FW: This bounced - can you forward to tax list?

["Harm-Jan van Burg" <harmjan@vanburg.net>]

-----Oorspronkelijk bericht-----
Van: eric.e.cohen@us.pwc.com [mailto:eric.e.cohen@us.pwc.com] 
Verzonden: donderdag 22 april 2004 22:56
Aan: harmjan@vanburg.net
Onderwerp: This bounced - can you forward to tax list?

Dave, I appreciate your comments, and know this is a vital area for you.

I find it interesting that the group developing the SAF is wondering
whether the name properly conveys what it is designed to do. We have had -
and continue to have - the same problem with XBRL GL. It is not the
representation of a General Ledger - especially not the General Ledger as
defined in any one jurisdiction.

Your comment "In a VAT environment, transactions which are only held in
subsidiary ledgers rather than the general ledger can be important in
establishing completeness and timeliness of VAT declaration." again makes
me want to highlight that XBRL GL has been designed to be a modular
framework to represent not just what is in the General Ledger (which is
somewhat different based on your region) but to represent the subledgers
also - in fact to represent the master files, transaction files and
history files of subledgers in a generic file format. Perhaps we are
"violently agreeing" here - I just need to make sure that we are all on
line that XBRL GL is not just for General Ledgers, despite its name. And
what comprises a General Ledger is actually different in different places.

In parts of the Continental Europe market, for example, information found
only in US/UK subledgers is part of the General Ledger. Customer and
Vendor information, invoice detail sufficient to create open receivables
and payables listings - these are passed to the GL so they can be shared
with the external accountant and the government. As XBRL GL has been
jointly developed by US, UK, Continental European and Japanese
representatives, it has been developed to represent all of the data
necessary for each region on a modular basis. In other words, the goals
for its development would be able to fully convey the information found in
those subsidiary ledgers necessary to establish the completeness and
timeless of VAT declarations - as well as many other audit requirements.
You don't see all of that in the current public working drafts, but within
XBRL International we have a series of internal modules we are working on.

Let me end this note by once again "violently agreeing" with you on your
last point. "The issue in this discussion is not whether the data is
transmitted in XML, XBRL-GL [Eric adds: which is XML!] or indeed any other
format, but whether the dataset projected for the audit file would be fit
for the purpose for which it is intended." My goal is that what comes from
this is something that will be fully fit for the purpose for which it is
intended - and more; enough to benefit all of the members of the business
reporting supply chain. The intellectual content of XBRL GL has five years
and international participation from CPAs/CAs, accounting, tax, audit and
analysis software developers, corporate users, the EDI community and
others. We should make sure we leverage all of this knowledge and
experience is whatever comes next.

We appreciate the opportunity to work with this community and look to make
sure its needs are understood and incorporated.

<eccn />

Eric E. Cohen
Chair, XBRL GL Working Group of XBRL International
Chair, XBRL US Steering Committee




"Chambers, Dave {LBG, Reading, CAS South}" <dave.chambers@hmce.gsi.gov.uk>

04/22/2004 12:57 PM


To
"'tax@lists.oasis-open.org'" <tax@lists.oasis-open.org>
cc

Subject
[tax] XBRL-GL and Standard Audit File






I found Phillip Allen's summary of the discussion between Phillip himself,
Andy Greener and Eric Cohen very interesting.

I also felt that Alex Fiteni's comments were very useful.

I appreciate that Eric Cohen is the leading authority on XBRL-GL and that

"XBRL-GL is a generic representation of the documents, parties, resources,
links to accounts, links to XML/XBRL elements for reporting, and other
classifications that are put together in different combinations to
represent
transactions or other triggers of taxation as a generic audit trail. It
represents through the existing modules some large portion of the fields
collected in a typical transaction, and the "X" of XML/XBRL is
extensibility. so it can be expanded upon for the specifics of
transactions
[where these reside elsewhere than in the G/L]. Anything with monetary
amounts or quantities that can be put to accounts or classification codes
can be represented. Documents and transactions can be represented before
"accounting"/assignment of accounts or classifications".

Where Alex is correct is to highlight the practical considerations that
pertain to particularly indirect taxes. In a VAT environment, transactions
which are only held in subsidiary ledgers rather than the general ledger
can
be important in establishing completeness and timeliness of VAT
declaration.
In an excise duty environment, the point at which excise taxes become due
can be different to the point at which the transactions are posted to the
general ledger.

The Standard Audit File which is being developed in the OECD consists
primarily of the data elements listed in the attached file:

<<Key Data Elements Of The Standard Audit File.doc>>

In the UK, there has been much discussion about whether sufficient data
would be provided by an audit file containing these fields to enable
indirect tax audits effectively to be performed. The points made in this
discussion have come from the same practical place as Alex mentioned in
his
postings.

The issue in this discussion is not whether the data is transmitted in
XML,
XBRL-GL or indeed any other format, but whether the dataset projected for
the audit file would be fit for the purpose for which it is intended.

Dave Chambers.




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