Plain speaking!Benchmarking the new auditor’s report among Dutch listed entities

www.pwc.nl

April 2014

Foreword 3

1. Transparency regarding audit work 4

2. Analysis of the new auditor’s report 6

3. The auditor’s report as the final word 10

4. Reflection: Moving forward together 16

Appendices 18Appendix 1. Example of Independent auditor’s report 19Appendix 2: Status of the 2013 annual reports as of 22 March 2014 23Appendix 3. Examples of key audit matters in the auditor’s reports 25

Contents

The original Report ‘Klare taal!’ was prepared in Dutch. This document is a translation of the original. In case of difference between the English and the Dutch version, the latter shall prevail.

2 PwC

Foreword

The draft of a more informative and entity specific auditor’s report was launched in the summer of 2013. It challenged auditors to say more about how they go about auditing at their clients. At the launch of the exposure draft, its author, Arnold Schilder of the International Auditing and Assurance Standards Board (IAASB), made it clear that these changes are critical to the intrinsic value of the auditor’s report and therefore also to the relevance of the auditing profession.

And he does, of course, have a point. The current outdated auditor’s report no longer meets today’s expectations of transparency. A simple ‘true and fair’ is not good enough. It gives the user of the financial statements little comfort and also provides no insight for the wider public into the process leading up to an unqualified auditor’s report. When my car is serviced, I want to know what work the mechanic has done; that gives me a greater degree of comfort and also gives the mechanic a greater degree of credit in his work.

So it is right that auditors should start to talk the language of the users of financial statements. However, it would be misleading to think that this only enhances the relevance of the auditing profession. It benefits also the users and the preparers of financial statements, i.e. the entities being audited. The preparer benefits from the assurance that its stakeholders derive from the information reported. And they want Plain speaking!

This is clearly a strong message to get moving robustly with the new auditor’s report. Some fear that individual countries going it alone will jeopardize the comparability of auditor’s reports. At this stage, that will inevitably be so. However, it also means that the Netherlands can show the way and, in doing so, can make its contribution to maximizing the relevance of the auditor’s report - and this latter issue is what we believe matters most.

Before the new auditor’s report becomes mandatory, we have recently piloted it in the Netherlands at a number of our listed clients. In some cases, we went further than the IAASB draft by providing information regarding materiality and group audit scoping, more in line with the requirements in the UK where the more informative auditor’s report is already mandatory.

We see the new auditor’s report as a logical development in an ongoing process. There is already more and more communication regarding audit work taking place between auditor and shareholder during shareholders’ meetings. Stakeholders will undoubtedly take the next step of getting the debate started as to who should be primarily responsible for disseminating entity specific information and where the extent of the auditor’s transparency ends and that of the entity being audited begins. Engrossing issues that merit a broad-based debate.

This publication presents the results of, and our experiences with, the pilot in the Netherlands. It stands as our contribution to the public debate. As far as we are concerned, both the ongoing developments and the results of the pilot provide strong grounds for pressing on further down this line. As we move forward, we also call upon managing and supervisory directors, investors, analysts, and other stakeholders to share the experiences they have had with the new auditor’s report.

The season for 2014 shareholders’ meetings has just opened, so this is an excellent initial opportunity.

Michael de Ridder, Chairman of the Assurance practice of PwC The Netherlands

Plain speaking! 3

1. Transparency regarding audit workMore informative auditor’s reporting as a logical next step

The current auditor’s report does not include enough information for those in the outside world to be able to form their opinions. That is strange, to say the least. You could say that the external auditor is a professional practising in the public sphere and serving the public good. In this he needs to be transparent and unambiguous about his findings and about how these were reached.

But, instead, the audit work he does on valuation assumptions, complex tax issues, provisions, revenue recognition, and the reliability of processes and systems all remain under the radar for the wider public. This is also the case for the discussions he has with managing and supervisory directors regarding the amounts, and the wording of notes, to be included in the financial statements and annual report, and the outside world is given no insight into the adjustments that result from these discussions.

Strengthening the reporting roleThe auditor has always reported to his client’s boards of managing and supervisory directors. In many cases, there is also contact with the entity’s bank or

the supervisory body responsible, such as the Dutch Central Bank, or a government department. Shareholders, other interested parties, and society in general have had to make do solely with his concluding opinion on the financial statements given in prescribed standard wording. The theory goes that this facilitates international comparability and recognisability. But almost all are now agreed that the current auditor’s report has had its day.

For years now the profession has been looking for new ways to strengthen its reporting role and to better fulfil its social responsibilities. To this end, the NBA (the Netherlands Institute for Chartered Accountants) has been periodically issuing public management letters since 2010. These letters take the specific findings of individual financial statement audits and assimilate them into reports of generic, socially relevant themes and risk areas. To date, such public management letters have been issued for municipal government, healthcare, real estate, and other sectors.

External auditors are becoming more and more involved at Dutch shareholder meetings. To help provide insight to shareholders into the audit process, many auditors take the initiative to speak up when the financial statements are being discussed. The NBA survey indicated that this occurred at 56% of the 2013 Annual General Meeting of shareholders (AGMs), much to the satisfaction of those representing the institutional and other investors who had been calling for this.

Call it the tragedy of the auditor: tens of thousands of audit hours reduced down to one standard piece of text, an auditor’s report on a big bank that barely differs from that on a regional manufacturing company. The auditor does his work diligently, but the great majority of it is hidden from the stakeholders, the people he is doing it for.

4 PwC

What’s happening around the world?The new auditor’s report is a logical development in an ongoing process. There has been much work done internationally to achieve a format of reporting that provides more information as to how audits are performed. The IAASB published its own exposure draft in the summer of 2013; in the UK a more informative auditor’s report has been mandatory since 2013; and in the US, the supervisory body for auditors (the PCAOB) also wants to mandate the reporting of greater insight into the audit process. The common denominator in all of this is information which is more detailed and more relevant.

But there are also differences. The UK has opted for an auditor’s report focussed on the ‘story of the audit’, in which auditors are required to report the primary audit risks and materiality considerations, together with the related audit work. The IAASB and PCAOB have opted for the reporting of the more significant matters that arose during the audit and/or those that attracted the auditor’s greatest focus of attention. This could, for instance, be audit risks, but could also include changes that were needed to the audit approach as a result of significant weaknesses in internal control.

