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HMRC internal manual

Bank Levy Manual

Chargeable equity and liabilities: relevant foreign banks: attribution of chargeable equity and liabilities to a branch: calculation of branch liabilities: GAAP differences: other local GAAPs

It is recognised that in a number of territories, local GAAP will be required for domestic reporting purposes for foreign banks. Such 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.