In this comment letter, we do not object to the board’s proposal to restore the use of the equity method as one of the options to account for investments in subsidiaries, joint ventures and associates in an entity’s separate financial statements. However, we do not support the requirement for retrospective application of the exposure draft nor the proposed consequential amendment to IAS 28, Investments in Associates and Joint Ventures.
In this comment letter, we respond to the boards tentative agenda decision: IFRS 2, Share-based payment – price difference between the institutional offer price and the retail offer price for shares in an initial public offering. We support the committee’s decision not to take this question onto the agenda but not for the reasons given. We are concerned that the reasons given for the agenda decision will increase diversity in practice regarding the application of IFRS 2 paragraph 13A and may also lead to diversity in the application of IFRS 13.
The PwC global network of firms expresses support of the proposed interim standard on regulatory deferral balances. The interim standard will help resolve practice problems in some jurisdictions and reduce the barriers to adopting IFRS, but will not increase diversity in practice among entities that already apply IFRS. Our letter also provides responses to the board's specific questions.
In this comment letter, the PwC global network of firms responded to the IASB’s exposure draft on Financial instruments: Expected credit losses. The PwC global network continues to support the development of a single converged model for credit impairment under both IFRS and US GAAP. We believe an expected loss approach that requires constituents to consider a broader information set, including future expectations, represents a significant improvement as compared to the incurred loss model used today.
The PwC global network of firms supports the board’s efforts to gather information on the topic of rate regulation and provides suggestions for the board to consider for the discussion paper phase of the project.
PwC supports the board’s efforts in clarifying whether an entity is required to discontinue hedge accounting when an over-the-counter (OTC) derivative is novated to a central counterparty (CCP) as required by law or regulation. We also appreciate the board’s responsiveness in addressing this urgent issue in a pragmatic way, as requiring entities to treat such novations as a discontinuance of hedge accounting would not provide useful information to investors.
PwC agrees with the board’s objectives to amend IFRS 9 and commend the board on their progress in achieving those objectives. The letter includes key comments that we would like to raise with the board.
Following consultation with members of the PwC network of firms, this response summarizes the views of member firms who commented on the tentative agenda decision, published in the January 2013 edition of IFRIC Update.
PwC global network of firms submitted comments on the IASB's request for information on IFRS for SMEs. The comments provided have been grouped into six broad categories to simplify our response and to avoid repetition. The Firm comments specifically on the scope of the SME standard, convergence with IFRSs, income taxes, options, convergence with the EU directives and the use of additional IASB guidance for SMEs.
The PwC network global network of firms believes that the application of the conclusions in the draft interpretation will result in accounting that does not reflect the economic substance of many levies.
PwC global network of firms supports the Interpretations Committee's decision that the accounting for employee benefit plans with a promised return on contributions or notional contributions explored in the Draft IFRIC should be further considered.