IFRS Now

Issue 2

Oracles Jeff Epstein discusses the opportunities of IFRS Steering your systems safely through IFRS conversion

View from inside

Stormy waters

The technology issue

How does IFRS impact your IT strategy?
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

You cant afford to ignore the impact of IFRS on technology.

Anyone already planning a systems replacement or upgrade may have to change their approach significantly. Others may have to reshape their systems strategy radically to meet IFRS requirements. Failure to plan for the changes required for IFRS could leave you with systems that need extensive manual workarounds if theyre to achieve compliance. That could push up costs and drain resources. In this, the second edition of IFRS Now, we take a more detailed look at how IFRS can affect your systems. We examine the issues from a number of perspectives including that of a business software company, where our discussion with Jeff Epstein is particularly illuminating, as it reveals how KPMG and Oracle share a number of common perspectives on IFRS. Well also examine how Internal Audit can improve the quality of IFRS implementation as it embeds quality assessment firmly into the conversion process. Our contributors include people with real, practical IFRS experience. Whether your deadline for IFRS is imminent or uncertain, were confident that these articles will help you to shape your thoughts on such vital issues. Gary Reader edge zarrella

Gary Reader leads KPMGs Global IFRS Initiative Edge Zarrella is the Global Head of KPMGs IT Advisory practice

02 IFRS Now
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

04

14

08
Jeff Epstein in conversation

10

The Oracle CFO tells KPMGs Gary Reader why IFRS represents an opportunity

Edge Zarellas essential point-by-point guide to IFRS and technology

Make sure that IFRS doesnt disrupt your current systems strategy The conversion team should rely on this well-informed function or a culture clash? Its essential that both parties work together harmoniously

04 What every CIO needs to know 08 IFRS and IT strategy 10 Why Internal Audit can make sure youre fighting fit 12 Finance and IT: a meeting of minds 14
IFRS Now 03

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

What happens when the CFO of the worlds largest business software company meets the man spearheading KPMGs global IFRS initiatives?
Youd naturally expect technology and accounting to be high on the agenda. What I didnt predict was the level to which both of them share similar views on the challenges and benefits that IFRS conversion can bring
Angela Carter, KPMGs Global Oracle Lead Partner

04 IFRS Now
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

IN coNveRSatIoN
Talking shop (from left): Angela Carter, Jeff Epstein and Gary Reader tackle IFRS and IT

IFRS and U.S. GAAP are principles-based. Its just that the U.S. has built up the voluminous interpretation and industry guidance over the years. Jeff You have to build the expertise to do all these things and also ensure that the close process gives you enough time to make that happen. Theres a Wall Street component as well. Your earnings and revenues are going to be different and youll want to know any variations sooner rather than later. Its the No Surprises Rule you dont want your CEO, investors and Board members to be surprised by changes in your financial statements. Gary Youre right. Its all about managing expectations and some have done this better than others. The way you communicate the impact of IFRS can actually give you a competitive advantage. On the opportunities for process improvement Jeff Oracle has transformed its Finance function over the past ten years to make internal operations far more effective and efficient. Our strategy has been to Simplify, Standardize, Centralize and Automate and weve continued to do that as weve begun to adopt IFRS. Were far along in this process and most of the improvements have been done. But

Why pave over old tracks when you can build a brand new superhighway?
The challenges IFRS brings to a global company Jeff At this point, most of the world seems to be converting, so if youre a multinational American company, parts of your business may already be reporting IFRS locally. What youre essentially facing is a multi-step process and all countries conversion dates are on the critical path. Gary Very true. Japan, for example, is allowing voluntary adoption now. And although the U.S. hasnt firmed up its timetable yet, I really think its a case of when rather than if. Jeff And if its going to happen, you have to be ready for it. In a way, IFRSs principles-based approach is simpler, with just 3,000 pages, while U.S. GAAP has 25,000 pages. On the other hand, the greater detail of U.S. GAAP may make litigation defense easier in our highly litigious U.S. legal environment. Gary Although its not clear that the additional guidance in U.S. GAAP necessarily provides stronger support when accounting conclusions are questioned by regulators or in litigation. In any case, if you look at it from another angle, arguably both for other companies, combining a process improvement project with the adoption of IFRS can dramatically decrease costs and increase effectiveness. Companies still have plenty of time to come up with thoughtful ways of accomplishing both compliance and process improvement. Gary Unfortunately, not everyone saw it this way. A number of companies treated conversion as more of a compliance exercise and missed out on the opportunity to improve their processes. Some didnt think through the technology implications, such as how to embed IFRS numbers into business as usual. Inevitably, this led to a big increase in finance transformation initiatives post-conversion, with substantial amounts being spent to deliver IFRS in a more robust manner. Jeff A corporation has a choice. If it starts planning now, theres still time to come up with ways of accomplishing compliance and delivering business benefits. We have plenty of time now waiting until the last minute is not a sensible strategy. I think the best-performing companies will take a forwardlooking approach. Their attitude will be that they
IFRS Now 05

