On 1 February 2013 the IVSC announced the release of an Exposure Draft dealing with amendments to IVS 2011.

Similar documents
MARKET VALUE BASIS OF VALUATION

TECHNICAL INFORMATION PAPER - VALUATIONS OF REAL PROPERTY, PLANT & EQUIPMENT FOR USE IN AUSTRALIAN FINANCIAL REPORTS

RE: Request for Comments on the Exposure Draft The Valuation of Forests dated November 16, 2012

This version includes amendments resulting from IFRSs issued up to 31 December 2009.

.01 The objective of this Standard is to prescribe the accounting treatment for investment property and related disclosure requirements.

International Valuation Standards Board 15 Feb Moorgate London EC2R 6PP United Kingdom

ANZVGN 9 ASSESSING RENTAL VALUE

EXPOSURE DRAFT Proposed Guidance Note The Valuation of Investment Property under Construction. February 2010 August 2009

HKAS 40 Revised January 2017April Hong Kong Accounting Standard 40. Investment Property

International Conference A comprehensive approach to NPL resolution international experiences Collateral valuation an appraisers perspective

Investment Property AASB 140. Compiled AASB Standard RDR Early Application Only

International Valuation Standards Update

TECHNICAL INFORMATION PAPER - MARKET VALUE OF PROPERTY, PLANT & EQUIPMENT IN A BUSINESS

Sri Lanka Accounting Standard-LKAS 40. Investment Property

International Business Valuation Standards

International Accounting Standard 40. Investment Property

VALUATION REPORTING REVISED Introduction. 3.0 Definitions. 2.0 Scope INTERNATIONAL VALUATION STANDARDS 3

BEST PRACTICE PINZ. Valuation and Property Standards Board

International Financial Reporting Standards (IFRSs ) 2004

New Zealand Equivalent to International Accounting Standard 40 Investment Property (NZ IAS 40)

Valuation and the Real Estate Market; a new paradigm for a new decade

PRINCIPLES OF VALUATION

IAG Conference Accounting Update Emerging issues in the public sector 20 November 2014 Michael Crowe Yannick Maurice

Fair value implications for the real estate sector and example disclosures for real estate entities. Applying IFRS in Real Estate

EN Official Journal of the European Union L 320/323

7829 Glenwood Avenue Canal Winchester, Ohio November 19,2013

Technical Corrections and Improvements to Recently Issued Standards

First Exposure Draft of proposed changes for the edition of the Uniform Standards of Professional Appraisal Practice

NETHERLANDS COUNCIL FOR REAL ESTATE ASSESSMENT

proceed with the proposals in ED 64 for lessee accounting, except for concessionary leases;

Re: File Reference: No , Exposure Draft: Leases (Topic 842)

IASB Exposure Draft ED/2013/6 - Leases

FASB Emerging Issues Task Force. Issue No Title: Accounting by Lessees for Maintenance Deposits under Lease Arrangements

LEASES ICAEW REPRESENTATION 75/18

In December 2003 the IASB issued a revised IAS 40 as part of its initial agenda of technical projects.

In December 2003 the Board issued a revised IAS 40 as part of its initial agenda of technical projects.

Financial reporting standards: is market value for the existing use now obsolete?

EXPOSURE DRAFT. Hong Kong Accounting Standard 40. Investment Property

Deloitte & Touche LLP

Property, Plant and Equipment

Paragraph 5.b. We ask that the Board provide a definition of the term biological assets.

In December 2003 the Board issued a revised IAS 17 as part of its initial agenda of technical projects.

ANZVGN 7 THE VALUATION OF PARTIAL INTERESTS IN PROPERTY HELD WITHIN CO-OWNERSHIP STRUCTURES

Business Combinations

In December 2003 the Board issued a revised IAS 40 as part of its initial agenda of technical projects.

