Whilst we support the proposed amendments, we believe that the amendments provide the IASB with an opportunity to develop a principle for the accounting for all types of share-based payment arrangements involving group entities and owners of the entity as a whole. Such an approach would help to avoid issuing interpretations and amendments on the accounting for share-based payment transactions on a piecemeal basis by the Board.

To establish such a principle, we believe that the definition of a 'share-based payment transaction' in Appendix A of IFRS 2 should be amended to clarify that share-based payments involving group entities meet that definition.

We also encourage the Board to consider addressing situations where linkage of separate transactions may be appropriate in share-based payment transactions involving group entities.