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

Marc Benjamin

have to do it anyway, so they may as well take the opportunity to build a brand new superhighway rather than simply paving over the old tracks. Also, if you think about the U.S. timeline, youll need to report three years of IFRS history. And while you could theoretically wait until January 2014 and then recreate the previous two years, I wouldnt advise it. The more efficient way is to begin automating today, to take advantage of the year and a half window before 2012. On addressing the technology challenges of IFRS Gary In coming up with the right technical solutions, you must have thought a lot about how different clients approach conversion? Jeff Thats a very good point. We offer three technical components to accomplish IFRS conversion. First, you need an ERP system that can handle multi-GAAP accounting, and E Business Suite R12 does just that. Second, you need an effective enterprise performance management system like Hyperion for consolidation and reporting. The third area to consider is governance, risk and compliance. Our GRC suite helps maintain control as you change over, particularly during parallel reporting. Youll want to make sure you havent made any mistakes. Some of our clients have chosen all three

Combining process improvement with IFRS can dramatically decrease costs and increase effectiveness
components, while others will take a phased approach in order to get the benefits of IFRS. Oracles corporate strategy is to be Complete, Open and Integrated, which means our products are designed to work well with other suppliers, or your own, technology. This is critical to give you the flexibility to select the right technology for you to accomplish your goals. Gary Presumably, the more complex your systems environment, the harder it must be to achieve such integration? Jeff Yes. I just read today that the average company with US$1bn of revenue has 650 different IT applications, and larger businesses may have thousands of applications, so customers prefer systems which are based on open standards and integrate well with their other applications. This is at the heart of Oracles strategy. In response to your point about different customer needs, Oracle has developed flexible solutions.

Some customers want to dive deep and make changes in their transaction systems and recognition and measurement applications, to do dual GAAP accounting at a transaction level. Others want a less expensive solution that records the impacts at a higher level in the transition period. We can help both kinds of customers. So if you want to hold off on flipping the switch on your transaction system, we can provide a solution. If you want to go all the way, and go down to the transaction level, we have a solution for that too. On learning from others mistakes Gary Given that conversion involves both accounting and technology, its inevitable that advisory specialists such as KPMG firms will be helping many Oracle users in their journey towards IFRS. Jeff Youve already done this for a number of clients. So, for a company that is only going to do this once, there are a lot of benefits from learning from other peoples experience. KPMG has a thorough, tested, four-step methodology, where you help assess the situation, design the solution, implement this solution and then sustain it. Gary Weve certainly built our firms learning from previous conversions into our approach.

06 IFRS Now
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

IN coNveRSatIoN

KPMG firms are working with Oracle in helping their common clients understand the requirements in moving to IFRS. KPMG firms professionals will be presenting on IFRS at the 2009 Oracle OpenWorld conference. Jeff Epstein is Executive Vice President and Chief Financial Officer (CFO) of Oracle Corporation.Gary Reader leads KPMGs Global IFRS Initiative. Angela Carter is KPMGs Global Oracle Lead Partner based in KPMGs U.S. firm. garyreader@kpmg.com acarter@kpmg.com

With worldwide operations and dual listings in the United States and the United Kingdom, managing the financial performance to world class standards was a significant challenge for international media company Pearson Group. Pearson elected to transition from Hyperion Enterprise to Hyperion Financial Management. While Pearson did not identify IFRS as the major driver for the Hyperion Financial Management implementation, the company did consider it important and with the benefit of hindsight, its

Head of Financial Reporting, Andrew Midgley, conceded: It would be difficult to imagine how we would have coped just relying on our old system. Hyperion Financial Managements flexibility proved vital in allowing the group to understand and communicate the business impact of the IFRS standards, as well as deal confidently with the constant stream of required accounting changes. Hyperion Financial Managements entity structure readily accommodated the challenges of segmental reporting, and Pearson used a custom dimension for more

detailed reporting of segments used in internal management accounts. The flexibility and ease of reporting using standard production reporting and the Excel add-in for Hyperion Financial Management also assisted in a smooth transition to IFRS. Not only could we easily reconcile between UK GAAP and IFRS, but we could also take the Board through the changes and help everyone understand the impact on our published results, Midgley said. Copyright 2007 , Oracle and/or its affiliates. All rights reserved.