International Accounting Standard 17. Leases

APPROVAL BY THE BOARD OF IAS 17 ISSUED IN DECEMBER 2003 BASIS FOR CONCLUSIONS DISSENTING OPINION IMPLEMENTATION GUIDANCE

27 September Hans Hoogervorst IFRS Foundation 30 Cannon Street, London EC4M 6XH. Dear Hans IASB ED/2013/6: LEASES

The actual universe of valuation standards

EVS Wolfgang Kaelberer, Hon REV. Global Valuation Opportunities and Challenges: European Valuation Standards

Sri Lanka Accounting Standard LKAS 40. Investment Property

PUBLIC BENEFIT ENTITY INTERNATIONAL PUBLIC SECTOR ACCOUNTING STANDARD 16 INVESTMENT PROPERTY (PBE IPSAS 16)

Sri Lanka Accounting Standard - SLFRS 16. Leases

Exposure Draft ED/2013/6, issued by the International Accounting Standards Board (IASB)

Restoring the Past U.E.P.C. Building the Future

The Influence of EU Regulation and European Valuation Standards on Real Estate Valuation

IAS 18. Revenue recognition Measurement & Disclosures

International Financial Reporting Standard 16 Leases. Objective. Scope. Recognition exemptions (paragraphs B3 B8) IFRS 16

Comment Letter 16 from the National Association of Romanian Valuers, ANEVAR

New Zealand Equivalent to International Accounting Standard 40 Investment Property (NZ IAS 40)

These FAQs reflect current views and understanding of the IASB project.

US Views on Valuation Methodology

General Valuation Concepts and Principles

SRI LANKA ACCOUNTING STANDARD INVESTMENT PROPERTY

Valuation Update 2017

(a) Assets arising from construction contracts (see Section 23 of FRS 102, Revenue); and

2018 KPMG Lower Gulf Limited, operating in the UAE and Oman, member firm of the KPMG network of independent member firms affiliated with KPMG

IAS 40 Investment Property

Valuation Presentation for the Residents of the Central Hill Estate

Thank you for the opportunity to comment on the above referenced Exposure Draft.

REPORT ON: VALUATION APPROACH AND METHODOLOGY FOR SPECIALISED AIRFIELD ASSETS (RUNWAY, TAXIWAYS AND APRONS) BY PROFESSOR TERRY BOYD 3 AUGUST 2001

ACCOUNTING STANDARDS BOARD STANDARD OF GENERALLY RECOGNISED ACCOUNTING PRACTICE INVESTMENT PROPERTY (GRAP 16)

LEASES CONTINUING FORWARD IFRS NEWSLETTER

Consolidation (Topic 810)

ACCOUNTING STANDARDS BOARD INTERPRETATION OF THE STANDARDS OF GENERALLY RECOGNISED ACCOUNTING PRACTICE

Submission on Exposure Draft 64: Leases

In December 2003 the IASB issued a revised IAS 17 as part of its initial agenda of technical projects.

EFRAG s Draft Letter to the European Commission Regarding Endorsement of Transfers of Investment Property

EFRAG s Letter to the European Commission Regarding Endorsement of Transfers of Investment Property

Re: Exposure Draft, Revenue from Contracts with Customers IASB Reference ED 2011/6

Valuation Update 2017

Agreements for the Construction of Real Estate

Senior management of alstria would be pleased to meet with the Boards or staff to discuss any questions regarding our comments.

TERMS OF ENGAGEMENT Name of the firm. Previous involvement with the property or parties to the case:

International Valuation Standards 2017 Queenstown 29 June Presenter Chris Stanley

TECHNICAL INFORMATION PAPER VALUATION OF SELF STORAGE FACILITIES

Comment on the Exposure Draft Leases

Determining whether an Arrangement contains a Lease

July 12, Dear Mr. Bean:

IASB Exposure Draft ED/2013/6 Leases

FASB Emerging Issues Task Force

LKAS 17 Sri Lanka Accounting Standard LKAS 17

APES 225 Valuation Services

New Clarity & Relief Proposed for Leases

Exposure Draft 64 January 2018 Comments due: June 30, Proposed International Public Sector Accounting Standard. Leases

Real Property Assets Policy and Procedures

Business Combinations

21 August Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom

Private Company Council. PCC Issue No Title: Applying Variable Interest Entity Guidance to Common Control Leasing Arrangements

