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Deloitte comment letter on the SME Implementation Group draft Q&As (third batch)

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Deloitte comment letter on the IASB's proposal to defer the effective date of recent IAS 1 amendments
03 Jun 2020
We have commented on IASB exposure draft ED/2020/3, "Classification of Liabilities as Current or Non-Current – Deferral of Effective Date," which was published by the IASB on 4 May 2020. The ED proposes to defer the effective date of the January 2020 amendments to IAS 1 by one year.
Deloitte comment letter on the IASB's proposed amendments as a result of the second phase of its project on the IBOR reform
25 May 2020
We are largely supportive of the amendments. In particular, we support the key changes that ensure that entities that apply hedge accounting will continue to do so as they transition to new benchmark interest rates and that the accounting for the modification of hedged items, when those modifications arise directly from the reforms, are reflected on a prospective basis via the application of IFRS 9:B5.4.5. We consider these as being the two most important elements of the proposals.
Deloitte comment letter on tentative agenda decision on IAS 12 — Deferred tax related to an investment in a subsidiary
13 May 2020
We have commented on the IFRS Interpretations Committee's publication in the March 2020 IFRIC Update of the tentative decision not to take onto the Committee's agenda the request for clarification on how an entity, in its consolidated financial statements, accounts for deferred tax related to its investment in a subsidiary.
Deloitte comment letter on tentative agenda decision on IFRS 16 — Sale and leaseback with variable payments
13 May 2020
We have commented on the IFRS Interpretations Committee's publication in the March 2020 IFRIC Update of the tentative decision not to take onto the Committee's agenda the request for clarification on how to measure a right-of-use asset (RoU asset) arising from a sale and leaseback and thus how to determine the amount of any gain or loss on the transaction.
Deloitte comment letter on the IASB's proposed amendments to IFRS 16 related to COVID-19
08 May 2020
We have commented on IASB Exposure Draft (ED) 2020/2 'Covid-19-Related Rent Concessions' which was published by the IASB on 24 April 2020. The ED contains a proposed amendment that would provide lessees with an exemption from assessing whether a COVID-19-related rent concession is a lease modification.
Deloitte comment letter on tentative agenda decision on IAS 38 — Presentation of player transfer payments
14 Feb 2020
We have commented on the IFRS Interpretations Committee's publication in the November 2019 IFRIC Update of the tentative decision not to take onto the Committee's agenda the request for clarification on the presentation of the transfer payment received by an entity in exchange for releasing a player from an employment contract, when the costs to obtain the registration rights had been recognised as an intangible asset.
Deloitte comment letter on tentative agenda decision on IAS 12 — Multiple tax consequences of recovering an asset
14 Feb 2020
We have commented on the IFRS Interpretations Committee's publication in the November 2019 IFRIC Update of the tentative decision not to take onto the Committee's agenda the request for clarification on the determination of the tax base of an asset and the accounting for the related deferred tax when the recovery of the carrying amount of an asset gives rise to multiple tax consequences.
Deloitte comment letter on the IASB's proposed amendments to IAS 1 and the Materiality Practice Statement
29 Nov 2019
Whilst we agree that it is useful to replace “significant” by “material”, we are concerned that without further guidance, the assessment of whether an accounting policy is material may be driven primarily by quantitative considerations. This is why we suggest that additional guidance is added to IAS 1 to highlight that the assessment of materiality should be based on whether the transaction, other event or condition to which the accounting policy relates is material in size or nature or a combination of both.
Deloitte comment letter on tentative agenda decision on IAS 21 and IAS 29 — Cumulative exchange differences before a foreign operation becomes hyperinflationary
25 Nov 2019
We have commented on the IFRS Interpretations Committee's publication in the September 2019 IFRIC Update of the tentative decision not to take onto the Committee's agenda the request for clarification on whether, at the beginning of the period during which its foreign operation becomes hyperinflationary, an entity reclassifies within equity the cumulative pre-hyperinflation exchange differences.
Deloitte comment letter on tentative agenda decision on IFRS 16 — Definition of a lease — Shipping contract
25 Nov 2019
We have commented on the IFRS Interpretations Committee's publication in the September 2019 IFRIC Update of the tentative decision not to take onto the Committee's agenda the request for clarification on whether in the specific fact pattern presented the customer has the right to direct the use of a ship throughout the five-year term of a particular contract.

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