IFRS Now 07

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

The views and opinions expressed herein are those of the interviewees and do not necessarily represent the views and opinions of KPMG International

Jeff The key is to work side by side to get the benefit of your in-depth experience, as you guide customers through the transition and help make sure they get it right first time. And as you said, its about far more than just getting over the compliance line. If a CFO reading this article has never done an IFRS conversion before, I recommend he or she gives KPMG a call. I always learn a lot from introductory conversations with advisors, whether or not I end up hiring them. Gary If Ive helped a CFO get a better grasp of the potential challenges and benefits of IFRS, then that conversation will definitely have been worthwhile.

How Oracle has helped Pearson plc on its IFRS journey

The 60-second guide to IFRS and technology

Edge Zarrellas journey with IFRS began when forward-thinking Australian and Asian companies were considering their approaches to the new standards. Since then he has helped many executives understand what IFRS means for their systems. Here are some of the main lessons he has learnt

Integrate IT into the conversion from the start

For an IFRS conversion project to succeed, it should be viewed in the context of the whole business, financial and information systems strategy. By initially assessing the impact of IFRS, IT can determine whether the existing infrastructure can handle the necessary changes or whether this is an opportunity to invest in a new system. The impact assessment can then be used to translate the accounting differences into technical system specifications. Stay engaged throughout the remainder of the program, particularly during the design phase, where an early understanding of business requirements can help immeasurably.

Seize the opportunity to transform

In the last edition of IFRS Now we discussed how you should consider IFRS as a major transformation opportunity to overhaul systems and reduce costs. For instance, many organizations operate several general ledgers and IFRS provides an opportunity to rationalize the systems, reducing the number of instances and applications. This in turn can reduce the number of fixes, databases and layers of mapping. Interfaces become simplified and the time it takes to consolidate should decrease. However, it can be a challenge for the end user to visualize what a new system could be capable of and they will appreciate the vision the IT function can bring.

Dmitry Rukhlenko/Shutterstock

IT costs can easily take up the majority of the overall conversion costs, particularly for industries such as financial services. Under new disclosure and recognition requirements, you may require new data and calculations on a different basis. Changes to the chart of accounts and reporting mappings will almost be inevitable and a clean slate redesign may even be required. Furthermore, under IFRS, youll potentially have to change the number and type of entities that need to be included in the consolidated statements.

Be prepared for some big changes

08 IFRS Now
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

need to know

Go back to the source

Its not just about the general ledger and the consolidation tools. You should also consider business process and system changes at an operational level, and assess the source systems and interfaces that feed the ledger. Organizations may often lack an understanding of the detailed end-to-end flow of data from the source systems (including models) to the general ledger.

Be ready for dual ledgers

Many companies will need dual ledger accounting to facilitate their comparative reporting requirements during the transition period. Two application environments can double the workload for IT but you may have to make allowances for subsidiaries with systems that cannot reflect parallel accounting and/or those which have no interface to the consolidation system.

Be pragmatic to a point

Its possible that not all the required systems changes can be made prior to the first year of IFRS accounting. The degree to which an organization builds short-term workarounds or long-term solutions is a function of time, cost and resource commitment. Some changes can be deferred until the post-conversion sustain period, but dont compromise the project with inefficient manual workarounds such as spreadsheets. Excessive use of spreadsheets is not a very realistic way of managing the mapping changes going forward.

Dont forget the impact on people

Do not underestimate the need to identify dedicated IT staff to assist in the conversion. Your IT people may not fully understand the detailed IFRS requirements and awareness training can help. Its worth the effort this is a great chance to improve collaboration between technologists and business people.

Integrate IT into the conversion from the start and stay engaged throughout the remainder of the program

Edge Zarrella is Global Head of KPMGs IT Advisory practice, based in KPMGs Hong Kong firm egidio.zarrella@kpmg.com.hk
IFRS Now 09

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

Dont lose your way with IFRS

Ken Gabriel and Brad Fisher discuss how best to integrate IFRS efficiently into your existing systems implementation plans

