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Deloitte comment letter on annual improvements to IFRSs

Published on: Sep 05, 2012

Deloitte's IFRS Global Office has submitted a letter of comment to the International Accounting Standards Board (IASB) on its Exposure Draft ED/2012/1 — Annual improvements to IFRSs 2010–2012 cycle.

In the comment letter, we express our agreement with most of the proposed amendments in the 2010–2012 cycle of annual improvements, but also note that there are more effective ways in which the issues could be resolved. Examples include:

  • [T]he proposed amendments to IAS 1 and IAS 12 are interpretative issues that the Board should consider addressing primarily through the addition of examples rather than by introducing changes to the standards that may have unintended consequences and give rise to further interpretative issues.
  • [W]e do not believe that changes to, or clarifications of, requirements should be expressed only in a standard’s basis of conclusions (as is the case for the exposure draft’s proposals in respect of IFRS 13 and, to some extent, IFRS 2).

We also recommend that the proposed amendments to IFRS 8 requiring disclosures about the basis of aggregation should not be finalised until the post-implementation review of IFRS 8 is complete. Similarly, we also suggest that the proposed amendments to IAS 7 specifying the classification of payments of interest capitalized in accordance with IAS 23 should not be finalised because of the ongoing IFRS Interpretations Committee project on the classification of various items in the statement of cash flows.

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