Impairment Testing — Goodwill and Cash-Generating Units Services

AASB 136 — The Impairment Framework

The principle is simple: an asset must not be carried at more than the amount recoverable through its use or sale. Where carrying amount exceeds recoverable amount, the difference is recognised as an impairment loss.

Recoverable amount is the higher of two measures:

Value in use (VIU) — The present value of the future cash flows expected to be derived from the asset or CGU in its current condition, discounted at a pre-tax rate reflecting current market assessments of the time value of money and the risks specific to the asset.

Fair value less costs of disposal (FVLCD) — The price obtainable in an orderly transaction between market participants, measured under AASB 13, less the incremental costs directly attributable to disposal.

Because recoverable amount is the higher of the two, an asset is only impaired if it fails both tests. In practice most entities calculate VIU first, and only prepare an FVLCD calculation where VIU produces an impairment or the headroom is thin. Where an observable market price or recent comparable transaction exists, FVLCD can be the more defensible measure — and occasionally the more favourable one.

When Testing Is Required

Annually, regardless of indicators — Goodwill, indefinite-lived intangible assets (including certain brands and licences), and intangible assets not yet available for use. The annual test may be performed at any point in the reporting period, provided it is performed at the same time each year, but a newly acquired CGU with goodwill must be tested before the end of the year of acquisition.

Whenever an impairment indicator exists — All other non-financial assets within scope. AASB 136 requires an assessment at each reporting date, including interim reporting dates for entities preparing half-year reports under AASB 134.

Indicators of Impairment

AASB 136 sets out external and internal indicators; the list is not exhaustive and the standard requires consideration of any other available evidence:

• Market capitalisation below the carrying amount of net assets — a strong indicator that auditors and ASIC treat as requiring explicit rebuttal
• Significant adverse changes in the market, technological, economic, or legal environment
• Increases in market interest rates or required rates of return affecting the discount rate
• Evidence of obsolescence or physical damage
• Significant adverse change in the extent or manner in which an asset is used, including restructuring or plans to dispose
• Actual cash flows or operating results materially worse than budget, or forecasts revised downward
• Loss of a major customer, contract, licence, or key personnel

Cash-Generating Units — Identification and Aggregation

Most assets do not generate cash flows independently, so impairment testing happens at the level of the smallest identifiable group of assets that generates cash inflows largely independent of other assets — the CGU.

How CGUs Are Determined

Identification turns on the independence of cash inflows, not on how the business is managed or reported. The test is whether the group of assets generates revenue from external customers separately from the rest of the entity. Relevant considerations include how management monitors operations (by product line, region, site, or business), how decisions about continuing or disposing of assets are made, and whether an active market exists for the output of the unit.

Common structures include the individual retail site or branch, the individual production facility, the product line or brand, the geographic operating segment, and the acquired business retained as a discrete unit.

CGU identification is one of the most consequential judgements in the whole exercise. Defining units too broadly allows a strong business to mask an underperforming one, which auditors will challenge. Defining them too narrowly can trigger impairments that the economics of the combined operation do not support. Once determined, CGUs must be identified consistently from period to period unless a change is genuinely justified — and any change requires disclosure.

Allocating Goodwill to CGUs

Goodwill acquired in a business combination must be allocated to the CGUs or groups of CGUs expected to benefit from the synergies of the acquisition. The allocation is subject to two constraints: it cannot be at a level higher than an operating segment as defined in AASB 8, and it must be at the lowest level at which goodwill is monitored for internal management purposes.

Because goodwill does not generate cash flows on its own, it is only ever tested as part of a CGU. Where goodwill cannot be allocated on a non-arbitrary basis to individual CGUs, it is tested at the level of the group of CGUs to which it relates.

Corporate and Shared Assets

Head office buildings, shared IT infrastructure, and other corporate assets do not generate independent cash inflows. AASB 136 requires them to be allocated to CGUs on a reasonable and consistent basis where such an allocation can be made — usually by revenue, headcount, or asset base. Where allocation is not possible, the entity tests the smallest group of CGUs that includes the corporate asset, in addition to testing each CGU individually.

Value in Use — Getting the Calculation Right

VIU is where most impairment testing is won or lost, and where auditors concentrate their attention.

Cash Flow Requirements

Current condition basis — Cash flows must reflect the asset in its current condition. This is the most commonly misapplied requirement. VIU excludes cash inflows and outflows expected from future restructurings to which the entity is not yet committed, and from enhancing or improving the asset’s performance. Maintenance capital expenditure is included; expansionary capex and the benefits it would generate are not.

Board-approved forecasts — Projections must be based on the most recent budgets and forecasts approved by management, generally covering a maximum of five years. A longer explicit period is permitted only where a longer forecast can be justified as reliable — a genuinely high bar that auditors will test against the entity’s forecasting track record.

Terminal growth rate — Cash flows beyond the explicit forecast period are extrapolated using a steady or declining growth rate. Exceeding the long-term average growth rate for the products, industries, or country in which the entity operates requires specific justification. A terminal rate above long-run GDP or inflation expectations is a standing audit query.

Exclusions — VIU cash flows exclude financing cash flows and income tax receipts and payments, since these are reflected in the discount rate and the pre-tax basis of the calculation.

The Discount Rate

AASB 136 requires a pre-tax discount rate reflecting current market assessments of the time value of money and the risks specific to the asset for which the cash flow estimates have not been adjusted.

In practice, entities build a post-tax WACC from observable market inputs — risk-free rate, equity risk premium, comparable company betas, target capital structure, and cost of debt — and then derive an equivalent pre-tax rate. The critical point, and a frequent error, is that the pre-tax rate is not the post-tax rate grossed up by dividing by (1 − tax rate). It must be derived iteratively, so that discounting pre-tax cash flows at the pre-tax rate produces the same VIU as discounting post-tax cash flows at the post-tax rate. Auditors test this derivation directly.