Brad Many large companies seem to be always in the process of replacing or upgrading their financial systems. It can take years up to a decade sometimes before a rollout of new implementations to all countries is completed. Ken Thats no surprise given the size and complexity of some multinationals. Its inevitable that the business environment will change during this period, and IFRS certainly wasnt on the horizon for many organizations when they started their systems journey. Brad For some, IFRS has only recently risen to the surface, particularly in the U.S., where the conversion timetable is still unclear. The real risk is that youll spend a significant amount of money and effort implementing a system based on your current GAAP, only to have elements of that system become obsolete within a few years due to new accounting requirements. Ken Which would not be sensible! Plenty of companies are aware of the risk, but they dont all have a clear view of what to do about it. Just understanding IFRSs high-level accounting requirements wont be enough to help them

shape the system requirements and design. Brad It wont be enough. Whats really needed is an accounting impact assessment to determine the differences between the current GAAP and future IFRS. After that, theyll have to assess the impact these changes have on their business processes, people and, of course, systems. Ken A U.S. firm client has already embarked on a lengthy ERP implementation and business transformation effort. They hadnt necessarily thought about IFRS from the beginning, but sure enough, IFRS compliance became one of the fundamental business drivers for the design of the new systems. Brad How did this company approach integrating the IFRS requirements? Ken Initially, KPMG helped them complete an in-depth IFRS impact assessment. As is often the case, the key areas affected included inventory, property/plant/equipment and lease accounting. Many of the changes related to footnote disclosure and reporting information. KPMG then worked with them to assess how the required accounting changes could affect

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2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

IFRS AND it STRATEGY

The risk is that youll spend large sums implementing a system based on your current GAAP, only to have elements become obsolete within a few years

their ongoing ERP implementation, including plans for parallel ledgers. Brad Was it practical to integrate all the IFRS needs into the current system requirements? Ken Thats a really important point, given that theyre currently working through the systems implications for each of the 130 detailed accounting items that have been impacted. Unfortunately, this company had started on its business transformation program before considering IFRS. Therefore timelines, budgets and rollouts had already been established. Some changes were easy to incorporate, but others are still very much up for discussion. From a practical perspective, you should strike a balance between doing some changes now and some later, and look at the cost-benefits of both options. That involves building flexibility into the configuration. Brad That cant have been easy Ken Not always. Although the ERP project team said the IFRS changes would push back its deadlines by six months, Finance was ultimately very successful at convincing the project team

Darryl Leniuk/Getty Images

of its requirements. The systems leaders were quick to conclude that a little pain up front is better than a larger cost down the road. Brad Stakeholder management must have been an important consideration? Ken It always is but Finance became a successful champion of IFRS and is turning out to be forward-thinking and pragmatic. Brad I wish every organization had that level of vision. A number are in the midst of systems projects yet are still not considering IFRS. Ken I know. Even if the conversion timetable is uncertain, playing a waiting game can potentially be risky and costly. It will inevitably lead to IFRS being retro-fitted to their systems at considerable cost and disruption. Brad Lets hope that doesnt happen. Keeping a focus on the future horizon will, hopefully, keep a companys IT strategy on course.

Ken Gabriel and Brad Fisher are both ERP Advisory Partners in KPMGs U.S. Firm. ksgabriel@kpmg.com bfisher@kpmg.com
IFRS Now 11

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

quality assessment

Internal Audit can help make sure youre fighting fit

With an extensive knowledge of its organization, Internal Audits role in an IFRS conversion could be more useful than you imagine, says John McGaw
FRS is far more than just an accounting exercise. Its also about systems, process, people and change management areas to which Internal Audit brings invaluable perspectives. More and more, I see todays Internal Audit function as an enabler it can help your conversion team understand which business units are best equipped to meet conversion challenges, and which may need more help. Youre likely to see a greater benefit by engaging Internal Audit as early as possible; by inviting them onto the steering committee, youll utilize their knowledge to examine the risks and opportunities. As leading Internal Audit departments have evolved over the past ten years, many of their staff have developed a deep understanding of their companys accounting policies. So it makes sense for them to become involved in the conversion process, especially during the impact assessment stage. Ive also been encouraging conversion teams to use Internal Audit talent in wider project roles, as their project management skills can be a real asset. Dont forget, either, that you can ask IT auditors to help gather information during the IFRS impact assessment. Theyll also be useful during the design phase, when fundamental systems redesign may be needed. Internal Audit is well equipped to review risk and controls Owing to the scale of the effort involved in a transition from historical GAAP policies to IFRS, the conversion may introduce substantial risks. Companies may need to evaluate whether existing controls are appropriate (especially key Sarbanes-Oxley 404 controls). A traditional project audit will continue to add value, particularly from a governance perspective. That said, I think conversions will only maximize such benefits if Internal Audit is embedded in the process. Few IFRS project leaders would completely welcome Internal Audit comments after the project has delivered its key phases.

