The first comment letter refers to the IFRS IC’s tentative agenda decision on IAS 34 Interim Financial Reporting.   The IFRIC IC took the tentative decision not to add to its agenda the request for clarification it received on the application of the requirements regarding the presentation and content of the condensed statement of cash flows in the interim financial statements. 

ESMA agrees that an explicit prohibition of a three-line presentation of statement of cash flows in IAS 34 “would be inconsistent with the principles-based nature of IFRSs”.  However, due to “existing diversity in practice” ESMA believes that “a clarification of paragraphs 10 and 15 of IAS 34 would enhance the enforceability of IFRSs”.  ESMA also believes that the threshold for including additional line items or notes in the interim financial statements in paragraph 10 of IAS 34 “could be lowered”.  ESMA comments that “these suggested amendments to IAS 34 would contribute to consistency in application and enhance enforceability of IAS 34 requirements”.

The second comment letter refers to the IFRIC IC’s tentative agenda decision on IAS 12 Income Taxes.  The IFRIC IC took the tentative agenda decision not to add to its agenda the request for clarification it received on the accounting for deferred tax in the consolidated financial statements of the parent, when a subsidiary has only one asset and the parent expects to recover the carrying amount of this asset by selling all the shares in that subsidiary.

ESMA believes that this project should be dealt with by the International Accounting Standard Board (IASB) as a narrow scope project and “urges the IFRIC IC to refer this matter to the IASB”.

Both the IAS 34 and IAS 12 comment letters can be found on the ESMA website.