The rate must also carry any CGU-specific risk not already built into the cash flows — country risk, small-company or size premiums, and forecast risk — without double-counting risk already reflected in a probability-weighted or conservative forecast.

Common Errors That Draw Audit Findings

• Including expansionary capex and its associated revenue growth in the same model
• Grossing up the post-tax discount rate arithmetically instead of deriving the pre-tax rate iteratively
• Terminal growth rates unsupported by industry or macroeconomic evidence
• Cash flows inconsistent with the CGU’s asset base — forecasting revenue that requires assets not included in the carrying amount
• Including tax or financing flows in a pre-tax VIU calculation
• A carrying amount that omits allocated corporate assets or includes liabilities not consistent with the cash flow basis
• Forecasts that repeat the prior year’s optimism after that year’s actuals missed budget — a pattern auditors specifically look for

Fair Value Less Costs of Disposal

Where VIU is marginal or an observable market benchmark exists, FVLCD is the alternative measure — determined under AASB 13, so market-participant assumptions govern rather than entity-specific ones.

Market approach — Trading multiples of comparable listed companies or multiples implied by comparable transactions, applied to the CGU’s earnings or revenue. Where the entity itself is listed and the CGU approximates the whole entity, market capitalisation plus a control premium is a relevant reference point.

Discounted cash flow on a market-participant basis — Unlike VIU, an FVLCD DCF may include growth and restructuring benefits a market participant would expect to realise, and is prepared on a post-tax basis at a post-tax discount rate. This is often why FVLCD exceeds VIU for a CGU with credible expansion plans that VIU is not permitted to recognise.

Costs of disposal — Incremental legal, advisory, transaction, and stamp duty costs directly attributable to a disposal are deducted. Finance costs, income tax, and termination benefits already recognised as liabilities are not.

Recognising, Allocating and Reversing Impairment

Allocation of the Loss

Where a CGU’s carrying amount exceeds its recoverable amount, the impairment loss is allocated in a prescribed order: first to reduce any goodwill allocated to the CGU, then pro rata to the other assets of the unit based on their carrying amounts. The allocation is subject to a floor — no individual asset may be written below the highest of its own fair value less costs of disposal, its value in use, and zero. Any residual loss that cannot be allocated because of that floor is reallocated across the remaining assets.

The loss is recognised in profit or loss, except where the asset is carried at a revalued amount under another standard, in which case it is treated as a revaluation decrease.

Reversals

Impairment losses on assets other than goodwill may be reversed where there has been a change in the estimates used to determine recoverable amount — but only up to the carrying amount that would have applied had no impairment ever been recognised, net of depreciation.

Goodwill impairment can never be reversed. This asymmetry is the single strongest argument for getting the initial test right and for not over-impairing under pressure: the write-down is permanent, and a subsequent recovery in the business cannot restore it.

Disclosure — Where ASIC Looks First

AASB 136 requires disclosure by CGU of the carrying amount of allocated goodwill and indefinite-lived intangibles, the basis on which recoverable amount was determined, the key assumptions used and management’s approach to determining each value assigned, the period of the forecast, the terminal growth rate, and the discount rate applied.

Where a reasonably possible change in a key assumption would cause the carrying amount to exceed recoverable amount, the entity must disclose the amount of headroom, the value assigned to the key assumption, and the change that would eliminate the headroom.

This last requirement is where reporting most often falls short. Boilerplate sensitivity language, undisclosed headroom, and generic statements that assumptions are “based on past experience” are recurring findings in ASIC’s financial reporting surveillance program, which has consistently identified impairment of non-financial assets and the adequacy of impairment disclosures as focus areas. Where an entity’s market capitalisation sits below the carrying amount of its net assets, ASIC expects that to be addressed explicitly rather than left unremarked.

InteleK’s Impairment Testing Approach

Our accredited valuers bring deep AASB 136 and AASB 13 experience to every impairment engagement. Here’s what sets our process apart:

CGU Structure Reviewed First — We assess whether your CGU identification and goodwill allocation actually satisfy AASB 136 and AASB 8 before running any numbers. A model built on an indefensible CGU structure fails at the audit stage no matter how rigorous the arithmetic.

Correctly Derived Pre-Tax Discount Rates — We build a market-based WACC from observable inputs and derive the pre-tax equivalent iteratively, documenting the derivation so your auditor can replicate it. No arithmetic gross-up shortcuts.

Current-Condition Cash Flow Discipline — We work through your board-approved forecasts to strip out expansionary capex, uncommitted restructuring benefits, and enhancement assumptions that VIU does not permit — and flag them, so nothing is quietly excluded that management believed was in the model.

Both Measures Where It Matters — Where VIU is marginal, we prepare an FVLCD calculation on a market-participant basis. Recoverable amount is the higher of the two, and entities that only ever calculate VIU sometimes impair assets that are not impaired.

Sensitivity and Headroom Analysis Built for Disclosure — Every engagement includes the sensitivity analysis and headroom quantification AASB 136 requires, in a form that drops directly into your notes rather than needing to be reverse-engineered at the last minute.

Audit-Ready Documentation — Every assumption sourced, every judgement explained, in a report structured for the way auditors test recoverable amount under ASA 540 Auditing Accounting Estimates. We understand what they test, because we have been through the review process hundreds of times.

Board and Audit Committee Support — Where the conclusion is contentious, we present the analysis and its sensitivities directly to your board or audit committee — including what would have to change for the conclusion to change.

Collaboration With Your Finance Team — We work alongside your CFO, financial controller, and auditor to fit the testing into your reporting timetable, not to arrive with a deliverable after the numbers have already been signed off.