The expectation is that a more informative form of auditor’s report will be required in much of the world by 2017. In the Netherlands, the NBA is aiming for mandatory application for listed entities for the 2014 financial statements.

The Netherlands is ahead of the curveThe IAASB has called on auditors to get to work on this issue, and the NBA has, in turn, called on audit firms to put the new auditor’s report to the test. Current auditing standards permit voluntary application of the new auditor’s report for the 2013 financial statements, and the Dutch

political world and those representing investors, such as the VEB and Euromedion, are also strongly pressing for it.

Together with a number of other audit firms, PwC has picked up the gauntlet. We have put the new auditor’s report to the test at a number of our Dutch listed entity clients – in the first instance, with managing and supervisory directors but also in some cases in the public arena, the objectives being to get a dialogue going between companies and stakeholders and to identify whether and how the international proposals could be improved. In some cases we have gone further than the IAASB’s proposals in that we have provided company specific information regarding the scope of the audit and we explained the materiality considerations applied.

The enthusiasm shown for the test by the managing and supervisory directors of the entities involved is very encouraging indeed. They have also bought in to the importance of stakeholders being provided with meaningful information regarding the audit approach. The upshot is that nearly half of the 2013 published annual reports of AEX and AMX listed entities already include an auditor’s report in the new format.

The Netherlands (on a voluntary basis) is ahead of the curve on this, along with the UK (on a mandatory basis). Both the IAASB and the PCAOB have taken note of the developments in the Netherlands with interest.

Plain speaking! 5

2. Analysis of the new auditor’s reportBenchmarking among Dutch listed entities

The pilot we ran has been extremely valuable because the ramifications for users of financial statements, boards of management and supervisory directors, and auditors can be assessed now. It was often pioneering work and, naturally, not everything has yet fully crystallized. Is that a bad thing? Definitely not! The pilot has brought up a host of lessons for the future that standard setters can now use to develop better standards, fully aligned to day-to-day practice.

There are also entities which have opted not to anticipate the definitive international standard. They prefer to work within the framework of an established set of rules put together after due process. And there is something to be said for that too. What we have done with many of these entities is to discuss with their management and supervisory directors what their new auditor’s report might

look like. Also these discussions have highlighted some useful new insights.

Nearly half of large and mid-sized entities have a new auditor’s reportOf the 38 published AEX and AMX annual reports1, 45% have a new auditor’s report. The new auditor’s report being applied in the Netherlands is based on the illustrative text included in the IAASB Exposure Draft. This differs in a number of ways from the old report, in that the auditor now reports the more important audit issues and indicates explicitly his concurrence with management’s conclusions as to going concern. The report has been expanded by a number of auditors to include passages concerning materiality and the group audit scope, as is the practice for reports issued in the UK. There are three entities which, as a result of their English legal background, use the passages which are mandatory in the UK. Because of their legal structure and the requirements of French law, two entities have had an extensive auditor’s report for several years, but have not yet published their 2013 auditor’s reports. There are four entities that have a Belgian or Luxembourg legal form.

A number of listed entity auditors have provided a more informative auditor’s report on their 2013 financial statements, in anticipation of a requirement that is expected to be applicable for the 2014 financial statements for all listed entities.

AEX entities which have published a more informative auditor’s

report

AMX entities which have published a more informative auditor’s

report

Total

Yes No Yes No Yes No

Total 9 13 8 8 17 21

1 The position as of 22 March 2014 on the basis of annual reports published on the internet. As of 22 March 2014, 3 AEX and 9 AMX entities had not yet published their financial statements. Refer to Appendix 2 for further details.

2 Based on the new Euronext classification as of 24 March 2014.

Table 1: The benchmarking1 focussed on AEX and AMX entities2:

6 PwC

The new auditor’s report3 opens up with the opinion paragraph, so it is immediately clear what the auditor’s overall conclusion is. It then proceeds to provide a summary of the key audit matters and a conclusion as to management’s analysis of the assumptions underlying going concern, all relating specifically to the individual entity’s financial statements. The standard texts are included either towards the end of the auditor’s report or, in some cases, in an appendix.

Key audit mattersThe new auditor’s report includes a section for key audit matters4. These represent the more significant matters arising during the audit or those which have involved the greatest amount of attention on the part of the auditor. These key audit matters have high informational value because they relate specifically to the entity being audited, i.e. not standard boiler-plate text that recurs at all entities year in year out.

Getting these key audit matters right is a very challenging task. One such matter could involve, for instance, a significant amount of goodwill, not just because of

3 An illustrative new auditor’s report is provided in Appendix 1.4 Refer to Appendix 3 for a number of examples of entity specific key audit matters.

Number of key audit matters

Item about going

concern

Item about materiality

Item about the scope of

the group audit

Auditor

Ahold 5 yes no yes PwC

Brunel 3 yes yes yes PwC

Corio 3 yes no no PwC

KPN 3 yes yes yes PwC

NSI 2 yes no no KPMG

Nutreco 3 yes no no KPMG

PostNL 5 yes yes yes PwC

Randstad 4 yes yes yes PwC

Reed Elsevier *) 4 yes yes yes Deloitte

SBM 3 yes no no KPMG

Shell *) 6 yes yes yes PwC

Sligro 3 yes no no KPMG

TNT Express 6 yes no no PwC

Unilever *) 6 yes yes yes PwC

Vastned 5 yes yes yes Deloitte

Vopak 4 yes no yes PwC

Wereldhave 3 yes no no PwC

* As a result of the audit reporting requirements mandatory in the UK and the combined nature of the financial statements, the auditor of Unilever NV refers to the auditor’s report issued by the auditor of Unilever plc. In the case of Reed Elsevier NV, the auditor refers to the auditor’s report on the combined financial statements of Reed Elsevier plc and Reed Elsevier NV. As Shell is a plc, the auditor follows the UK requirements. In this benchmark, we have used the auditor’s reports issued regarding these plcs, and the risks noted by the auditor have been taken as key audit matters.

