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HMRC internal manual

Bank Levy Manual

From
HM Revenue & Customs
Updated
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Chargeable equity and liabilities: relevant entities and groups: foreign banking groups: GAAP differences: other local GAAPs

Other local GAAPs are known to include significant differences from IAS, such as:

French GAAP

French GAAP is understood to contain a number of significant differences from IAS, including non recognition of derivatives on balance sheet.

German GAAP

German GAAP permits recognition of losses on derivatives but may not recognise fair value gains on derivatives.

Canadian GAAP

Canadian GAAP asset derecognition rules focus on control, rather than the risks/rewards based approach of IAS 39, which may lead to different treatment.

Where foreign banking groups are required to report under IAS in their consolidated accounts (for example most European banks, Canadian banks from 2011), it is expected that there should not be a significant compliance burden associated with identifying and adjusting for those significant GAAP differences, given that such adjustments must already be carried out for group reporting purposes.