Deloitte comment letter on IASB ED/2013/11 'Annual Improvements to IFRSs 2012–2014 Cycle'

Published on: 10 Mar, 2014

Deloitte Touche Tohmatsu Limited has responded to the International Accounting Standards Board's (IASB) Exposure darft ED/2013/11 Annual Improvements to IFRSs 2012–2014 Cycle published in December 2013.

We continue to believe that the Annual Improvement Project is an efficient and effective means of dealing with isolated issues within IFRSs that are leading to divergent practice. However, in respect of the 2012-2014 cycle of annual improvements, we are concerned by the proposed amendments to IFRS 7, IAS 19 and IAS 34:

  • We question whether disclosure of market rate servicing contracts is consistent with the purpose of the 2010 amendments to IFRS 7 Financial Instruments: Disclosures and whether it will provide valuable information to users.
  • We also believe that the issue of discount rates on defined benefit obligations should be considered more thoroughly. The proposed amendment to IAS 19 Employee Benefits may not be appropriate for all jurisdictions.
  • Lastly, we recommend that the Board liaise with the IAASB before finalising the amendment to IAS 34 Interim Financial Reporting to ensure that no conflict between accounting and assurance standards arises.

Download the full comment letter below.


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