Table 2: Key audit matters per listed entity:

Table 3: Key audit matters reported:

AEX AMX Total

Acquisition and disposal of operating activities 4 5 9

Taxation (deferred and current) 8 1 9

Valuation of goodwill 5 3 8

Valuation of real estate 2 3 5

(Fraud risks in) revenue recognition 4 1 5

Pensions 2 2 4

Valuation of other assets 3 1 4

Management override of controls 3 1 4

Claims & litigation 3 0 3

Derivatives 1 2 3

Purchase discounts 1 1 2

IT environment 0 2 2

Valuation of debtors 0 2 2

Cash position/bank debt 0 2 2

Other 4 2 6

Total 40 28 68

the need for an impairment test but more specifically because of those elements where the testing indicates little or no surplus value and which are therefore sensitive to changes in value. Users expect the auditor to be particularly critical regarding the assumptions used and the underlying cash flows as well as regarding the entity’s note disclosures of the sensitivities inherent in the assumptions made.

Plain speaking! 7

The benchmarking indicated that a total of 68 key audit matters were included in the 17 auditor’s reports. These key audit matters comprised a wide variety of matters specific to the individual entity and also several that appeared at a number of entities.

The key audit matters reported covered a wide variety of issues, for instance goodwill or real estate valuation, taxation, valuation of and accounting for derivatives, pension accounting, and the IT environment.

Materiality and group audit scopeA number of auditor’s reports included passages about the materiality considerations applied by the auditor and the scope set for the group audit. Mindful of the particular needs of investors and the objectives of the pilot, these auditors have not restricted their comments solely to the IAASB’s illustrative text. In fact, the illustrative text does not include such passages. It is worth noting that the IAASB believes that, while such passages fit very well into its exposure draft, they are not necessarily applicable in all situations.

There does seem to be some reluctance on the part of auditors in this area. Maybe some find it difficult to address the concept of materiality and the related thinking behind the audit approach to the group audit in the auditor’s report. This is understandable. Providing insight into the considerations of materiality, how this is set, and what goes into determining the scope of the group audit can all be key to getting a good insight into the audit - but also into its limitations. It is therefore very helpful that a number of auditors have made a start on this and that a serious discussion can now take place both within the audit profession and with stakeholders.

Going concernIn the section on going concern, the auditor must indicate whether he is in agreement with management’s considerations and conclusions as to the continuity of the entity. This is done irrespective of whether

or not there is an issue on this score. In the old-style auditor’s report, the auditor reports only as and when he has flagged an issue regarding going concern.

An emphasis of matter paragraph can act like a red flag and generate more circumspection on the part of users than a paragraph that comes back year after year. On the other hand, going concern risks can vary from very low to very high and this involves a great deal of care. It is not easy to break it down into a simple choice as to whether to report or not. What is called for is regular and nuanced reporting about the situation.

The question is: Does the current draft do this issue justice? The downside of the new text is that it may be perceived as simply boilerplate with only superficial informational value. Also there may be an expectation created that the auditor will provide information that the entity should be providing. A more logical aim may be to require the entity to provide a balanced analysis of going concern in its financial statements and for the auditor to explicitly provide his views on this analysis in his auditor’s report.

Keep it clearIn contrast to the regular auditor’s report, the new report includes more entity specific information, and the report is therefore longer. This means that the user may not be able to absorb the key points at a glance.

In a number of auditor’s reports, PwC has addressed this by physically highlighting the more important aspects of every new audit report with bordering or, in some cases, with different colouring. Furthermore, at a number of listed entities we have included the mandatory paragraph regarding the respective responsibilities of the entity and the auditor as an appendix to the auditor’s report. While this paragraph is an important one, it is the same for all entities and therefore not entity specific.

The IAASB has given national standard setters the option of allowing the auditor to refer, in the auditor’s report, to a website where this generic paragraph is available. Recently issued auditor’s reports have not (yet) used this option.

8 PwC

None of his will happen of its own accordRunning this pilot has allowed us to experience how a large number of new auditor’s reports have been put together, both in terms of the formulation of the reports and also in terms of the auditor’s preparation for the AGMs. We would like to share a few lessons learnt that may be helpful for auditors who have to deal with this in the future:

• Begin with the end in mind. A good audit starts with good risk analysis and scoping. Assessing in advance what issues are relevant means that these should automatically make it through into the management letter and the auditor’s report.

• Knowledge is power. Drafting a key audit matter needs to be thought through properly. A key audit matter which, with no previous knowledge of the entity, could apply to any entity is inadequate.

• Consistency is not an end in itself. By definition, entity specific reports must differ entity to entity. But ensure that you understand and can explain why matters which have been identified as key to one entity in the sector are not also key to another entity in the same sector.

• Reader mindset. The challenge is to draft succinct key audit matters which address the technical aspects in language which is understandable to the stakeholders. This is an iterative process which needs to be critically reviewed from outside the audit team (for instance, via consultation).

• Explain your role. A number of responses indicate that misunderstandings can arise as to the respective responsibilities of the auditor and of the entity and its supervisory board. It is important that this is made very clear. The upcoming AGMs present an excellent opportunity to re-clarify.

Plain speaking! 9

3. The auditor’s report as the final wordThe auditor’s report in relation to the entity and its supervisory directors

The key audit matters focus on areas of higher risk and matters which are material to the picture presented by the financial statements and which are open to subjectivity. The user wishes to know what issues the auditor has identified and what he has done about them. The relation between this information and the risk areas and sources of estimation uncertainty reported by the entity is particularly relevant. This information appears specifically in two places, namely in the risk paragraph and in the section on significant estimates.

Auditor’s report vs risk paragraphIn the risk paragraph of the annual report, management sets out the primary strategic, operational, financial, compliance, and financial reporting risks that the entity faces in carrying out its strategy and day-to-day business. This should not be an inexhaustible list of potential risks, but a description of the principal risks that the entity faces given the company’s strategy and risk appetite.

The key audit matters in the new auditor’s report should address those particular risks that attract greater attention on the part of the external auditor in his audit of the financial statements. In other words, key

The auditor’s report represents the auditor’s final conclusion on the entity’s financial statements and thus relates to the information prepared by the company. An entity specific auditor’s report must go hand in hand with the provision of more entity specific information by the entity and its board of supervisory directors.

audit matters, by definition, represent the financial reporting risks and not the whole spectrum of business risks that the entity faces.

