of SOP 81-1 in the proposed model would better fit the economic rationale for our contracts, versus requiring us to account for contract elements based on timing of delivery. We thus recommend the Boards consider the contract as the appropriate unit of account and include the separation criteria under SOP 81-1 in the proposed model, adding further guiding principles to promote consistency in application.“ (Northrop Grumman)309„Thus, we recommend that the Discussion Paper be modified to presume that the contract is the basic unit of account and to provide guidance on when it is appropriate to overcome this presumption […]. This guidance could borrow from the concepts in SOP 81-1 and IAS 11.“ (General Dynamics)310
„We generally negotiate contracts as a single project with an overall profit margin […]. In such circumstances, the entire contract should represent a single performance obligation unless the economics of the contract clearly indicate that there are components that should be accounted for separately […].“ (Northrop Grumman)312
„[A]pplying the guidance under the proposed model and unnaturally disaggregating performance obligations could be interpreted to result in immediate loss recognition with respect to that apparent onerous element. We believe this is counter to the way the overall contract is managed and, more importantly, counter to the overall economics of the transaction. On many long-term construction / production-type contracts, the various tasks are deeply interrelated.“ (Raytheon)314
„The company proposes that the definition of a performance obligation […] be amended to include the concept that the performance obligation must have stand-alone customer value as a good or service.“ (IBM)319„However, some additional criteria should be met when identifying a performance obligation. Performance obligations should be determined with reference to whether the customer would purchase the asset on a standalone basis in normal circumstances.“ (Telefónica)320
„Representatives from the construction industry preferred to account for all the promised goods or services in a contract as a single performance obligation unless a part of the contract is regularly sold separately. […]In contrast, representatives from other industries (for example, the technology industry) preferred to account for an individual good or service as a separate performance obligation even if it is not sold separately. […]Consequently, when considering how entities across various industries should identify separate performance obligations, […] the boards decided that an entity should account for a promise of a good or service as a separate performance obligation only if that good or service is distinct.“ (IASB/FASB)325
„Telefónica supports the separation of performance obligations, but we consider that the notion of “distinct” is not clear enough. […] Further, we believe that determining how to unbundle performance obligations […] should not include deliverables that do not have value to the customer on a standalone basis […].“ (Telefónica)326
„We believe that the concept of “distinct” is a reasonable basis for identifying separate performance obligations. However, we request additional guidance and examples to clarify the application of this concept in practice.“ (Nokia)328„We believe further clarification is needed for the proposed principle of determining when a good or service is distinct. […] We believe it would be helpful if the Board developed more complex examples (perhaps as an extension to existing example 10) in the proposed guidance.“ (XenoPort)329
„Distinct profit margin should be an indicator rather than specific criteria.“ (Dell)331„We propose that the Boards please clarify the distinct profit margin standard and consider that a good or service can have a distinct profit margin if the entity has a reasonable basis to estimate a profit margin.“ (Symantec)332„We support the idea of identifying the individual performance obligations within a contract and separately accounting for each obligation, but we would seek additional guidance on the application of the distinct profit margin guidance in determining contract performance obligations.“ (IHS Inc.)333
„Specifically, we request that the Boards recognize that in most cases, all construction activities for a given project […] have overall risks which are inseparable. Therefore, construction companies like ourselves lack a basis for determining the price at which it would sell the components of a contract separately. Characteristics of distinct profit margin will not be met (in most cases) and hence there is typically no more than a single performance obligation for most construction contracts.“ (MYR Group)336„We appreciate that the Board has acknowledged in the application guidance in Paragraphs BC56 – BC59 that, in many instances, it does not make sense to separate long-term contracts into multiple performance obligations due to significant over-arching contract management services and pervasive risks involved in the production of highly complex deliverables. We believe that this concept should have more prominence in the proposed standard, supplementing the guidance provided in paragraphs 23 (a) and (b) for determining whether a good or service, or a bundle of goods or services, is distinct.“ (Bombardier)337
