Regarding the discussion paper Business Combinations under Common Control, 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. Please click to download our full comment letter here.

Regarding the exposure draft Lack of Exchangeability (Proposed amendments to IAS 21), 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. Please click to download our full comment letter here.