Strategic, operational, financial, and compliance risks can of course affect the financial reporting, and our benchmarking survey highlights that about two thirds of the reported key audit matters related, either directly or indirectly, to the risks set out in the risk profile in the risk paragraph. Goodwill impairment risk is regularly reported as a key audit matter. It is an example of a risk that is often included, indirectly, in the risk paragraph as an amalgamation of factors in the areas, for instance, of market developments, technology, and/or competition and then translated into the impact on the financial statements.

Around one third of the key audit matters included in the new auditor’s reports related to specific risks that were not included as such in the risk profile, and this occurred at three quarters of the entities (refer to the examples in the box on page 11).

These examples illustrate the informational value of the new auditor’s report as regards financial reporting risks. The new auditor’s reports also included key audit matters which in a number of cases are not specifically included as such in the risk paragraph of the annual report. This is not inconsistent or surprising, given that the strategic risk profile in the risk paragraph addresses the broad spectrum of primary operating risks involved. The strategic risk profile, therefore, is less focussed on only

10 PwC

the financial reporting risks than the new auditor’s report is. Furthermore, the key audit matters reported by the auditor may well be addressed elsewhere in the annual report.

Potential expectation gapThis brings us to a potential new expectation gap. It is not unlikely that users of the annual report and financial statements will ask why auditors include risk areas in their auditor’s report which are not reported as such by management in their risk profile. Indeed, that is the first place in the annual report where a user would expect the financial statement risks to be reported. The question may also arise as to whether or not the managing and supervisory directors and the auditor are in agreement as regards the assessment of financial statement risks. This is because it is primarily the supervisory board and managing directors that are responsible for keeping the shareholders and other stakeholders informed of all relevant matters relating to the entity, and this

Examples of key audit matters that are not included as such by a number of entities in the risk profile in the annual report:

• Vendor allowances• Deferred tax assets / taxation• Management override of internal

controls• Measurement of and change in

accounting for pensions• Valuation and recognition of

interest rate derivatives• Lease classification is complex and

highly judgemental• Fraud in revenue recognition• Revenue recognition on

construction contracts is highly judgemental

• Revenue recognition• Gross and net presentation of

balances

includes the financial statements. So this is an area that merits still further discussion and resolution in the Dutch context.

A solution to this possible new expectation gap lies in the UK model for the new auditor’s report. In this model, the audit committee addresses the significant issues surrounding the financial statements in its report, and the key audit matters in the auditor’s report complement these. The UK auditor’s report explicitly refers back to the audit committee’s report (refer to page 13).

The role of the auditor regarding the risk paragraph merits further debateIn the context of the audit of the financial statements, the auditor is responsible for determining that the information included in the risk paragraph is consistent with the financial statements and with the results of his audit. Various stakeholder groups have indicated that they would like to see the auditor, in his signalling role, provide a more explicit statement about the risk

profile included in the annual report. This could, for instance, take the form of a passage in the auditor’s report to the effect that, within the context of the audit of the financial statements, the auditor did not come across any risks other than those included by management in the risk profile. The scope of this publication does not permit us to dig deeper into the pros and cons of this option at this stage, nor to consider the extensions to the scope of the audit and the inclusion of an additional passage in the new auditor’s report. PwC calls for further debate among all stakeholders on this issue.

Uncertainties inherent in estimatesIFRS requires entities to provide information in their financial statements as to assumptions made regarding the future and about sources of estimation uncertainty - uncertainties that carry serious risk of material adjustment to the carrying amounts of assets and liabilities in the subsequent financial year, i.e. the more

Plain speaking! 11

Randstad Holding

Annual report – Risk & opportunity managementOther financial reporting risks mainly relate to the valuation of deferred tax assets and goodwill, to the provisions for claims of third parties, and to revenue recognition.

We have various policies in place, such as accounting policies and review procedures to mitigate these risks. Further information is included in notes 3.2 and 4 to the financial statements.

Annual report – 4.3.1 Deferred and current income taxes

Deferred income tax assetsThe recoverability of deferred income tax assets resulting from tax losses carry-forward and temporary differences is reviewed and assessed annually, using forecasts that are based on the actual operating results and the expected future performance based on management’s estimates and assumptions of revenue growth and the development of operating margins of the Group companies concerned. External data are used for reference, and significant judgment is required. Deviations from these estimates and assumptions can affect the value of deferred tax assets and may, in that case,

have a material impact on the effective tax rate. The actual outcome may differ significantly from the outcome estimated by management.

Certain deferred income tax assets, whose recoverability is considered not probable are valued at nil. These comprise deferred tax assets in relation to tax losses carry-forward of € 191 million (2012: € 160 million), deferred tax assets relating to other temporary differences of € 6 million (2012: € 10 million).

The part of deferred tax assets that is expected to be recovered within one year is estimated at € 47 million (2012: € 50 million).

SensitivityThese projections are assessed using a number of scenarios to cover reasonable changes in the assumptions underlying the projections. These changes mainly relate to variations in revenue growth percentages and operating margin percentages. The deferred tax assets are only recognized to the extent that it is considered probable that future taxable profits will be available, against which these deferred tax assets can be utilized. The various scenarios are in agreement with the variations in estimates and assumptions used in the goodwill impairment testing (see note 4.1.2).

The various scenarios yield potential outcomes that do not materially deviate from the carrying amount.

Auditor’s report – Key audit matterJudgment in valuation of deferred income tax positionsThe Group’s deferred income tax assets and deferred income tax liabilities as at 31 December 2013 are valued at € 521.9 million and € 36.6 million respectively. Under EU-IFRS, the Company is required to annually determine the valuation of deferred tax positions. This area was significant to our audit because of the related complexity and subjectivity of the assessment process, which is based on assumptions that are affected by expected future market or economic conditions. As a result, our audit procedures included, amongst others, using our tax specialists to assist us in evaluating the assumptions and methodologies used by the Company. In particular we assessed the recoverability of deferred tax assets related to operations in the USA, Luxembourg, France, Spain, Belgium and the UK by reviewing their profitability, management’s forecasts and local fiscal developments. We also focused on the adequacy of the Company’s disclosures on deferred income tax positions and assumptions used. The Company’s disclosures concerning income taxes are included in note 4.3 to the consolidated financial statements.

difficult, subjective, and complex estimates that management is called on to make.

