EFRAG does not see a conceptual reason why the rationale explained in the Basis for Conclusions of the Draft Interpretation would not also apply to levies due only if a minimum revenue threshold is achieved. That is, in EFRAG's view, the generation of revenue prior to reaching the threshold is necessary, but not sufficient to create an obligation which would give rise to the recognition of a liability. Consequently, EFRAG believes that the Interpretations Committee should explain why this would not apply in the case of levies that are due only if a minimum revenue threshold is achieved.

Furthermore, EFRAG recommends that the IASB make clearer that the scope of the Draft Interpretation is very broad and includes within its scope the majority of payments to public authorities (e.g. property tax).  Other matters discussed in the draft comment letter include such topics as the treatment of levies that are not non-reciprocal transfers or have multiple elements, how fixed fee levies should be treated, and various suggestions to clarify the wording and intent of the Draft Interpretation.

Comments on the letter are invited by 22 August 2012. The draft comment letter can be downloaded via the press release on EFRAG's website.