12 February 2013
Mr Hans Hoogervorst
International Accounting Standards Board
30 Cannon Street
London EC 4M 6XH
Dear Mr Hoogervorst
ED/2012/2 Annual Improvements to IFRSs 2011–2013 cycle
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. We are pleased to offer comment on the Exposure Draft.
Q1 Do you agree with the IASB’s proposal to amend the Standard as described in the ED? If not, why and what alternative do you propose?
|a .||IFRS 1 First-time adoption of IFRSs
While supporting the proposed clarification the G100 believes that any such clarification should be included as part of the commentary in IFRS 1 rather than the Basis for Conclusions which accompanies, but does not form part of, the IFRS.
|b.||IFRS 3 Business Combinations
The G100 supports the proposed amendments.
|c.||IFRS 13 Fair Value Measurement
The G100 supports the proposed amendment to clarify that the portfolio exception applies to all contracts within the scope of IFRS 9 and IAS 39.
|d.||IAS 40 Investment Property
The G100 supports the proposed amendment to clarify the interaction of IFRS 3 and IAS 40 where an investment property is acquired including the operation of IAS 40 requirements relating to classifying a property as an owner occupied property or an investment property.
Q2 Do you agree with the proposed transitional provisions and effective date for the issue as described in the ED? If not, why and what alternative do you propose?
|a .||IFRS 1 First-time adoption of IFRSs|
|b.||IFRS 3 Business Combinations|
|c.||IFRS 13 Fair Value Measurement|
|d.||IAS 40 Investment Property|
The G100 agrees with the proposed transitional provisions and effective dates for these changes.
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