Information needs to be provided to help the user gain insight into the estimates made and their impact on the financial statements, such as the key assumptions made, the range of potential scenarios, and the sensitivity of carrying amounts to the methodologies, assumptions and estimates.

The risk paragraph, significant estimates reported in the financial statements and the information provided in the auditor’s

report regarding the audit work done all come together to provide the user with a comprehensive picture of where the entity stands (refer to the box: Example Randstad).

The auditor’s report vs governance reportingBy the term governance reporting, we mean the information provided regarding corporate governance in both the reports of the managing and supervisory directors and the remuneration report. Governance reporting and the new auditor’s report cannot be viewed independently of each

other. Based on the recommendation of the boards of supervisory and managing directors, it is the AGM that appoints the auditor to audit the financial statements. It is also primarily the boards of supervisory and managing directors which are charged with providing the necessary information to the shareholders and other stakeholders regarding the entity

As a matter of principle, the information provided by the external auditor may never be seen as a replacement of the information which either the managing

12 PwC

Audit committee Report Unilever 2013

The Committee reviewed the quarterly financial press releases together with the associated quarterly reports from the Chief Financial Officer and the Disclosure Committee, and with respect to the half-year and full-year results the external auditors’ reports, prior to their publication. They also reviewed the Annual Report and Accounts and Annual Report on Form 20-F. These reviews incorporated the accounting policies and significant judgements and estimates underpinning the financial statements as disclosed within note 1 on pages 94 and 95. Particular attention was paid to the following significant issues in relation to the financial statements:• goodwill and intangible assets –

impairment testing, refer to note 9;• pensions – obligations and

assumptions, refer to note 4;• provisions and contingencies,

including direct and indirect tax provisions, refer to notes 6 and 19;

The external auditors have agreed the list of significant issues reported.

For each of the above areas a paper outlining the key facts and judgements, prepared by management, was circulated to the Committee prior to the meeting at which it was discussed. Members of management attended the section of the meeting of the Committee where their paper was discussed to answer any questions or challenges posed by the Committee. The issues were also discussed with the external auditor. The Committee was satisfied that these significant issues have been appropriately addressed by management.

Auditor’s report 2013 Unilever Plc

We considered the following areas to be those that required particular focus in the current year. This is not a complete list of all risks or areas of focus identified by our audit. We discussed these areas of focus with the Audit Committee. Their report on those matters that they considered to be significant issues in relation to the financial statements is set out on page 53.

directors in their annual report or the supervisory directors in their supervisory directors’ report are charged with providing to stakeholders. This applies also to matters which are highlighted in an explanatory paragraph (mandatory or otherwise) for the benefit of the users of the auditor’s report.

It is clear from the initial responses to the new auditor’s report that not everyone is clear as to the respective responsibilities of the entity and the auditor. In our view, this represents a major challenge. Auditors must make it clearer that their primary responsibility lies with providing assurance that all relevant information necessary for the user to form a view on the financial statements has been included by the entity itself in the financial statements. Only then can the auditor issue an unqualified report.

Update reporting requirementsThe auditor’s report must be read in conjunction with the financial statements and the annual report. The call for greater transparency also needs to be responded to in that same joint context. So, if the auditor provides a further informative dimension in his auditor’s report, then so should the supervisory board, and in particular the audit committee, provide greater detail and insight into the assignment it has given to the external auditor, for instance as regards scope, key audit matters that the supervisory board and the auditor have discussed, and issues from the management letter.

We believe that this would make clear to the readers of financial reporting that the auditor’s report is an integral part of the proactive dialogue and discussion that goes on with the audit committee throughout the whole year. Absent this, an unwelcome disparity arises regarding the provision of information about the financial statements. This therefore requires change to the reporting requirements for management and supervisory boards as regards financial statements and annual reports. If we take, for instance, the going concern paragraph

referred to earlier, the need for more information cannot be remedied by the auditor’s report alone.

The IAASB makes no link with the supervisory board reportAs the IAASB does not address the report of the supervisory board, the exposure draft does not address the relationship between the supervisory board report and the auditor’s report, and this comes through in our benchmarking among Dutch listed entities. We however do see this relationship in the new auditor’s report for entities that also have a listing in the UK, such as Unilever Plc, Reed Elsevier Plc, and Shell Plc.

The reason for this is that the UK model does address this relationship, and requires that the audit committee provide, in its report, details of significant issues relating to the financial statements. In the UK, the key audit matters need therefore to be complementary to the information provided by the audit committee (refer to box: Example Unilever Plc).

Include best practice in the Corporate Governance CodeVarious parties, including the jury of the Sijthoff Prize, the Monitoring Committee for the Corporate Governance Code, and a number of academics, have already called upon supervisory boards to improve the

Plain speaking! 13

transparency of their reports. It seems clear that any future revision of the Dutch Corporate Governance Code (hereafter ‘the Code’) should include a new best practice to challenge the audit committees to make specific mention in their reports of the key issues underpinning the financial reporting.

Testing of the governance information and the remuneration paragraphAnother particular aspect of the UK variant is the requirement that the auditor’s report includes a specific passage regarding what the external auditor has done in terms of (a) reviewing the governance information in the annual report and (b) reviewing the information provided in the remuneration report (refer to box: Example Reed Elsevier).

In our country, the assessment of the required governance disclosures in the annual report, including the remuneration paragraph, forms part of the testing that the auditor carries out as to whether the legally required disclosures have been included in the annual report and whether the information is consistent with the financial statements and the findings of the audit. The basis for the external auditor’s work here is included in NBA Guideline 1109. In fact, in contrast to the UK, we take an implicit approach in the Netherlands, whereby the testing of the governance information is covered by the general passage in the auditor’s report relating to the testing of the annual report’s compliance with the formal legal requirements.

In its 2014 letter to auditors5, the VEB (‘Vereniging voor Effectenbezitters’, the organization representing the interests of Dutch investors) calls explicitly for more detail as to the role of the auditor vis-à-vis governance information in the annual report and as to the testing of compliance. In their response to the NBA’s draft update of the guideline, Eumedion and

Reed Elsevier Plc 2013 – Auditor’s report concerning remuneration and corporate governance

Directors’ remunerationUnder the Companies Act 2006 we are also required to report if in our opinion certain disclosures of directors’ remuneration have not been made or the part of the Directors’ Remuneration Report to be audited is not in agreement with the accounting records and returns. Under the Listing Rules we are required to review certain elements of the Directors’ Remuneration Report. We have nothing to report arising from these matters or our review.

