Submissions and comment letters

2012

Draft IFRIC interpretation DI/2012/2: put options written on non-controlling interests (7 September 2012)

Exposure Draft: ED/2012/1 – annual improvements to IFRSs 2010-2012 cylce (21 August 2012)

Exposure Draft: transition guidance – proposed amendments to IFRS 10 (21 March 2012)

Exposure Draft: Revenue from Contracts with Customers (ED/2011/6), Revised Exposure Draft of a proposed Accounting Standards Update of Topic 605 (9 March 2012)

2011

Exposure Draft – Government Loans: Proposed amendments to IFRS 1 (22 December 2011) (149 KB)

Comments on the International Accounting Standards Board's (the Board) Exposure Draft Government Loans: Proposed amendments to IFRS 1(the ED).

Exposure Draft Investment Entities (ED/2011/4) (22 December 2011) (232 KB)

Comments on the International Accounting Standards Board's (the Board) Exposure Draft Investment Entities (ED/2011/4).

Exposure Draft Q&As 2011 IFRS for SMEs (28 November 2011) (175 KB)

Grant Thornton International Ltd is pleased to comment on the SME Implementation Group's (the SMEIG's) Exposure Drafts (EDs) of the Q&As listed. We have considered the EDs, as well as each accompanying draft Basis for Conclusions.

Request for Views - Agenda Consultation 2011 (28 November 2011) (193 KB)

Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's (the Board) Request for Views – Agenda Consultation 2011 (the Request for Views).

Exposure Draft – Improvements to International Financial Reporting (19 October 2011)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft Improvements to International Financial Reporting Standards (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

Exposure Draft Mandatory Effective Date of IFRS 9 (2 September 2011)

Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft Mandatory Effective Date of IFRS 9 (the Exposure Draft). We have considered the Exposure Draft along with the accompanying Basis for Conclusions.

Commission Statement in Support of Convergence and Global Accounting Standards (29 July 2011)

Comment on the May 26, 2011 SEC Staff Paper, Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers: Exploring a Possible Method of Incorporation.

Exposure Draft Q&As 2011/02; 03 and 04 IFRS for SMEs Section 1 (16 June 2011)

Comment on the SME Implementation Group's Exposure Drafts of several Q&As. We have considered the EDs, as well as each accompanying draft Basis for Conclusions.

Consultative Report on the Review of the IFRS Foundation's Governance (6 April 2011)

Comment on the IFRS Foundation Monitoring Board's Consultative Report on the Review of the IFRS Foundation's Governance.

Supplementary Document: Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities: Impairment (1 April 2011)

Comment on the International Accounting Standards Board’s and the Financial Accounting Standards Board’s Supplementary Document, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities: Impairment.

Use of the IFRS for SMEs in parent’s separate financial statements (1 April 2011)

Grant Thornton International Ltd is pleased to comment on the SME Implementation Group's Exposure Draft of Q&A 2011/01 Use of the IFRS for SMEs in parent’s separate financial statements.

Exposure Draft Hedge Accounting (8 March 2011)

Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft Hedge Accounting.

IFRS Foundation Strategy Review (24 February 2011)

Grant Thornton International Ltd welcomes the opportunity to respond to the IFRS Foundation's Paper for Public Consultation Status of Trustees' Strategy Review.

2010

Exposure Draft Leases (15 December 2010)

Comment on the International Accounting Standards Board and Financial Accounting Standards Board Exposure Draft, Leases.

Exposure Draft Severe Hyperinflation - Proposed amendment to IFRS 1 (29 November 2010)

Comment on the International Accounting Standards Board's Exposure Draft Severe Hyperinflation - Proposed amendment to IFRS 1 (the ED).

IFRIC Draft Interpretation DI/2010/1 Stripping Costs in the Production Phase of a Surface Mine (17 November 2010)

Comment on the IFRS Interpretations Committee’s Draft Interpretation DI/2010/1 Stripping Costs in the Production Phase of a SurfaceMine (DI/2010/1).

Exposure Draft Deferred Tax: Recovery of Underlying Assets (8 November 2010)

Comment on the International Accounting Standards Board's (the Board) Exposure Draft Deferred Tax: Recovery of Underlying Assets - Proposed amendments to IAS 12 (the ED).

Exposure Draft Removal of Fixed Dates for First-time Adopters (22 October 2010)

Comment on the International Accounting Standards Board's Exposure Draft Removal of Fixed Dates for First-time Adopters - Proposed amendments to IFRS 1 (the ED)

Exposure Draft Revenue from Contracts with Customers (21 October 2010)

Comment on the International Accounting Standards Board and Financial Accounting Standards Board Exposure Draft Revenue from Contracts with Customers (the ED).

Exposure Draft ED/2010/5 Presentation of Other Comprehensive Income (27 September 2010)

Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2010/5 Presentation of Other Comprehensive Income (Proposed amendments to IAS 1) (the ED).

ED/2010/7 Measurement Uncertainty Analysis Disclosure for Fair Value Measurement (3 September 2010)

Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's (the Board)Exposure Draft ED/2010/7 Measurement Uncertainty Analysis Disclosure for Fair Value Measurements (the ED).

Exposure Draft ED/2010/3 Defined Benefit Plans (3 September 2010)

Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2010/3 Defined Benefit Plans (Proposed amendments to IAS 19) (the ED).

