IASB: ED/2013/11 Annual Improvements to IFRSs: 2012–2014 Cycle

5 February 2014


Mr H. Hoogervorst
International Accounting Standards Board
30 Cannon Street
London EC 4M 6Xh

Dear Mr Hoogervorst

ED/2013/11 “Annual Improvements to IFRSs
2012 – 2014 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 agree that these issues are appropriately addressed as part of the annual improvements process.

1. IFRS 5 ‘Non-current assets held for sale and discontinued operations

The G100 supports the proposed clarification of the requirements.

2. IFRS 7 ‘Financial Instruments: Disclosure’

a. Issue – service contracts: The G100 supports the proposed amendments to clarify the requirements regarding whether there is continuing involvement in relation to service contracts.
b. Issue – offsetting: The G100 agrees with the proposed amendments which will reduce the volume of disclosures and associated costs without the loss of relevant information for users.

3. IAS 19 ‘Employee Benefits’

The G100 supports the proposal to make a requirement in IAS 19 referring to ‘countries’ more reflective of the current institutional arrangements. However, it is unclear whether an entity will be required to determine the discount rate on the basis of the corporate bond market in all countries in the currency zone or whether the rate can be determined on the basis of the corporate bond market applying in its national jurisdiction.

4. IAS 34 ‘interim financial reporting’

The G100 supports these amendments to IAS 34.


Neville Mitchell


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