„We believe the Boards should consider the following indicators when determining whether a contract represents a single performance obligation: The product or services delivered are highly customized, integrated, customer specific and delivered over an extended period.“ (Lockheed Martin)339„[F]or software arrangements the topics of functional interdependence (e.g. essentiality and services for significant production, modification, or customization of the software) should be covered […].“ (SAP)340
„We propose you keep the guidance provided in SOP 81-1, allowing long term construction contracts to be viewed as a single distinct obligation.“ (National Oilwell Varco)343„We believe that the standard should allow for the determination of a single performance obligation as a possible outcome when contract activities are performed in an overlapping, concurrent and/or highly interrelated manner and the pricing of the related activities is not distinct or readily determinable in the market.“ (ST Marine)344„We suggest that the Board consider amending the proposed principles such that when an entity negotiates a long-term contract and prices as a single large profit margin for the contract as a whole, it is not necessary to apply the proposed recognition and measurement requirements to each performance obligation separately […].“ (MWH Global)345
„The staff was persuaded by many of the responses in the comment letters that the criterion proposed in the exposure draft that a good or service is distinct if “the entity, or another entity, sells an identical or similar good or service separately” was too rigid and could inadvertently deem some goods or services to be distinct even though those goods or services might not have a distinct function or distinct risks. Instead, the staff would prefer entities to judge whether the goods or services they promise to their customers possess those attributes.“ (Staff)346„Consequently, some of those respondents suggested that the boards might need to develop industry-specific guidance or create industry-specific exceptions to the general principles. The boards addressed those concerns during the re-deliberations of the proposals in the 2010 exposure draft. […] In some cases, the changes have resulted in revised requirements that align more closely with existing requirements or current practice than did the proposals in the 2010 exposure draft.[…] The boards decided unanimously that it was appropriate to go beyond established due process and re-expose their revised revenue proposals because of the importance of the revenue number to all entities and the desire to avoid unintended consequences in the recognition of revenue for specific contracts or industries.“ (IASB/FASB)347
„The boards developed the criterion specified in paragraph 29(a) using feedback on the 2010 exposure draft and suggestions from respondents (especially respondents from the construction and manufacturing industries) that the standard should include some of the discussion in the 2010 exposure draft’s Basis for Conclusions on distinct profit margins.“ (IASB/FASB)349
„In order to avoid misapplication of the guidance as intended by the Boards, we recommend the Boards provide indicators in paragraph 29(a) to help companies determine whether the goods or services in a bundle are “highly interrelated”.“ (Boeing)352„We would ask the Boards to consider including the indicators/criteria set forth in ASC 985 or to include additional implementation guidance that would help companies understand when goods and services are deemed to be highly interrelated.“ (Cisco)353
„We believe that additional guidance is necessary to clarify whether, for example, a contract to supply oil or gas over a period of time is a single performance obligation satisfied over time, or a series of performance obligations, as described further on pages 8 and 9 of this letter.“ (BP)355„Therefore, we respectively request that the Boards provide additional implementation guidance and an example of how this guidance should be applied to a contract involving repetitive deliveries of the same good or service where the benefits associated with those goods and services is instantaneously controlled and the consumed upon delivery, in order to confirm our interpretation.“ (NextEra Energy)356
„The boards decided to include this notion as part of the definition of a performance obligation to simplify the application of the model and to promote consistency in the identification of performance obligations in circumstances in which the entity provides the same good or service consecutively over a period of time (for example, a repetitive service arrangement).“ (IASB/FASB)357
