Deferred Tax on IFRS 16 Leases: 2023 IAS 12 Amendment

Published: January 8, 2025 | Reading Time: 9 minutes

The intersection of IFRS 16 lease accounting and deferred tax has been a source of confusion since IFRS 16's adoption in 2019. This changed dramatically on January 1, 2023, when amendments to IAS 12 "Income Taxes" became effective, fundamentally changing how companies account for deferred tax on leases.

This guide explains the deferred tax implications of IFRS 16 leases, the 2023 IAS 12 amendment, and provides practical examples with calculations for Singapore and Malaysia entities.

Background: Why Deferred Tax Arises on IFRS 16 Leases

The Fundamental Mismatch

IFRS 16 creates a temporary difference between accounting and tax treatment of leases:

Accounting Treatment (IFRS 16)

Balance Sheet:

  • ROU Asset recognized
  • Lease Liability recognized

P&L Impact:

  • Depreciation expense (on ROU asset)
  • Interest expense (on lease liability)
  • Front-loaded: Higher expense in early years

Tax Treatment (IRAS / LHDN)

Tax Base:

  • No ROU asset recognized (tax base = nil)
  • No lease liability recognized (tax base = nil)

Tax Deduction:

  • Deduct actual lease payments as incurred
  • Straight-line pattern over lease term
  • No depreciation or interest concepts

The Result: Temporary Differences

Because accounting expense (depreciation + interest) ≠ tax deduction (lease payment), temporary differences arise that reverse over the lease term.

This triggers deferred tax accounting under IAS 12.

Before 2023: The Initial Recognition Exemption (IRE)

Prior to January 1, 2023, many companies applied the Initial Recognition Exemption in IAS 12.15:

IAS 12.15 (Original): Deferred tax is NOT recognized for temporary differences arising from the initial recognition of an asset or liability in a transaction that:

  • Is not a business combination, AND
  • At the time of transaction, affects neither accounting profit nor taxable profit

Impact: Many entities argued IFRS 16 leases qualified for IRE and did not recognize deferred tax. This created:

  • Diversity in practice (some recognized, some didn't)
  • Lack of comparability
  • Significant unrecognized deferred tax amounts

The 2023 IAS 12 Amendment

Amendment: Deferred Tax related to Assets and Liabilities arising from a Single Transaction

Effective Date: January 1, 2023 (with early adoption permitted)

Issued: May 2021

Key Change

The IASB narrowed the scope of the initial recognition exemption by adding paragraph 15A to IAS 12:

IAS 12.15A (New Rule):

The initial recognition exemption does NOT apply to transactions that, on initial recognition, give rise to equal taxable and deductible temporary differences.

Impact on IFRS 16 Leases

IFRS 16 leases create equal and offsetting temporary differences:

  • ROU Asset: Carrying amount > Tax base (nil) = Taxable temporary difference → DTL
  • Lease Liability: Carrying amount > Tax base (nil) = Deductible temporary difference → DTA
  • At inception: These are equal in amount

Conclusion: The IRE no longer applies to leases. Companies MUST recognize deferred tax.

Transition Requirements

Retrospective Application: The amendment is applied retrospectively, but with practical relief:

  • Comparative Information: Not required to restate comparatives
  • Cumulative Effect: Adjust opening retained earnings and other components of equity at Jan 1, 2023
  • Opening Balances: Recognize DTA and DTL for all existing leases as of Jan 1, 2023
Practical Impact: Most companies recognized a one-time adjustment in their January 1, 2023 opening balance sheet, with equal DTA and DTL (net impact often close to zero, but disclosure required).

