How should companies assess and account for multiple exchange rates and lack of exchangeability?

Assessing lack of exchangeability

Whenever no legal mechanisms exist, the company cannot access one or more of the exchange mechanisms available in practice, or an exchange rate is not available for immediate delivery due to economic uncertainty, judgement may be needed to determine whether the lack of exchangeability is temporary or long term.

Temporary

If the lack of exchangeability is temporary, then a company considers the use of the first subsequent rate at which exchanges could be made. [IAS 21.26]

If such a rate does not exist, then this may indicate that the lack of exchangeability is long term. [Insights 2.7.93.30]

Long term

If the lack of exchangeability is long term, then the company considers the rate to which it would have access at the measurement date through a legal exchange rate mechanism. This will normally be the official rate. During periods of economic uncertainty, it is particularly important that the company reassess at each reporting date whether the official exchange rate meets the IAS 21 definition of a closing rate and, if applicable, the spot exchange rates at the dates of the foreign currency transactions. However, the use of an unofficial exchange rate (see below) may be more appropriate in very limited circumstances. [Insights 2.7.93.20–30]

Translation of foreign currency financial statements

In some countries there may be dual exchange rates: the official exchange rate and an unofficial parallel exchange rate. In our view, when a foreign operation operates in a dual exchange rate environment (which may be the case when exchangeability is lacking such that multiple unofficial rates exist), its financial statements should be translated using the rate applicable to dividends and capital repatriation because this is how the investment in the foreign operation will be recovered. [Insights 2.7.250.10]

Determining the rate to use when there is a long-term lack of exchangeability

In our view, the determination of which rate to use in these circumstances may be a matter of judgement and the conclusion may change over time. For example, although a company may legally apply to a government agency for foreign currency at the official rate for the purpose of paying dividends, it may also be able to effect dividends or capital repayments through parallel market transactions. We believe that a company should consider all relevant facts and circumstances to determine what is the more appropriate rate to use for the purposes of translation, including:

• practical difficulties, uncertainties or delays associated with applying for foreign currency at the official rate;
• whether a company would plan to remit a dividend or repayment of the net investment through an application for funds at the official rate or through parallel market transactions;
• past and current practice in relation to the remittance of dividends and capital; and
• the ability to source funds for dividend or capital repayments through parallel market transactions. [Insights 2.7.250.15]

Disclosures

A company discloses its significant accounting policies, and the judgements that management makes in applying the company’s accounting policies, that have the most significant effects on the amounts recognised in the financial statements.

This may include the following.

• The judgements made and the reasons for selecting one specific foreign exchange rate rather than another when more than one foreign exchange rate exists.
• Where there are multiple exchange rates, the determination of spot or closing rates may be a source of estimation uncertainty. Therefore, in these cases, the company may be required to disclose information about that source if it has a significant risk of resulting in a material adjustment to carrying amounts of assets or liabilities in the next financial year.
• In our view, companies should disclose the reasons for not applying an official exchange rate as well as information about the rate used, if a rate other than the official rate has been used.

The IFRS^® Interpretations Committee has drawn attention to the requirement to disclose the nature and extent of significant restrictions on a company’s ability to access or use assets and settle liabilities of the group, or in relation to its joint ventures or associates under specific scenarios. [Insights 2.7.250.20, 40, 50]

Actions for management

When there are multiple exchange rates and lack of exchangeability:

• assess whether the lack of exchangeability is temporary or long term;
• determine which rate to use in the presence of multiple exchange rates;
• consider all relevant facts and circumstances in determining a rate to use; and
• disclose significant judgements that were made in selecting a specific spot rate or, under very limited circumstances, reasons for not applying an official exchange rate and information about the rate used.

Amendments to IAS 21 to address a lack of exchangeability have been finalised and are available for early adoption.

References to ‘Insights’ mean our publication Insights into IFRS^®