„We do not agree with the IASB’s approach to clarify the application of the concept of ‘distinct’ by only amending the Illustrative Examples. It is our view that amendments to the Standard are required to clarify the requirements of identifying performance obligations.“ (MTN Group)360„The FASB has proposed an exemption relating to the accounting for shipping and handling activities that occur after the customer has obtained control of the goods. We consider that the IASB should propose the same exemption to address these issues in order to retain the benefits achieved by the converged standards.“ (Rio Tinto)361
3.2.2.1.4 Konzeptionell konsistente Ausgestaltung der Regelungen zur Aufteilung des Transaktionspreises unter Gewährung praxisgerechter Ermessensspielräume
Aufteilung Transaktionspreis
|
DP
|
ED
|
Re-ED
|
CL
|
---|---|---|---|---|
Alternativer Bewertungsmaßstab
|
16,92 %
|
2,87 %
|
–
|
–
|
Contingent-Revenue-Cap-Methode
|
6,15 %
|
2,87 %*
|
6,90 %*
|
–
|
Relativer Einzelveräußerungspreis
|
60,00 %*
|
25,48 %*
|
12,93 %*
|
–
|
Residualwertmethode
|
12,31 %
|
6,69 %*
|
12,07 %*
|
–
|
„Yes we agree that if an entity does not sell a good or service separately it should be able to estimate the standalone selling price of that good or service. We believe there should be a hierarchy for estimation similar to the concepts proposed in EITF 08-1 […].“ (Dell)365
„The telecommunications industry currently applies the ‘contingent revenue cap’ principle, as per paragraph 14 of EITF 00-21 and EITF 08-1, which we believe to be compatible with IAS 18. […] The Discussion Paper requires arrangement consideration to be allocated between performance obligations on the basis of relative standalone selling prices. We believe that for the telecommunications industry the contingent revenue cap remains appropriate for the following reasons […].“ (Vodafone)367„Only allowing the allocation of revenue based on the relative standalone selling price of performance obligations is not practical to apply […]. Specifically we believe that the ‘residual’ or ‘cash cap’ method of allocation (as permissible under US GAAP and also compatible under IAS 18) would better reflect the economics of a particular transaction […].“ (BT)368
„Thus, we believe that the allocation basis for the transaction price would be the contractor’s best estimates of the costs of various components of a project and their relative costs and margin.“ (Shaw Group)370
„Some respondents to the discussion paper suggested that the proposed requirements should permit the residual method […]. However, the boards noted that the residual method is unnecessary if an entity is required to estimate stand-alone selling prices. […] Consequently, the boards confirmed their view that the residual method should not be used to allocate the transaction price to separate performance obligations. However, the boards noted that a residual (or reverse residual) technique may be an appropriate method for estimating a stand-alone selling price […].“ (IASB/FASB)373
„Additionally we agree that as long as the method of estimating standalone selling price is consistent and maximizes the use of observable inputs, that no method of estimation should be precluded or prescribed.“ (Northrop Grumman)375„We agree that an entity should allocate the transaction price to all separate performance obligations in a contract in proportion to the standalone selling price (estimated if necessary) […]. However. we believe additional implementation guidance and examples on suitable estimation methods would be necessary specifically as it relates to suitable estimation methods for biotechnology entities.“ (Xenoport)376
„The exposure draft requires the “relative selling price” approach to be followed in allocating the transaction price to the performance obligations. […] We recommend retaining the accounting policy choice of using either the relative fair value selling price approach or the residual method as currently available under IAS 18 - Revenue.“ (MTN Group)378„We have noted para BC125 of the ED which states “that a residual (or reverse residual) technique may be an appropriate method […]”. We believe that this guidance should be in the text of the standard rather than in the basis for conclusion.“ (SAP)379
„We generally agree that the transaction price should be allocated to all separate performance obligations in a contract in proportion to the stand-alone selling price […]. However, we strongly recommend maintaining the FASB’s provision under ASC 605-25-30. That is, the amount allocable to a satisfied performance obligation should be limited to the amount that is not contingent upon the fulfilment of additional future performance obligations (“contingent revenue cap”).“ (Deutsche Telekom)380„In order to avoid the inconsistencies described above regarding the recognition of handset and service revenues in our industry we suggest that the amount allocable to a satisfied performance obligation should be limited to the amount that is not contingent upon the fulfilment of additional future performance obligations (“contingent revenue cap”).“ (Telefónica)381
