Deloitte comment letter on IFRIC D23 'Distributions of Non-cash Assets to Owners'
We agree with and support the consensus proposed in the Draft Interpretation to measure a liability to distribute non-cash assets as dividends to its owners at fair value, with any difference between the fair value of the liability and the carrying amount of the non-cash assets being recognised in profit or loss.
We also agree that the entity should apply the requirements of IFRS 5 to non-current assets held for distribution to owners. However, we have a number of concerns with the consensus which are outlined in our detailed responses to the specific questions for comment in Appendix A of the letter. In addition, we have included further comments and concerns on other aspects of the draft Interpretation in Appendix B to the letter.
Our key concern with the proposals outlined in the draft Interpretation is that we do not agree that when an entity enters into an obligation to distribute non-cash assets to its owners, the measurement of that liability falls within the scope of IAS 37 Provisions, Contingent Liabilities and Contingent Assets.