We comment on two IASB exposure drafts

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20 Aug 2019

We have responded to the IASB’s exposure drafts ED/2019/2 'Annual Improvements to IFRS Standards 2018–2020' and ED/2019/3 'Reference to the Conceptual Framework (Proposed amendments to IFRS 3)'.

As regards the proposed annual improvements, we agree with the proposed amendments to IFRS 9, IFRS 16, and IAS 41, however, we do not believe that the proposed amendment to IFRS 1 should be a requirement - we believe it should be an option. Our full comment letter is available here.

As regards the proposed amendments to IFRS 3, we agree with the proposed amendments to IFRS 3 to replace a reference to an old version of the Conceptual Framework. We also agree with the proposed addition of an exception for the recognition principles in IFRS 3 with respect to liabilities and contingent liabilities in the scope of IAS 37 and of IFRIC 21 and of the clarification of the IFRS 3 requirements for contingent assets. However, we believe that an exception to the recognition principles in IFRS 3 is also required with respect to uncertain current tax positions within the scope of IFRIC 23. Our full comment letter is available here.

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