„[T]hose respondents thought that the proposed requirements should clarify how and when an entity could use the residual approach as an estimation method. Therefore, paragraph 73(c) of the proposed requirements specifies the circumstances in which a residual approach would be a suitable method to estimate a stand-alone selling price. In specifying those circumstances, the boards were particularly mindful of the challenges in determining stand-alone selling prices in contracts for intellectual property and other intangible products […].However, the boards affirmed their proposal in the 2010 exposure draft not to carry forward the contingent revenue cap for the following reasons […] Additionally, the boards decided not to introduce an exception to the revenue model for telecommunications and similar contracts because they do not view those contracts to be unique.“ (IASB/FASB)382
„We believe that a restriction on revenue akin to the contingent revenue cap remains the best solution and addresses each of the adverse effects noted above.“ (Vodafone)384„We request that the final standard retain the current contingent revenue cap. If this is not possible, then we request that additional practical expedients be introduced into the final standard. For instance, we request that the use of the residual technique be specifically allowable for contracts in the telecommunications industry.“ (Rogers Communication)385
3.2.2.2 Rolle der Rhetorik bei der Standardsetzung
3.2.2.2.1 Häufigkeit verwendeter Überzeugungsarten und rhetorischer Stilmittel
3.2.2.2.2 Verwendung von Pathos zur Verdeutlichung von Anwendungsproblemen
„The number of performance obligations that would be identified, combined with the sheer volume of low value transactions, results in a number of relative standalone sales price that is simply impossible for a telecommunications company to apply.“ (Deutsche Telekom)397
„Like the rest of the economy the construction industry is on hard times; however the construction economy is suffering far worse than our United States economy. This would not be a good time to introduce additional economic hardship to the construction industry.“ (Emerick)401„The cost of new software and additional accounting staff expenses will be an onerous burden on, particularly, smaller private companies. This will close some companies’ doors and be a huge burden on our already struggling industry.“ (Vance Brown)402
„As a result of the field-testing we feel justified in our concerns that the proposed model will be impossible to apply for telecom operators, given the tremendous volume of transactions we face every day.“ (Deutsche Telekom)403
„It would be difficult, if not impossible, for an entity to know the customer’s intentions in any given contract.“ (IASB/FASB)404
3.2.2.2.3 Verwendung von Logos zur Demonstration der rational underpinnings
„As a result, it is not clear that the guidance will be able to be implemented in an objective, practical and consistent manner across all entities.“ (CSC)411„We believe that splitting E&C contracts into different performance obligations would be arbitrary. […] One contractor might classify, for example, scaffolding and mobilization as deliverables; whereas another might classify them as indirect costs and spread them among other identified deliverables, leading to inconsistent revenue recognition between the two contracts.“ (Kiewit)412
„The proposed standard currently calls for an entity to identify all of the elements in a contract […] and then aggregate them into performance obligations […]. The practical implementation issues are highly significant and may not lead to useful information for decision making.“ (CSC)414„[T]he exposure draft appears to ignore the intent of the parties who negotiated the contract, focusing instead on the unrelated possibility that the good or service “can” be sold separately. We believe this approach will produce financial results that are not relevant and could be misleading to financial statement users of companies involved in long-term construction projects.“ (National Oilwell Varco)415
„The boards observed that even though IFRS 15 may result in significant differences in the allocation of the transaction price to performance obligations […] in some industries, the change was necessary to provide greater consistency in the recognition of revenue across industries.“ (IASB/FASB)418
„We see some inconsistencies in the underlying principles in the DP, as the contract is used as the base to identify performance obligations but the prices agreed in that contract are not used for the allocation of the transaction price to such obligations.“ (Telefónica)421„As written, we are concerned it could result in a proliferation of segmenting that would be inconsistent with the spirit of the related guidance on identifying performance obligations.“ (Bombardier)422
„Our main arguments for introducing the contingent revenue cap into the proposed model were the following: The contract asset recognised for the amount exceeding the non-contingent amount does not fulfil the definition of an asset according to the Conceptual Framework.“ (Deutsche Telekom)423
