Deloitte comment letter on ED/2011/2 'Improvements to IFRSs'
We are generally in agreement with the intentions of the proposed amendments, but are concerned that some amendments (in particular, those to IFRS 1 First-time Adoption of International Financial Reporting Standards) may have unintended consequences.
These unintended consequences arise principally from ambiguous drafting which, as noted in our comments on the exposure draft of the 2009 amendments (ED/2009/11), include inconsistencies between the Basis of Conclusions and the actual wording of the amendment.