Posted by & filed under Financial Reporting.

4 February 2016

Mr H. Hoogervorst
Chairman
International Accounting Standards Board 30 Cannon Street
London EC4M 6XH
UNITED KINGDOM

Dear Mr Hoogervorst

commentletters@ifrs.org

ED/2015/10 ‘Annual Improvements to IFRSs’

The Group of 100 (G100) is an organization of chief financial officers from Australia’s largest business enterprises with the purpose of advancing Australia’s financial competitiveness. The G100 is pleased to provide comment on this ED.

Q1 Proposed amendments

Do you agree with the IASB’s proposal to amend the Standards as described in the ED? If not, why and what alternative do you propose?

  • IFRS 1 First-time adoption of IFRSs: The G100 supports the proposed amendments to IFRS 1 to remove the short-term exemptions from the Standard.
  • IFRS 12 Disclosure of interests in other entities: The G100 supports the proposals to clarify the application of the disclosure requirements in IFRS 12 as they interact with the disclosure requirements of IFRS 5 ‘Non-current assets held for sale and discontinued operations’.
  • IAS 28 Investments in associates and joint ventures: The G100 supports the proposed amendment to clarify that the fair value through profit and loss measurement option can be applied on an investment-by-investment basis.

Q2 Transition provisions

Do you agree with the proposed transition provisions as described in the ED. If not, why and what alternative do you propose?

  1. IFRS 1 First-time adoption of IFRSs: The G100 agrees with the transitional provisions.
  2. IFRS 12 Disclosure of interests in other entities: The G100 agrees with the proposed transitional provisions which are consistent with IAS 8 ‘Accounting policies, changes in accounting estimates and errors’.
  3. IAS 28 Investments in associates and joint ventures: The G100 agrees with the proposed transitional provisions which are consistent with IAS 8 ‘Accounting policies, changes in accounting estimates and errors’.

Sincerely

Group of 100 Inc

Zlatko Todorcevski

President