Deloitte Comment Letters
Responses from Deloitte to standard-setters invitations to comments and exposure-drafts.
Responses from Deloitte to standard-setters invitations to comments and exposure-drafts.
Mar 10, 2023
Deloitte Touche Tohmatsu Limited is pleased to respond to the International Accounting Standards Board’s (“the IASB”) Exposure draft International Tax Reform—Pillar Two Model Rules (“the ED”).
Jul 20, 2022
We have commented on the ISSB's exposure draft ED/2022/S1 'General Requirements for Disclosure of Sustainability-related Financial Information' published in March 2022.
Jul 20, 2022
We have commented on the ISSB's exposure draft ED/2022/S2 'Climate-related Disclosures' published in March 2022.
Apr 11, 2022
We have commented on the IASB's exposure draft Supplier Finance Arrangements — Proposed amendments to IAS 7 and IFRS 7.
Mar 23, 2022
We have commented on the IASB's exposure draft Non-current Liabilities with Covenants — Proposed amendments to IAS 1 published in November 2021.
Jan 28, 2022
We have commented on the IASB's Request for Information — Post-implementation Review IFRS 9 Financial Instruments Classification and Measurement (RFI) published in September 2021.
Jan 06, 2022
We have commented on the IASB's exposure draft ED/2021/3 'Disclosure Requirements in IFRS Standards — A Pilot Approach' published in March 2021.
Nov 23, 2021
We welcome the Board’s project to revise the Practice Statement on Management Commentary. However, we suggest that further improvements are necessary on certain significant issues.
Sep 28, 2021
We support the proposals in the exposure draft and provide recommendations in a number of areas.
Sep 24, 2021
Overall, we believe that the Board’s time is appropriately allocated to the different activities and that this allocation will remain largely appropriate for the next few years. However, we believe that two key areas will require further direct attention by the Board — sustainability reporting related issues and digital reporting.
Aug 31, 2021
We acknowledge that the use of an official exchange rate may not produce meaningful results when this rate is not available to the entity. However, we do not believe that attempting to estimate the exchange rate that would have been available if the currency had been exchangeable would produce meaningful results either. Accordingly, we believe that the Board should seek a solution that gives precedence to comparability.
Aug 31, 2021
We generally agree with the Board’s preliminary views as expressed in the discussion paper. In particular, we agree that different methods should be applied depending on the characteristics of the receiving entity. We agree that when the receiving entity does not have non-controlling shareholders, use of a book-value method is justified by cost-benefit considerations. However, we do not agree that the receiving entity should be required to use the transferred entity’s book values. We also agree that the acquisition method is likely to provide more relevant information to investors that must rely on general purpose financial statements of the receiving entity to obtain the information they require. Accordingly, we believe that the application of the acquisition method should be required more broadly than what is proposed in the discussion paper.
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