How to Calculate Deferred Tax on Leases

Step-by-Step Methodology

Step 1: Identify Carrying Amounts (Accounting)

From your IFRS 16 lease schedule:

  • ROU Asset Carrying Amount: Original cost - Accumulated depreciation
  • Lease Liability Carrying Amount: From amortization schedule (Opening + Interest - Payment)

Step 2: Determine Tax Bases

Under most tax jurisdictions (Singapore, Malaysia, etc.):

  • ROU Asset Tax Base: Nil (not a tax-deductible asset)
  • Lease Liability Tax Base: Nil (not a tax liability; tax deduction only on payment)

Step 3: Calculate Temporary Differences

Temporary Difference = Carrying Amount - Tax Base


ROU Asset:

Taxable Temporary Difference = ROU Asset Carrying Amount - Nil

Results in Deferred Tax Liability (DTL)


Lease Liability:

Deductible Temporary Difference = Lease Liability Carrying Amount - Nil

Results in Deferred Tax Asset (DTA)

Step 4: Apply Tax Rate

DTL = Taxable Temporary Difference × Tax Rate

DTA = Deductible Temporary Difference × Tax Rate


Singapore Corporate Tax Rate: 17%

Malaysia Corporate Tax Rate: 24%

Step 5: Net Presentation

IAS 12 allows offsetting of DTA and DTL if they relate to the same taxing authority:

  • Net DTA: If deductible > taxable temporary differences
  • Net DTL: If taxable > deductible temporary differences

Example: Singapore Office Lease

Scenario

TechStart Pte Ltd (Singapore) enters a 3-year office lease on January 1, 2024:

  • Monthly rent: $10,000
  • Lease term: 36 months
  • Payment timing: End of month
  • IBR: 5.0% per annum
  • Singapore corporate tax rate: 17%

Initial Recognition (January 1, 2024)

Lease Liability Calculation:
PV = $10,000 × [(1 - (1.004167)^-36) / 0.004167]
Initial Lease Liability = $338,688
Initial ROU Asset = $338,688

Initial Deferred Tax Calculation

Item Carrying Amount Tax Base Temp. Diff. DT @ 17%
ROU Asset $338,688 $0 $338,688 DTL: $57,577
Lease Liability $338,688 $0 $338,688 DTA: $57,577
Net Position $0

Journal Entry (January 1, 2024)

Dr. Deferred Tax Asset           $57,577
    Cr. Deferred Tax Liability        $57,577
(To recognize deferred tax on lease at commencement)

Note: Net P&L impact is nil at commencement because DTA = DTL.

After 12 Months (December 31, 2024)

Carrying Amounts After Year 1:

  • ROU Asset: $338,688 - ($338,688/36 × 12) = $225,792
  • Lease Liability (from amortization schedule): $230,850

Deferred Tax Calculation (Dec 31, 2024)

Item Carrying Amount Tax Base Temp. Diff. DT @ 17%
ROU Asset $225,792 $0 $225,792 DTL: $38,385
Lease Liability $230,850 $0 $230,850 DTA: $39,245
Net Position Net DTA: $860

Explanation: The lease liability reduces slower than the ROU asset (due to interest), creating a small net DTA over time. This reverses by lease end.

Example: Malaysia Equipment Lease

Scenario

ManufactureCo Sdn Bhd (Malaysia) leases equipment on January 1, 2024:

  • Quarterly payment: RM 50,000
  • Lease term: 16 quarters (4 years)
  • Payment timing: End of quarter
  • IBR: 6.0% per annum (1.5% per quarter)
  • Malaysia corporate tax rate: 24%

Initial Recognition

Lease Liability:
PV = RM 50,000 × [(1 - (1.015)^-16) / 0.015]
Initial Lease Liability = RM 706,565
Initial ROU Asset = RM 706,565

Initial Deferred Tax

DTL (on ROU Asset): RM 706,565 × 24% = RM 169,576

DTA (on Lease Liability): RM 706,565 × 24% = RM 169,576

Net Position: RM 0

Journal Entry

Dr. Deferred Tax Asset           RM 169,576
    Cr. Deferred Tax Liability        RM 169,576

After 4 Quarters (December 31, 2024)

Carrying Amounts:

  • ROU Asset: RM 706,565 - (RM 706,565/16 × 4) = RM 529,924
  • Lease Liability: RM 540,739 (from schedule)

Year-End Deferred Tax

DTL: RM 529,924 × 24% = RM 127,182

DTA: RM 540,739 × 24% = RM 129,777

Net DTA: RM 2,595

Movement in Year:

  • Opening: Net RM 0
  • Closing: Net DTA RM 2,595
  • Deferred Tax Benefit in P&L: RM 2,595