„[L]imiting the amount of consideration that can be allocated to a satisfied separate performance obligation is tantamount to cash-basis accounting and does not meet the core principle of the proposed requirements.[…] recognising a contract asset in the situation described in paragraph BC195 is appropriate because the entity clearly has a valuable contractual right as a result of satisfying a performance obligation and that right meets the definition of an asset.“ (IASB/FASB)425
„Furthermore, the proposed model involves the use of estimations to a greater extent thereby increasing complexity and potentially decreasing reliability and comparability of the information.“ (Telefónica)428
„In those circumstances, the most reliable way of determining the stand-alone selling price in the contract will often be to use a residual approach.“ (IASB/FASB)429
„A contract can indeed bundle separate performance obligations, and unbundling all separate performance obligations would be unnecessarily complex.“ (Roche)433„[I]n theory, we do not have an issue with allocating the transaction price to all separate performance obligations. Our concem again is with the practical application of this principle.“ (Alcatel Lucent)434„We are concerned that the “performance obligation” approach to revenue recognition will not improve the existing financial reports, for our particular industry, and will increase the cost of financial reporting and reduce the availability of surety credit to an industry that is already suffering amidst an economic downturn.“ (Hatcher Construction)435
„Consequently, when considering how entities across various industries should identify separate performance obligations, the boards’ objective was to develop requirements that would result in an entity recognising revenue and profit margins in a manner that faithfully depicts the transfer of goods or services to the customer and that would be practical.“ (IASB/FASB)438„These requirements were developed on the basis of extensive consultation and attempts to separate contracts in a meaningful and cost-effective way with intuitive outcomes.“ (IASB/FASB)439
„Specifically, the functional interdependence between deliverables within distinct arrangements is a factor that is not sufficiently covered by the current proposal. For example, consider two arrangements entered into and fulfilled in parallel with one deliverable each where the prices are fixed and equal the respective list prices but where the deliverable of the one arrangement is essential to the deliverable of the other arrangement […].“ (SAP)441„The boards were concerned that requiring an entity to account separately (and estimate a stand-alone selling price) for a good or service that is not capable of providing a benefit to the customer might result in information that would not be relevant to users of financial statements. For example, if an entity transferred a machine to the customer, but the machine is only capable of providing a benefit to the customer after an installation process that only the entity can provide, the machine would not be distinct.“ (IASB/FASB)442
3.2.2.2.4 Verwendung von Ethos zur Legitimation formaler und inhaltlicher Standardsetzungskompetenz
„The next section considers some of the problems in US GAAP and IFRSs.“ (IASB/FASB)446„Because revenue is a crucial number to users of financial statements, the boards think that having a common standard on revenue for IFRSs and US GAAP is an important step towards achieving the goal of a single set of high quality global accounting standards.“ (IASB/FASB)447
„We believe that a contract by contract assessment of the treatment of these materials […] on this basis would be burdensome for any member of the E&C industry that operates in multiple jurisdictions (in fact, individual contracts can be constructed in multiple jurisdictions), and would result in otherwise similar transactions receiving different accounting.“ (Kiewit)449„As written, it is also unclear whether paragraph 29 would apply to the software/services industry or whether it only applies to the construction of physical assets such as buildings. For example, IBM sells “bundles” of software and services in which the software is significantly modified to meet the needs of the customer.“ (IBM)450
„We support the Boards’ efforts to simplify the complex framework of revenue recognition standards currently in place under U.S. Generally Accepted Accounting Principles (U.S. GAAP), and we agree that the goal of a single standard for revenue recognition across all industries is a worthy objective.“ (General Dynamics)452„NTT DOCOMO, INC. is a large mobile telecommunication services provider with operations principally in Japan. Our shares have been listed on the First Section of the Tokyo Stock Exchange. Our shares have been also quoted and traded through the New York Stock Exchange and the London Stock Exchange. Therefore, we are preparing our consolidated financial statements in accordance with accounting principles generally accepted in the United States of America (“U.S. GAAP”). In this regard, we fully support the International Accounting Standards Board and the Financial Accounting Standards Board’s intention to develop a single principle for revenue recognition.“ (NTT Docomo)453