TESCO. International Accounting Standards Board jst Floor

Transcription:

29 April 2013 IVSC Standards Board International Valuation Standards Council 41 Moorgate LONDON EC2R 6PP Dear Sirs, Exposure Draft Amendments to the International Valuation Standards On 1 February 2013 the IVSC announced the release of an Exposure Draft dealing with amendments to IVS 2011. The document was issued seeking a response from interested parties by 30 April 2013. The Australian Valuation Standards Board in general supports the amendments, however, where it believes further guidance is required, has provided the following for consideration. 1. Definitions: Proposed Change Valuation Date: The date on which the opinion of value applies. When and where applicable, the valuation date shall also include the time on which it applies if the value of the type of asset can be observed as changing materially in the course of a single day. The Australian Property Institute has added the words where and when applicable to further clarify what is meant. 2. Definitions: (a) The eighth edition of the International Valuation Standards included the following definition: Highest & Best Use The most probable use of a property which is physically possible, appropriately justified, legally permissible, financially feasible, and which results in the highest value of the property being valued. The IVSC International Valuation Glossary now defines Highest & Best Use as: The use of an asset that maximises its value and that is physically possible, legally permissible and financially feasible. As the concept of highest and best use is critical to the determination of market value the Australian Property Institute is of the opinion it should also form part of the definitions in the revision of IVS 2011. 1

However, before such inclusion the question as to whether it should more accurately read The use of an asset or liability... rather than The use of an asset.. needs to be resolved. Does a liability have a HABU? It is also noted that the Accounting Standards define Highest & Best Use as: The use of a non-financial asset by market participants that would maximise the value of the asset or the group of assets and liabilities (eg a business) within which the asset would be used. An alternative definition for consideration by IVSC is: The most probable use of a non-financial asset that maximises its value and that is physically possible, legally permissible and financially feasible. We are talking about the HABU of real estate, plant and equipment etc. Because of the circumstances surrounding some zoning laws the use cannot always be absolutely determined as is implied in the current wording. The existing wording has the real potential to leave valuers exposed to legal challenge. (b) The eighth edition of the International Valuation Standards included the following definition: Market Rent The estimated amount for which a property, or a space within a property, should lease on the date of valuation between a willing lessor and a willing lessee on appropriate lease term s in an arm s-length transaction, after proper marketing wherein the parties had each acted knowledgeably, prudently, and without compulsion. Wherever market rent is provided, the appropriate lease terms which it reflects should also be stated. IVS 2011 and the IVSC International Valuation Glossary now define Market Rent as: The estimated amount for which a property would be leased on the valuation date between a willing lessor and a willing lessee on appropriate lease terms in an arm s length transaction, after proper marketing and where the parties had each acted knowledgeably, prudently and without compulsion. However, the issue is whether: the word property should be replaced by asset or asset or liability. the words and where should be replaced by wherein to ensure consistency with the recommended wording of market value. The word would to be replaced by should in line with the definition of market value (c) The eighth edition of the International Valuation Standards included the following definition: Market Value The estimated amount for which a property should exchange on the date of valuation between a willing buyer and a willing seller in an arm s-length transaction after proper marketing wherein the parties had each acted knowledgeably, prudently, and without compulsion. IVS 2011 now defines Market Value as:

The estimated amount for which an asset or liability should exchange on the valuation date between a willing buyer and a willing seller in an arm s-length transaction after proper marketing and where the parties had each acted knowledgeably, prudently, and without compulsion. The IVSC International Valuation Glossary now defines Market Value as: The estimated amount for which an asset or liability should exchange on the date of valuation between a willing buyer and a willing seller in an arm s-length transaction after proper marketing wherein the parties had each acted knowledgeably, prudently, and without compulsion. The Australian Property Institute would prefer that the Glossary definition appear in the revised version of IVS and all TIPs. Currently the documents / definitions refer to Property, Asset or Asset or Liability. Irrespective of the decision of the IVSC, the terms used need to be consistent in all documents. It would also be appropriate for guidance to be provided on whether the IVSC believes the words asset or asset or liability interchangeable as an accepted definition of market value. Some members believe the word liability is at odds with fee simple and could be taken to include mortgage debt in use of the market value definition / terminology asset or liability. 3. IVS Framework 3 and 4. Proposed Change: Independence and Objectivity 3 Many states have laws or regulations that only allow certain persons to value particular classes of assets for various purposes. Additionally, many professional bodies and valuation providers have ethical codes that require the identification and disclosure of potential conflicts of interest. The purpose of these standards is to set internationally recognised principles and definitions for the preparation and reporting of valuations. They do not include regulations on the relationship between those commissioning valuations and those undertaking them, as Whilst the Exposure Draft proposes to delete the above, the Institute believes there is merit in retaining the wording as it is an important statement that warns those who may otherwise see an internationally endorsed Standard as overriding state/national laws. 6. IVS Framework: 30 Proposed Change: 30 Market value is the estimated amount for which an asset or liability should exchange on the valuation date between a willing buyer and a willing seller in an arm s length transaction, after proper marketing and where the parties had each acted knowledgeably, prudently and without compulsion.

Reason: consistency with approved definition. (note: this was a publishing error in the printed version on IVS 2011 only) As stated earlier there is a need to ensure consistency of definitions in all documents i.e. IVS, TIPs and the International Valuation Glossary. Whilst the wording would be consistent with the current definition of IVS 2011 it would not be consistent with the wording in the IVS International Valuation Glossary or recent Exposure Drafts / Discussion Papers. The Institute would prefer the Glossary definition, however, consistency is paramount. 7. IVS Framework: 31 (c) Proposed Change: (c) the date of valuation requires that the value is date specific, and when and where applicable is time-specific as of a given date. Because markets and market conditions may change, the estimated value may be incorrect or inappropriate at another time. The valuation amount will reflect the actual market state and circumstances as of the effective valuation date, not as of either a past or future date. The definition also assumes simultaneous exchange and completion of the contract for sale without any variation in price that might otherwise be made; This is a reflection that prices and therefore values of certain asset classes such as equities, debt instruments and derivatives change during the course of the day. For asset classes such as real property, plant and equipment it is not necessary to record a time applying to the valuation. Reason: The references to exchange and completion are specific to certain countries systems of contract law and are therefore potentially confusing to readers unfamiliar with these terms. The definition of market value refers to an exchange on the valuation date, meaning that the agreed price is fixed and the asset transferred on that date. Under certain legal systems a contract is said to be exchanged when the contract becomes binding and completed when the transfer of the asset actually takes place, which may be on a later date. This alternative meaning of exchange in the conceptual framework for market value potentially causes confusion. And in any event, the price is fixed when a legally binding contract is entered into (legal exchange), not at any later physical exchange of the assets subject to that contract (legal completion), so the point being made by this sentence is redundant as price does not vary between exchange and completion The suggested additional amendments are in line with the Institutes recommended wording to the amended definition of Valuation Date as well as attempting to provide further clarity. It should also be noted that 31 (b), 33 and 34 if applicable need to be amended if we are talking about assets and liabilities. They currently refer to assets only. 22. IVS 230 Annexe Historic Property Proposed Change Remove the annexe from the IVSs. Reason: The Board does not consider that there are sufficient unique requirements or considerations when valuing historic (real) property that warrant the inclusion of this annexe in the standards. It also provides only guidance, which under current IVSC protocols should be included in a TIP. The guidance provided is similar to that in the proposed TIP on Specialised Public Sector Assets that was issued in late 2012. One proposal is to remove this annexe to this future TIP, or it may be issued as a standalone paper providing information and guidance on some of the valuation criteria to be considered.