Corporate Governance StatementUnder the Listing Rules we are also required to review the part of the Corporate Governance Statement relating to the company’s compliance with nine provisions of the UK Corporate Governance Code. We have nothing to report arising from our review.

the VEB have both said that they favour a broadening of the auditor’s current formal testing responsibility to include a number of specific best practices from the Code.

We argue that any upcoming update of the Code should include greater clarification as to the responsibility of the auditor, along the lines of the UK model, and that consideration be given as to whether the role of the auditor vis-à-vis governance reporting needs to be extended.

Auditor’s report vs management letterThose representing the interests of investors also argue that the key points from the management letter6 be shared with shareholders. Neither the IAASB

5 Letter (dated 20 January 2014) from the VEB to six of the large audit firms.6 What is referred to here as management letter is the “accountantsverslag” (Board Report) to the boards of supervisory and managing directors as referred to in Book 2 Section 9

of the Dutch Civil Code. This includes the matters reported in any management letter to the extent relevant to the board of supervisory directors.

proposals nor the UK model for new auditor’s reports provide for this. That is consistent with what is stated above.

Although auditors should not be averse to sharing with shareholders the key issues from their reports to the managing and supervisory boards, the auditor’s report is not a suitable vehicle for doing this. It is the entity that is responsible to report to its shareholders and it is the auditor who expresses an opinion on this. Furthermore, the management letter is written with management and the supervisory board as key users in mind. Key points from the management letter can be addressed in the supervisory board report or dealt with by the supervisory board in the AGM.

Benchmarking of the management letter in the supervisory board reportThe manner in which entities report key matters from the management letter vary very significantly. Most of the supervisory board reports simply say that the supervisory directors have discussed the auditors’ reporting. For instance Randstad, Unilever, Vopak, Ahold, Corio, and Reed Elsevier have all taken this approach.

A limited number of supervisory board reports disclose the issues and areas for improvement that the auditor has reported. Sligro says: ‘Apart from a few minor points of financial nature, it was mainly the IT environment that merited the attention of the auditor’. Nutreco (see box) says that all the management letter issues related to ‘improvement opportunities’ and that its external auditor has recommended particular attention to the project management process for new investments and the on-boarding programmes of newly acquired entities. The supervisory board report of PostNL states that the auditor has made recommendations regarding the continue updating the internal controls framework for financial reporting towards the changing PostNL environment, the importance to keep focus on the execution

14 PwC

Nutreco supervisory board report 2013: Management letter external auditor

In early February, in the presence of the external auditor KPMG Accountants N.V., we discussed the draft 2012 annual accounts as well as the external auditor’s report and the findings summarised in the management letter. The Board agreed with the Financial Statements and approved the dividend proposal and the 2012 annual results press release. The auditor’s recommendations in the management letter were all related to improvement opportunities; no material weaknesses in internal control were identified. The improvement potential mainly relates to the on-boarding programmes of new acquired companies, as well as project management for investments. The Executive Board agreed with these comments and plans were made for follow up; we have been monitoring progress.

of controls in the context of ongoing restructuring programs, and improvements in the IT control environment in the areas of segregation of duties and change management.

A third variant is that supervisory board reports provide an indication of the nature of the management letter points by making certain specific statements. A limited number of reports say explicitly that the auditor had no significant findings. The supervisory board of Brunel makes the following statement: ‘The external auditor found no irregularities in the financial reports and also the management letter did not contain material weaknesses.’

Inclusion in the supervisory board report of the key matters discussed with, and reported (for instance in the management letter) by, the external auditor is a trend which we expect to continue in the future.

Plain speaking! 15

4. Reflection: Moving forward together

The call for more timely and transparent information will only get louder, and it will be driven on through new media channels providing on-line, real time information and by the increasing interest in non-financial information. The auditor has a crucial role to play in this.

But the ball is not just in the auditor’s court. In ‘Plain Speaking’, we argue that managing and supervisory directors, regulators, supervisory bodies, and shareholders and other stakeholders also have a crucial role to play. So it makes good sense to coordinate the various interests and maintain the clarity of the various roles. The road to change is full of challenges, and we highlight five here:

1. The entity’s board of managing directors is the body primarily charged with the responsibility of providing information to stakeholders. Stakeholders are looking more and more for entity specific information. This means not only a set of financial statements that complies with IFRS or Dutch GAAP (compliance), but also a set of financial statements that tells the real story of the entity (transparency). That takes courage. Entities must drop the fear of sharing information that is critical for a good understanding of their business – also where there is, as yet, no obligation to do so. This fear is

We see the use of the new auditor’s report by a number of auditors as a major step forward in the provision of more transparent and relevant information to stakeholders. The importance of this step must not be under-estimated.

often counter-productive. The damage that can result from information that has been withheld later becoming public is many times greater than the initial perceived need to withhold this information. We will continue to challenge entities on this score.

2. Supervisory directors are charged with overseeing management’s performance and with representing the interests of the entity and its stakeholders. We call upon supervisory directors and audit committees to provide greater insight in their reports into how they discharge these oversight responsibilities. This includes providing insight into: the dialogue with stakeholders; the content and outcome of significant discussions with management regarding risk and key areas of attention in the financial reporting process; and the assignment given to the auditor and the key points discussed with the auditor and how these were resolved and (are being) dealt with. We will continue to keep these developments high on the agenda.

3. The auditor’s responsibility is to audit the entity. He has a key role to play in assessing and communicating whether the information provided by the managing and supervisory directors is appropriate in terms of supporting the decision making processes of the stakeholders. So the auditor must also be up to speed with what the stakeholders need. We need to strengthen the dialogue we have with stakeholders. Entity specific reporting deserves entity specific auditing and an entity specific auditor’s report. In the AGM, this helps stakeholders determine

16 PwC

areas of attention for inclusion in the following year’s annual audit process and to be addressed by the auditor in his subsequent auditor’s report thereon. We need to shake off our reticence to provide more information.

