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How to account for intangible assets under IFRS and US GAAP: Recognition, amortization, and impairment rules

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Intangible assets represent non-physical resources that generate future economic benefits, such as patents, trademarks, software, and licenses. While both IFRS (IAS 38) and US GAAP (ASC 350, ASC 985-20) offer frameworks for recognizing and measuring intangible assets, they differ significantly in how intangibles are defined, how internally generated assets are treated, and how subsequent amortization and impairment are handled. These differences can result in considerable divergence in reported financial results, especially in industries like technology, media, and pharmaceuticals.



Intangible assets must be identifiable, non-monetary, and lack physical substance.

Under IFRS (IAS 38), an intangible asset must meet three criteria:

  1. Identifiability: Arises from contractual or legal rights or is separable from the entity.

  2. Control: The entity must control the asset and restrict others from accessing benefits.

  3. Future economic benefits: Must be probable and measurable.


Common intangible assets include:

  • Patents

  • Trademarks

  • Copyrights

  • Customer relationships

  • Software

  • Licenses

  • Franchise agreements

  • Development costs (under strict criteria)


US GAAP uses similar criteria but applies them more conservatively, particularly with internally developed intangibles.


Internally generated intangibles are treated differently under the two frameworks.

One of the most significant divergences between IFRS and US GAAP lies in the treatment of internally developed intangible assets, especially research and development (R&D).


IFRS (IAS 38):

  • Research costs: Expensed as incurred.

  • Development costs: Capitalized only if the project meets six stringent criteria (technical feasibility, intention to complete, ability to use or sell, future economic benefits, resources available, ability to measure reliably).


US GAAP (ASC 730):

  • All R&D costs: Expensed as incurred, with few exceptions.

  • Software development:

    • Internal-use software (ASC 350-40): Development costs capitalized once the project reaches the application development stage.

    • Software for sale (ASC 985-20): Capitalization starts once technological feasibility is established.

Area

IFRS (IAS 38)

US GAAP (ASC 730, 350, 985-20)

Research

Expensed

Expensed

Development

Capitalized if strict criteria met

Generally expensed

Software for internal use

Capitalized after development stage

Same, but detailed guidance

Software for sale

Capitalized after feasibility

Capitalized after technological feasibility


Initial measurement is at cost, with limited ability to revalue.

Under both frameworks, intangible assets are initially measured at cost, including:

  • Purchase price

  • Import duties

  • Directly attributable costs (legal fees, registration, testing)


IFRS allows entities to choose the revaluation model for intangibles with an active market (rare in practice), recognizing fair value through OCI. US GAAP, in contrast, does not permit revaluation—cost model only.


Amortization applies unless the intangible has an indefinite useful life.

After initial recognition:

  • Finite-life intangibles (e.g., licenses, software, some trademarks) are amortized over their useful lives using a systematic method.

  • Indefinite-life intangibles (e.g., brand names with no foreseeable limit) are not amortized, but tested annually for impairment.


IFRS requires a review of useful life and amortization method at least annually.

US GAAP also requires annual evaluation of useful life, with impairment testing performed if a triggering event occurs (or annually for indefinite-life intangibles).


Impairment testing approaches vary in methodology and reversibility.

IFRS (IAS 36):

  • Uses a one-step approach: Compare carrying amount to recoverable amount (greater of value in use and fair value less costs to sell).

  • Impairment loss = Carrying amount – Recoverable amount

  • Impairment reversals are allowed (except for goodwill), if indicators change.


US GAAP (ASC 350):

  • Finite-life intangibles: Two-step model under ASC 360.

    1. Compare carrying amount to undiscounted cash flows.

    2. If not recoverable, impairment = carrying amount – fair value.

  • Indefinite-life intangibles: One-step fair value test.

  • Reversals are not allowed.


Disclosures provide visibility into asset types, values, and estimates.

Both IFRS and US GAAP require detailed disclosures related to intangible assets:

Disclosure area

IFRS (IAS 38)

US GAAP (ASC 350)

Asset types and useful lives

Required

Required

Amortization methods and rates

Required

Required

Revaluation model usage

Required (if applied)

Not applicable

Impairment losses and reversals

Required (losses and reversals)

Required (losses only)

Internally generated asset disclosure

Required if development costs capitalized

Not separately disclosed unless material


Key differences between IFRS and US GAAP for intangible assets.

Area

IFRS (IAS 38)

US GAAP (ASC 350, 730, etc.)

Capitalization of development

Permitted under strict criteria

Generally prohibited

Software development

Principles-based guidance

More prescriptive and segmented

Revaluation

Allowed if active market exists

Not allowed

Amortization

Required for finite-life intangibles

Same

Impairment testing

One-step approach

Two-step for finite life; one-step for indefinite

Impairment reversals

Allowed (except for goodwill)

Not allowed


The accounting treatment of intangible assets can significantly impact reported earnings, asset valuations, and key financial ratios. Entities operating globally or across sectors with high IP investment must understand how IFRS and US GAAP differ—not only for compliance but also for managing investor expectations and aligning valuation models with accounting reality.


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