The eighth edition of the International Valuation Standards included GN 15 Valuation of Historic Property. This was subsequently carried forward into IVS 2011 as an annexe to IVS 230 Real Property Interests. If the IVSC is now to delete the annexe from IVS the Institute believes it would be appropriate for the IVSC to produce a separate TIP on this matter. It should be noted that not all historic property resides in the hands of government. The alternative would be for individual professional bodies to develop their own TIP dealing with historic (real) property. 23. IVS 233 Investment Property Under Construction C10 and C11 Proposed Change C10 C11 The exact valuation inputs used will vary with the valuation model being used but will normally include those listed in this section. The inputs will also vary depending on whether a growth-implicit or growth-explicit model is nominal or real cash flow inputs are being used, see para C10 above. Typical inputs include: (a) Completed property If a growth-implicit model is used, this will reflect the value of the investment property as if complete, ie The value of the completed property may be based on current values on the special assumption its value on the assumption that on the valuation date it had already been completed in accordance with the current specification or. If a growth-explicit model is used, this will reflect the projected value of the property upon completion, ie the expected value of the property on the date when it is anticipated to be complete. The choice will depend upon the availability of data to support either current or projected values and should also be consistent with the other cash flows reflected in the model. Care must also be taken to ensure that the discount rate used is commensurate with the valuation of the completed property, ie regardless of whether the completed value is based on current values or projected values the discount rate must also be derived on the same basis. Reason: The terms growth implicit and growth explicit were used in the Exposure Draft of TIP 1 on DCF. However, it was clear from the responses to that ED that these terms are not widely understood. Also, the existing text made no reference to nominal and real DCF models which are discussed in the published TIP1. Some confused the concept of growth explicit and implicit inputs with real and nominal inputs although this is incorrect as growth is not synonymous with inflation. The original consultation on the 2010 Guidance Note upon which IVS 233 is based revealed that in some markets the practice is to use current values and costs as inputs into the calculation of the value of IPUC and in others projected values and costs are the norm. From a standards perspective either is acceptable providing there is consistency across all inputs in the model. Given that TIP 1 has now been developed and published the Board believes that there is no need to label different types of input beyond the broadly understood categories of nominal and real and is proposing the changes to bring consistency with the published TIP 1. It should also be noted that IVS 233 is under review as part of the on-going Investment Property Project. These currently proposed changes deal only with inconsistencies with TIP1. The API is of the opinion that valuation of investment real estate under construction is a complex area of valuation as it requires the consideration of development and investment cash flow logic. If it is the intention of the Standard to require an entity holding investment real estate under construction to value the investment under construction at the financial reporting date the API is of the view that additional guidance is needed to explain the practical issues of such valuation.

This is needed as such property does not usually transact in an open market willingly. Sales evidence is usually the subject of a forced or distressed sale situation i.e. not a transaction that satisfies the market value test. Another complexity is the fact the valuation methodologies, and analysis software models differ for a development when compared to an investment. It is rare to consider a valuation methodology that spans a development and sell period as well as an investment holding period following completion of the development in Australia. Most development and investment software models (including off the shelf models and proprietary models are based on discounted cash flow logic, implicit in which is the expectation that growth in cash outflows and cash inflows should be included. The adoption of growth in such a model also assumes that the discount rate applied is mindful of the growth in cash outflows and cash inflows. For this reason the API is of the opinion that there is merit in retaining the reference to growth and the nature of the model. Notwithstanding the inclusion of growth in any valuation model for an investment or a development the API is of the opinion that Valuations must be reported in Current Value terms as at the date of valuation which is one in the same at the date of inspection. This has been the position of the corporate regulator in Australia (Australian Securities and Investments Commission (ASIC) in a number of its regulatory guides relating to raising debt and equity for AREITS and unregulated capital raisings. In particular ASIC requires values to be determined at the current (Date of Valuation and Inspection terms) As is and As If Complete. The As Is and As if complete logic would be a beneficial addition to the IVSC s Standard on Valuation of Investment Property Under Construction as it differentiates between the property at the entities balance date/ valuation date and upon completion. Should this Standard continue to support either option, it will be up to bodies like the Australian Property Institute to advise its membership of the need to value in accordance with legislative and Institute requirements. However, it does beg the question as to when the IVSC considers the future value option as acceptable and how such a position is treated by regulators, mortgage lenders and those in the professional indemnity insurance markets in other world regimes. Yours faithfully, A.L. McNamara Professional Standards Manager Australian Property Institute