„The Boards have defined a performance obligation as “a promise in a contract with a customer to transfer an asset (such as a good or a service) to that customer.” We generally agree with the Boards’ definition of a performance obligation but believe this area requires further clarification.“ (Apple)456„The solution of allocating the transaction price to separate performance obligations contemplated by the board is quite understandable from our point of view. In our opinion it leads to sensible outcomes. Nevertheless, we consider the allocation of the transaction price to separate performance obligations to be only necessary for a few industrial sectors.“ (Volkswagen)457
„This discussion paper invites comments on the boards’ preliminary views on a single, contract-based revenue recognition model.“ (IASB/FASB)459„In response to questions from respondents, the boards decided to specify that a residual approach might be a suitable technique for estimating the stand-alone selling price of a good or service.“ (IASB/FASB)460
„As the standard is currently drafted, we believe we may be precluded from separating software license and PCS obligations in bundled transactions since the resources, costs and profit margin would not be separately identifiable. This would result in financial statements that are not reflective of the economics of the transaction.“ (Blackbaud)462„We believe application of the model proposed by the Revised ASU will result in accounting for items as performance obligations when they are no more than sales incentives, which will result in accounting for these items in a manner that is different from the way in which the underlying business is managed.“ (General Motors)463
„There are significant concerns in the surety community about any approach that diminishes consistency and increases subjectivity.“ (DPR Construction)464„We agree with EFRAG that only the entity’s own customary business practice should be considered when determining distinct goods and services, rather than the business practice of any other entity.“ (Maersk)465
„Compared with the proposals in the discussion paper, there would be fewer instances under the proposed requirements in which the transaction price would be allocated using estimates of stand-alone selling prices.“ (IASB/FASB)466„Hence, the boards affirmed their proposal in the 2010 exposure draft not to specify a hierarchy. Instead, the boards decided that it was important to emphasise that an entity should maximise the use of observable inputs when developing estimates of stand-alone selling prices“ (IASB/FASB)467
3.2.2.2.5 Verwendung rhetorischer Stilmittel bei allen Überzeugungsarten
„Most respondents agreed with the boards’ proposals in the discussion paper, although some suggested that the boards should consider whether: […] to constrain the use of estimates and specify a hierarchy for the basis of allocation […].[…] The boards reaffirmed the view they expressed in the discussion paper that they will not preclude or prescribe any particular method for estimating a stand-alone selling price […].“ (IASB/FASB)472
„The practical expedient is intended to address the concerns raised by some respondents that they frequently would have to identify numerous performance obligations and account for them separately.“ (IASB/FASB)473
„The company proposes that the definition of a performance obligation [...] be amended to include the concept that the performance obligation must have stand-alone customer value as a good or service. Otherwise, the company is concerned that performance obligations may be disaggregated to a level of detail which would be unnecessary and not useful to financial statement users.“ (IBM)475„When the goal is to improve overall contract profitability, reporting separate gain or loss on interdependent obligations within the contract is misleading to financial statement users who will only see a portion of the results of decisions that have been made.“ (Kiewit)476„The boards were concerned that requiring an entity to account separately (and estimate a stand-alone selling price) for a good or service that is not capable of providing a benefit to the customer might result in information that would not be relevant to users of financial statements.“ (IASB/FASB)477
„We generally agree that the transaction price should be allocated to all separate performance obligations in a contract in proportion to the stand-alone selling price of the good or service underlying each of those performance obligations. However, we strongly recommend maintaining the FASB’s provision under ASC 605-25-30.“ (Deutsche Telekom)481
„Because those goods and services are assets, the computer manufacturer’s promise to deliver a computer could, in concept, be separated into many performance obligations. In practice, however, identifying many performance obligations in a contract such as the above example and accounting for them separately would be unnecessarily complex.“ (IASB/FASB)483
3.2.3 Rekonstruktion relevanter story-lines im Sinne der argumentativen Diskursanalyse
