Approximate cumulative effect on shareholders' equity of differences between UK and US GAAP	1999 US$m*	1998 US$m*
Shareholders equity per UK GAAP	832.2	819.4
Approximate cumulative effect of differences between UK GAAP and US GAAP	2,097.2	2,425.5
Approximate shareholders' equity as adjusted for US GAAP	2,929.4	3,244.9
Attributable to:
Ordinary shareholders	2,367.1	2,641.5
Preference shareholders	562.3	603.4
	2,929.4	3,244.9
Approximate effect on net income of differences between UK and US GAAP
Income for the financial year attributable to holders of Ordinary shares, per UK GAAP	132.3	324.1
Approximate effect on net income of differences between UK GAAP and US GAAP (note 1)	(347.3)	(122.0)
Approximate net income attributable to holders of Ordinary shares under US GAAP	(215.0)	202.1
Approximate net income as adjusted for US GAAP:
per Ordinary share (note 1)	($0.35)	$0.33
per American Depositary share (note 1)	($1.75)	$1.66

*These reconciliations of net income and shareholders' equity reflect a translation of these statements using US$1.647/£, the rate in effect on 30 September 1999.

Note 1. US GAAP net income is stated after charging an exceptional provision for permanent diminutions in the carrying value of goodwill in the amount of £144.6m (US$238.2m) (1998 - Nil). The per Ordinary share amount of the exceptional provision in 1999 is (US$0.39) (per American Depositary share (US$1.94)).

Summary of differences between UK and US GAAP
The Group's financial statements are prepared in accordance with UK GAAP which differs in certain significant respects from US GAAP. These differences relate principally to the following items and the approximate effect of the necessary adjustments is shown in the foregoing tables.

Goodwill and US purchase accounting
Under UK GAAP, for acquisitions arising before 30 September 1998 the Group charged goodwill arising on such business combinations treated as purchases directly to reserves. From 1 October 1998 goodwill arising on acquisitions under UK GAAP has been capitalised as an intangible asset and is written off over periods of up to 20 years. Under US GAAP, intangibles, including goodwill, in respect of business combinations treated as purchases would be charged against income over their estimated lives. Any intangible relating to a business sold in the year is written off in determining the profit or loss on disposal. In determining the differences between UK GAAP and US GAAP shown above, US GAAP has been applied using amortisation periods in respect of goodwill of up to 40 years and in respect of other intangibles arising on acquisition, of up to 20 years.

Ordinary dividends
Under UK GAAP, final Ordinary dividends are provided for in the fiscal year in respect of which they are recommended by the Board of Directors for approval by the shareholders. Under US GAAP, such dividends are not provided for until approved by the shareholders.

Pension costs
Differences between the UK and US GAAP figures arise from the requirement to use different actuarial methods and assumptions and the method of amortising surpluses or deficits.

Programme production and development
Under UK GAAP programme production costs are written off fully when the material is first transmitted. Under US GAAP costs are written off over the expected useful life of the material, using the income forecast method.