4. Standard setters and regulators are responsible for the financial reporting framework and the supervision of auditors, respectively. They monitor the interests of stakeholders and thereby contribute significantly to the trust in financial reporting and the audit thereof. It is important that the standard setters and regulators ensure that the roles of the various parties remain untainted. They can do this, for instance, by translating the experiences with the new auditor’s report into more tailored standards and supervision. We have shared the results of the pilot with the IAASB and the NBA. They will continue to contribute, nationally and internationally, to the ongoing developments - for instance the new auditor’s report.

5. Shareholders and other stakeholders are demanding more relevant information from entities and their auditors. Where are the risks? What is management’s strategy therefor? What are the more subjective elements in the financial statements, and how would differing (“what if”) scenarios affect these? Does there need to be more clarity regarding the testing the auditor currently performs on the corporate governance information, the supervisory board report, and the remuneration paragraph, and does this testing need to be extended? The stakeholders themselves do need to make clear what information they need for their decision-making processes. For shareholders, the upcoming shareholders’ meetings are an excellent opportunity to get the dialogue on this going with management, the supervisory directors, and the auditor.

Plain speaking! 17

Appendices

Appendix 1. Example of Independent auditor’s report

To the General Meeting of Beursfonds N.V.

Report on the audit of the financial statements

Our opinion

In our opinion,

• the consolidated financial statements give a true and fair view of the financial position of Beursfonds N.V. as at 31 December 2013 and of its result and its cash flows for the year then ended in accordance with International Financial Reporting Standards as adopted by the European Union (EU-IFRS) and with Part 9 of Book 2 of the Dutch Civil Code, and

• the company financial statements give a true and fair view of the financial position of Beursfonds N.V. as at 31 December 2013, and of its result for the year then ended in accordance with Part 9 of Book 2 of the Dutch Civil Code.

What we have auditedWe have audited the accompanying financial statements 201X of Beursfonds N.V. Amsterdam (the Company). These financial statements consist of the consolidated financial statements and the company financial statements. The consolidated financial statements comprise the consolidated statement of income, the consolidated statement of comprehensive income, the consolidated statement of financial position as at 31 December 2013, the consolidated statement of changes in equity and the consolidated statement of cash flows for the year then ended and the notes, comprising a summary of significant accounting policies and other explanatory information. The company financial statements comprise the company statement of income for the year then ended, the company statement of financial position as at 31 December 2013 and the notes, comprising a summary of significant accounting policies and other explanatory information.

The basis for our opinionWe conducted our audit in accordance with Dutch law, including the Dutch Standards on Auditing. Our responsibilities under those standards are further described in the section Our Responsibilities for the Audit of Financial Statements as included in the appendix to our report.

We are independent of the Company within the meaning of the relevant Dutch ethical requirements as included in the ‘Verordening op de gedrags- en beroepsregels accountants’ (VGBA) and the ‘Verordening inzake de onafhankelijkheid van accountants bij assuranceopdrachten’ (ViO) and have fulfilled our other responsibilities under those ethical requirements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Plain speaking! 19

The key audit matters from our auditKey audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial statements. Key audit matters are selected from the matters communicated with [supervisory board], but are not intended to represent all matters that were discussed with them. Our audit procedures relating to these matters were designed in the context of our audit of the financial statements as a whole. Our opinion on the financial statements is not modified with respect to any of the key audit matters described below, and we do not express an opinion on these individual matters.

[Key audit matter 1 the headings describe the content of the KAM – pyramid reporting

Key audit matter 2

Key audit matter 3]

Our findings with respect to going concernAs included in Note X to the financial statements, the Company’s financial statements have been prepared using the going concern basis of accounting. The use of this basis of accounting is appropriate unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

As part of our audit of the financial statements, we concur with management’s use of the going concern basis of accounting in the preparation of the Company’s financial statements.

Management has not identified a material uncertainty that may cast significant doubt on the Company’s ability to continue as a going concern, and accordingly none is disclosed in the financial statements. Based on our audit of the financial statements, we also have not identified such a material uncertainty.

However, neither management nor the auditor can guarantee the Company’s ability to continue as a going concern.

20 PwC

Our responsibilities and the responsibilities of management and supervisory boardThe respective responsibilities are set out in the appendix to this report.

We are required to communicate with management and supervisory board regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

We are also required to provide supervisory board with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

Report on the management board report and the other informationPursuant to the legal requirements under Part 9 Book 2 of the Dutch Civil Code with respect to our responsibilities to report on the [management board report] and the other Information:

• We have no deficiencies to report as a result of our examination whether the management board report, to the extent we can assess, has been prepared in accordance with Part 9 of Book 2 of the Dutch Civil Code, and whether the other information has been annexed as required by Part 9 of Book 2 of this Code; and

• We report that the [management board report], to the extent we can assess, is consistent with the financial statements.

Amsterdam, XX February 2014PricewaterhouseCoopers Accountants N.V.

Name of the auditor and signature

Plain speaking! 21

Appendix to the auditor’s report

Responsibilities of management and supervisory board for the financial statementsManagement is responsible for the preparation and fair presentation of these financial statements in accordance with EU-IFRS and with Part 9 of Book 2 of the Dutch Civil Code and for the preparation of the management board report in accordance with Part 9 of Book 2 of the Dutch Civil Code. Furthermore management is responsible for such internal control as management determines is necessary to enable the preparation of financial statements that are free of material misstatement, whether due to fraud or error. The supervisory board are responsible for overseeing the Company’s financial reporting process.

Our responsibilities for the audit of the financial statementsThe objectives of our audit are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with Dutch Standards on Auditing will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

As part of an audit in accordance with Dutch Standards on Auditing, we exercise professional judgement and maintain professional scepticism throughout the planning and performance of the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

• Obtain sufficient appropriate audit evidence regarding the financial information and business activities of Beursfonds N.V. to express an opinion on the [consolidated] financial statements.

• We are responsible for the direction, supervision and performance of the group audit. We remain solely responsible for our audit opinion.

