Deloitte comment letter on ED/2009/1 'Post-implementation Revisions to IFRIC Interpretations'
We agree with the proposal to amend IFRIC 9 as set out in the ED and encourage the Board to finalise it as soon as feasible. At this time, we are not ready to support the proposal to amend IFRIC 16 as it is not clear to us what fact pattern the Board has in mind and whether the rationale applies to all situations where the hedging instrument is being held by the foreign operation being hedged. Additionally, we believe that the proposed effective date for the amendment to IFRIC 16 is not appropriate in light of the type of change to the guidance and of the prospective nature of hedge accounting.