3.2.3.1 Rekonstruktion der „user needs“ story-line
„Current contract accounting standards require an estimate to be made of a single gross margin for all production units expected to be delivered. […] A consistent profit margin estimate for all goods delivered under the contract provides financial statement users with more decision-useful contract information than separating performance obligations and potentially recognizing different profit margins on the same product under the same contract with a single customer.“ (United Technologies)494„Even if a good or service has a distinct function, the boards decided that it should be accounted for as separate performance obligation only if it also has a distinct profit margin. If a good or service does not have a distinct profit margin, the boards were concerned that requiring an entity to estimate a selling price for that good or service might result in information that would not be useful to users of financial statements.“ (IASB/FASB)495
„Our concern with applying a more theoretical view of what could potentially be sold separately will be difficult to apply in practice and will not result in more information for users of the financial statement.“ (Cisco)496„In the 2010 exposure draft, the boards proposed that a good or service is distinct if it is sold separately (by the entity or by another entity) or if it could be sold separately. The boards were concerned that requiring an entity to account separately (and estimate a stand-alone selling price) for a good or service that is not capable of being sold separately might result in information that would not be useful to users of financial statements.“ (IASB/FASB)497
„Current revenue recognition principles under US GAAP, and as generally applied by the telecommunications industry, ensure that revenue is not recognised for payments from customers that are contingent on the delivery of future services. We believe that this is of great value to users of the financial statements as recognised revenue is closely related to billings and cash received from the customer and the impact of management estimation is reduced. It is our belief that discarding the contingent revenue cap would be viewed negatively by users of the financial statements.“ (Vodafone)500„Our primary concern with the proposed standard has been, and continues to be, the reduction in the usefulness of information to the users of our financial statements should this proposed standard become effective.“ (Sprint Nextel)501
3.2.3.2 Rekonstruktion der „economic reality“ story-line
„We believe that the proposed model will improve upon existing revenue recognition guidance by allowing the allocation of the transaction price to the performance obligations on the basis of the entity’s standalone selling prices of the goods or services underlying those performance obligations. […] The change in the measurement approach from current practice to the proposed standard will allow companies to better reflect the underlying economics of an arrangement.“ (Intel)510
„In multiple element transactions, the DP proposes the allocation, at the inception of the contract, of the transaction price in proportion to the stand-alone selling price of each performance obligation (the relative stand-alone selling price method). This method does not reflect the substance of the telecommunications business where the huge amount of capital expenditures for network is earned from the rendering of services rather than through the sale of equipments to customers.“ (Telecom Italia)511
„The boards proposed that an entity should allocate the transaction price in proportion to the stand-alone selling prices of the promised goods or services. They noted that an allocation based on stand-alone selling prices faithfully depicts the different margins that may apply to promised goods or services.“ (IASB/FASB)512
„For bundled arrangements including performance obligations that are fulfilled at different moments in time, revenue should only be allocated to those obligations to the extent that the allocated revenue does not exceed the legally enforceable payments due from the customer under the terms of the contract without the delivery of future services. We consider that applying the contingent revenue cap would result in financial information that better reflects the economics of this type of transactions.“ (Telefónica)513„However, we believe that the proposed standard results in accounting which is even more disconnected from the underlying economics of our contracts and does not appropriately consider the value exchange from the customer’ s perspective.“ (Sprint Nextel)514
„Additionally, the boards decided not to introduce an exception to the revenue model for telecommunications and similar contracts because they do not view those contracts to be unique. Furthermore, the boards decided that the proposed requirements would provide a more consistent basis for recognising revenue and would produce results in accounting that more closely match the underlying economics of transactions.“ (IASB/FASB)516