22 PwC

Appendix 2: Status of the 2013 annual reports as of 22 March 2014on the basis of the AEX and AMX classification as of 24 March 2014

Auditor Financial statements published

New auditor’s report

Comments

AEX yes no yes no n/a

Aegon EY x x

Ahold PwC x x

Akzo Nobel KPMG x x

ArcelorMittal Deloitte x x SA (Luxembourg)

ASML Deloitte x x

Boskalis KPMG x x

Corio PwC x x

Delta Lloyd EY x x

DSM EY x x

Fugro KPMG x x

Gemalto PwC x x

Heineken KPMG x x

ING EY x x

KPN PwC x x

OCI KPMG x x

Philips KPMG x x

Randstad PwC x x

Reed Elsevier Deloitte x x Plc (UK) and NV

Shell PwC x x Plc (UK)

SBM KPMG x x

TNT Expresss PwC x x

Unibail Rodamco Deloitte/EY x x SA (France)

Unilever PwC x x Plc (UK) and NV

Wolters Kluwer KPMG x x

Ziggo EY x x

22 3 9 13 3

Plain speaking! 23

Auditor Financial statements published

New auditor’s report

Comments

AMX yes no yes no n/a

Aalberts PwC x x

Accell Deloitte x x

Air France-KLM KPMG/Deloitte x x SA (France)

Aperam Deloitte x x SA (Luxembourg)

Arcadis KPMG x x

Arceus PwC x x NV (Belgium)

ASMI Deloitte x x

BAM PwC x x

BinckBank EY x x

Brunel PwC x x

Cate, ten KPMG x x

Corbion Deloitte x x

Eurocommercial EY x x Year end 30 June

Exact KPMG x x

Imtech KPMG x x

NSI KPMG x x

Nutreco KPMG x x

PostNL PwC x x

Sligro KPMG x x

TKH Deloitte x x

TomTom Deloitte x x

USG PwC x x

Vastned Deloitte x x

Vopak PwC x x

Wereldhave PwC x x

16 9 8 8 9

Source: Company websites

24 PwC

Appendix 3. Examples of key audit matters in the auditor’s reports

Vopak:

Significant IT migration for the Netherlands businessIn 2013, the Netherlands business has migrated to a new IT system for its main financial reporting processes. We have focused on this migration due to the inherent risk of error and the impact such an error may have on the control environment of the Group’s largest operating segment. In this context we involved our IT specialists and assessed, amongst other things, the quality controls governing the implementation of the new IT system, the configuration within the new system’s modules, the interaction between the modules, the segregation of duties and the configuration of expected automated application controls. We also tested the migration of general ledger data from the legacy IT system to the new IT system.

SBM Offshore:

Revenue recognition on contruction contrcts involves significant judgementThe engineering and construction of Floating Production Storage and Offloading systems (FPSOs) is complex and exposes the Company to various business and financial reporting risks. Revenue arising from construction contracts, in its Turnkey segment, represent more than 75% of the Group’s total revenue. The recognition of revenue and the estimation of the outcome of construction contracts requires significant management judgement, in particular with respect to estimation the cost to complete and the amounts of variation orders to be recognised. In addition, significant management judgement is required to assess the consequences of various legal proceedings in respect of construction contracts. Reference is made to 4.2.6 Notes to the Consolidated Financial Statements, Accounting principles, C. Critical accounting policies, (e) Revenue: Contsruction contracts.

We identified revenue from construction contracts as a significant risk, requiring special audit consideration. Our audit procedures included an evaluation of the significant judgements made by management, amongst others based on an examination of the associated project documentation and discussion on the status of projects under construction with finance and technical staff of the Company. We also tested the controls that the Company has put in place over its process to record contract costs and contract revenues and the calculation of the stage of completion. In addition we visited two projects under construction. Furthermore, we discussed the status of legal proceedings in respect of construction contracts, examined various documents in this respect and obtained lawyers’ letters.

Plain speaking! 25

Nutreco:

Sensitivities with respect to the valuation goodwillThe annual impairment test was significant to our audit as the assessment process is complex and judgemental by nature as it is based on assumptions on future market and/or economic conditions. The assumptions used included future cash flow projections, discount rates, perpetuity and sensitivity analyses.We specifically focused on the valuation of goodwill allocated to the Animal Nutrition Brazll business’ given the available headroom. Our procedures included, among others, using a valuation expert assisting us in evaluating the model and assumptions used, in particular the future growth rates and discount rates which are key to the outcome of the impairment test. We further focused on the adequacy of the Company’s disclosures on key assumptions in Note 14 of the financial statements.

Post NL:

Pension accountingAs from 1 January 2013 the accounting standard for pensions has changed (IAS19R). Changes in key assumptions applied under IAS 19R have a significant impact on the defined benefit obligations, pension costs incurred and equity. The accounting requires the company to make assumptions regarding parameters such as the discount rate, the rate of benefit increase and future mortality rates. Our audit procedures included, amongst others, evaluating the assumptions and the methodologies used by the company, whereby we also used pension experts to assist us. We tested the disclosure of the pension paragraph and specifically the change to IAS 19R. The impact of IAS 19R on the consolidated 2012 balance sheet and (comprehensive) income statement has been disclosed in the Summary of restatements in the notes. Disclosures on the assumptions applied including a sensitivity analysis are included in note 11.

26 PwC

If you would you like more information about the pilot we have run with the new auditor’s report, please contact the authors of this publication:

Arjan Brouwer*PartnerTelephone: 088 792 4945E-mail: arjan.brouwer@nl.pwc.com*also associated with the University of Amsterdam

Peter Eimers*PartnerTelephone: 088 792 5081E-mail: peter.eimers@nl.pwc.com*also associated with the VU University, Amsterdam

Jos de GrootSenior DirectorTelephone: 088 792 5238E-mail: jos.de.groot@nl.pwc.com

Frans de GrootSenior managerTelephone: 088 792 5286E-mail: frans.de.groot@nl.pwc.com

This edition was completed as of 22 March 2014. Any developments subsequent to that date are not included.

At PwC in the Netherlands, over 4,300 people work together from 12 offices. PwC Netherlands helps organisations and individuals create the value they’re looking for. We’re a member of the PwC network of firms in 157 countries with more than 184,000 people. We’re committed to delivering quality in assurance, tax and advisory services. Tell us what matters to you and find out more by visiting us at www.pwc.nl.

Contact

© 2014 PricewaterhouseCoopers Accountants N.V. (KvK 34180285). All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.