Expanding into Quality Assessment But is a traditional project audit robust enough to answer the audit committee and executive managements tough questions on whether the conversion process is heading successfully towards IFRS compliance? Other stakeholders will also want to know whether the conversion is generating wider business benefits. Thats where quality assessment comes in. It helps provide confidence that the conversion projects objectives are being met on time and within budget. During the conversion, Internal Audit professionals can push the boundaries of their traditional role, and use their core skills of risk and control analysis to identify and capture opportunities to create value for their organizations. At the same time, despite having a good knowledge of their companys accounting operations and policies, you should ask whether your Internal Auditors have enough IFRS conversion experience to assess the required level of risk and control analysis. Youll probably need to check their skill sets and likely training needs some recruitment or sourcing with third parties may even be necessary. More companies may need some type of external assistance to help develop IFRS quality processes or, on occasion, perform the quality assessment exercise themselves. Get Internal Audit engaged now Many companies in the first wave of IFRS adopters in Europe, for instance unfortunately did not maximize all the above opportunities to involve Internal Audit in the conversion process. Lessons have been learned from these experiences and many companies now understand the far wider implications of IFRS. Accordingly, Internal Auditors should currently be talking to management about plans to make the transition to IFRS and begin to contemplate their own oversight plans, and their role in the transition.

Steven Errico/Getty Images

John McGaw is a Partner in KPMGs U.S. Firm. jmcgaw@kpmg.com

12 IFRS Now
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

IFRS Now 13

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

working together

Meeting of minds?
Successful IFRS conversions need a little yin and yang, says Mary Trussell, as Finance and IT learn to work in close harmony
Yin and yang How seemingly opposing forces are inter-reliant, each in turn giving rise to the other. lthough this edition of IFRS Now puts technology firmly in the spotlight, the role of people is still crucial. One tough challenge in implementing IFRS is aligning the activities of Finance and IT each with their very different cultures and motivations. Finance people typically concentrate on delivering the numbers. The pace of regulatory and reporting change, plus market challenges, inevitably leads to a focus on the here and now. Their IT counterparts, however, often excel at project management and may feel they have quite enough on their plate already, without the additional worry of integrating new standards. A recurring theme in this publication is the need to involve IT people early on in the conversion process and I make no apologies for repeating that message. Discussions at the impact assessment stage can get both sets of minds thinking about the touch points of their many projects. IFRS awareness training for systems people can complement these efforts, giving them a better understanding of how and where their work may be affected by IFRS. Regular formal and informal communication between both groups is, of course, vital but do make sure the messages are pitched at an appropriate level. Not all IT people get accounting language and vice versa. Even then, its easy for initial enthusiasm to wear thin, which is why leadership matters. Both Finance and IT management should seek to emphasize the benefits of a successful conversion. Apart from the obvious satisfaction of a job well done, a successful conversion can be the catalyst for a step change in performance and can also generate a greater level of empathy between Finance and IT. Such mutual appreciation can help to pave the way towards a culture of continuous improvement.

Mary Trussell has worked with a number of clients on their IFRS conversions as a KPMG Partner in the UK, and is currently working in KPMGs Hong Kong Firm. mary.hm.trussell@kpmg.com.hk

14 IFRS Now
2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

Find out more

To receive a copy of one of these publications, please send an email to advisory@kpmg.com or visit the IFRS Institute: www.kpmgifrsinstitute.com

IFRS Now A publication that reviews the impact of IFRS on Finance and discusses how it can be a catalyst for wider transformation, not only to meet compliance demands but also to serve the business better.

The Effects of IFRS on Information Systems How IFRS conversion affects information systems; it is a multifaceted business initiative, not just an accounting challenge.

The Impact of IFRS on Technology: A practical Introduction This paper aims to help companies facing the conversion to IFRS better understand and prepare for the impact the project will have on their information systems.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. 2009 KPMG International. KPMG International is a Swiss cooperative. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis--vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. Printed in the United Kingdom. KPMG and the KPMG logo are registered trademarks of KPMG International, a Swiss cooperative.

No part of this publication may be reproduced without the prior permission of KPMG International and Haymarket Network. Every care has been taken in the preparation of this material but Haymarket Network cannot be held responsible for the accuracy of the information herein or any consequence arising from it. Views expressed by contributors may not reflect the views of Haymarket Network or KPMG International or KPMG member firms. Designed by Haymarket Network, London, UK Reproduction by FMG, London, UK Publication name IFRS Now Publication no 314374 Publication date October 2009

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

Building IFRS conversion into IT now.

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

Or running to catch up later.

New reporting standards affect IT in many ways. If managed effectively, significant business benefits can result. By assessing the impact of IFRS early on, companies can determine whether their existing IT infrastructure can handle necessary changes, or whether its time to invest in a new system. KPMG firms IT Advisory professionals have worked with clients on numerous conversions around the world. They can advise on an IFRS approach to help you understand the technology impact and smooth the path to IFRS compliance. www.kpmgifrsinstitute.com

2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.