Regional Tax Authority Guidance

Singapore: IRAS Guidance

Reference: IRAS e-Tax Guide on FRS 116 (Updated for SFRS(I) 16)

Key Points for Singapore Entities:

  • Tax Deduction: Allowed based on actual lease payments made, not depreciation/interest
  • Timing Differences: Recognized as requiring deferred tax accounting under FRS 12 / SFRS(I) 1-12
  • Corporate Tax Rate: 17% (apply to temporary differences)
  • Disclosure: Must disclose deferred tax movements in tax reconciliation note

IRAS Position: The tax treatment is clear - lease payments are deductible when paid. The accounting treatment under SFRS(I) 16 does not change the tax treatment. Deferred tax must be recognized for the temporary differences.

Malaysia: LHDN / IRB Guidance

Inland Revenue Board of Malaysia (LHDN/IRB) position:

Key Points for Malaysian Entities:

  • Tax Deduction: Rental payments deductible under Section 33(1) of Income Tax Act 1967
  • Capital vs. Revenue: Operating lease payments are revenue expenditure (deductible)
  • MFRS 16 Impact: Accounting treatment does not affect deductibility - still based on payments
  • Corporate Tax Rate: 24% for resident companies (20% for SMEs on first RM 600k)
  • Deferred Tax: Required under MFRS 112 (equivalent to IAS 12)

Important: Malaysian companies must carefully document their deferred tax calculations in workpapers, as IRB may review deferred tax positions during tax audits.

Practical Implementation Challenges

Challenge 1: Data Requirements

Issue: Need period-by-period carrying amounts for ROU asset and lease liability.

Solution: Ensure your lease accounting system or spreadsheets track:

  • ROU asset carrying amount (cost - accumulated depreciation)
  • Lease liability balance at each reporting date
  • Changes during the period

Tip: Our IFRS 16 Calculator provides complete amortization schedules that feed directly into deferred tax calculations.

Challenge 2: Large Lease Portfolios

Issue: Companies with hundreds of leases face significant workload.

Solution: Consider:

  • Automation via lease accounting software with built-in tax tracking
  • Aggregation of similar leases for deferred tax purposes
  • Materiality thresholds for individual lease tracking

Challenge 3: Transition Adjustment (2023)

Issue: Calculating opening deferred tax for all existing leases as of Jan 1, 2023.

Solution:

  • Use December 31, 2022 lease register
  • Calculate DTA/DTL for each lease at that date
  • Aggregate and record as opening balance adjustment
  • Disclose in accounting policy note and tax note

Challenge 4: Lease Modifications

Issue: Modifications change ROU asset and liability - must update deferred tax.

Solution:

  • Recalculate temporary differences after modification
  • Adjust DTA/DTL accordingly
  • Recognize deferred tax impact in P&L (unless modification creates new asset)

Challenge 5: Different Tax Rates

Issue: Multiple jurisdictions with different tax rates.

Solution: Track deferred tax by jurisdiction:

  • Singapore leases: Apply 17%
  • Malaysia leases: Apply 24%
  • Other jurisdictions: Apply local rate
  • Cannot offset across jurisdictions

Challenge 6: Disclosure Requirements

Issue: Extensive disclosure required under IAS 12.

Required Disclosures:

  • Deferred tax asset and liability balances
  • Movement in deferred tax during the year
  • Tax reconciliation explaining DTA/DTL on leases
  • Impact of IAS 12 amendment adoption (one-time in 2023)

Key Takeaways

  1. Mandatory Since 2023: All companies must recognize deferred tax on IFRS 16 leases (IAS 12 amendment)
  2. Initial Recognition Exemption No Longer Applies: The 2023 amendment narrowed the IRE scope
  3. DTA and DTL Both Recognized: ROU asset creates DTL, lease liability creates DTA
  4. Net Position Often Small: At commencement, DTA = DTL; over time, small net position emerges
  5. Apply Appropriate Tax Rate: Singapore 17%, Malaysia 24%
  6. Track Period-by-Period: Need lease amortization schedules for accurate calculation
  7. Follow Local Tax Authority Guidance: IRAS in Singapore, LHDN in Malaysia
  8. Extensive Disclosure Required: Deferred tax note must explain lease-related movements

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