Discussion Paper Extractive Activities (19 July 2010)

Comment on the Discussion Paper Extractive Activities (the Paper). Our main comments and suggestions on the issues raised in the Paper are summarised in the attached document. Our responses to the Invitation to Comment questions are set out in the Appendix.

Exposure Draft ED/2010/4 Fair Value Option for Financial Liabilities (15 July 2010)

Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2010/4 Fair Value Option for Financial Liabilities. We have considered the ED as well as the accompanying draft Basis for Conclusions.

Exposure Draft ED/2009/12 - Financial Instruments: Amortised Cost and Impairment (9 June 2010)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/12 - Financial Instruments: AmortisedCost and Impairment.

Exposure Draft ED/2010/1 Measurement of Liabilities in IAS 37 (18 May 2010)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2010/1 Measurement of Liabilities in IAS 37 (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

Exposure Draft ED/2009/6 Management Commentary (19 February 2010)

Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/6 Management Commentary (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

2009

Exposure Draft ED/2009/13 Limited Exemption from Comparative IFRS 7 (17 December 2009) (81.21KB)

Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/13 Limited Exemption from Comparative IFRS 7 Disclosures for First-time Adopters (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

Review Part 2 Proposals for Enhanced Public Accountability (30 November 2009) (148.04KB)

Comment on the IASC Foundation's Consultation Document Part 2 of the Constitution Review - Proposals for Enhanced Public Accountability (the Part 2 Proposals). In the attached letter we offer some general comments on the Part 2 Proposals.

Exposure Draft Improvements to International Financial Reporting Standards (24 November 2009) (170.76KB)

Comment letter on the International Accounting Standards Board's (the Board) Exposure Draft Improvements to International Financial Reporting Standards (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

Rate Regulated Activities (17 November 2009) (140 KB)

Comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/8 Rate-regulated Activities(the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

Draft Endorsement Advice and Effects Study Report on IFRS 9 Financial Instruments (10 November 2009) (132 KB)

Comment letter submitted November 10, 2009.

IFRIC Draft Interpretation D25 Extinguishing Financial Liabilities with Equity Instruments (2 October 2009) (93.8 KB)

Grant Thornton International Ltd agrees that IFRS does not provide specific guidance on accounting for transactions in which an entity issues its own equity instruments to extinguish all or part of a financial liability. It also believes there is significant diversity in the accounting for such transactions in practice.

Exposure Draft ED/2009/05 - Fair Value Measurement (28 September 2009) (181 KB)

Grant Thornton International agrees with the proposed definition of fair value and with much of the supporting guidance. The comment letter outlines concerns with the application of the proposed definition and with some aspects of the detailed guidance.

Exposure Draft 2009/10 Discount Rate for Employee Benefits: Proposed Amendments to IAS 19 (24 September 2009) (46 KB)

Grant Thornton International has some concerns regarding the appropriateness of using the yield on high quality corporate bonds as the discount rate, but believes that the ED's proposals are an improvement to IAS 19. It therefore supports the Board's proposal for a fast-track amendment.

Exposure Draft ED/2009/07 - Financial Instruments: Classification and Measurement (11 September 2009) (190 KB)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/07 Financial Instruments: Classification and Measurement (the ED).

Exposure Draft ED/2009/9 Classification of Rights Issues - proposed amendment to IAS 32 (7 September 2009) (110 KB)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/9 Classification of Rights Issues - proposed amendment to IAS 32. We have considered the ED, as well as the accompanying draft Basis for Conclusions.

Discussion Paper - Credit Risk in Liability Measurement (24 August 2009) (125 KB)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Discussion Paper Credit Risk in Liability Measurement (the DP). We have considered the DP along with the accompanying Staff Paper and set out our comments. We welcome the Board's decision to seek views on the role of 'own credit risk' in measuring liabilities. As noted in the DP, this issue has generated considerable comment and controversy. It is also relevant to several of the Board's current projects.

Prepayments of a Minimum Funding Requirement - Proposed amendments to IFRIC 14 (24 July 2009) (95 KB)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board's) Exposure Draft Prepayments of a Minimum Funding Requirement - Proposed amendments to IFRIC 14. We have considered the ED, as well as the accompanying draft Basis for Conclusions. We support the Board in its proposals to amend IFRIC 14 IAS 19 - The Limit on a Defined Benefit Asset, Minimum Funding Requirements and their Interaction (IFRIC 14).

Discussion Paper: Leases - Preliminary Views (16 July 2009) (146 KB)

Grant Thornton International Ltd and its US member firm, Grant Thornton LLP, are pleased to comment on the International Accounting Standards Board's (the IASB) and the Financial Accounting Standards Board's (the FASB) joint Discussion Paper: Leases - Preliminary Views (the Discussion Paper). We summarise our main comments in the following letter. Our detailed comments and responses to the Invitation to Comment questions are included in the Appendix.

Exposure Draft ED/2009/2 Income Tax (10 July 2009) (148 KB)

Grant Thornton LLP is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft ED/2009/2 Income Tax (the ED). In summary, we do not support the introduction of an IFRS along the lines proposed in the ED. We are not convinced that the proposals, taken as a whole, represent an overall improvement on IAS 12. We also believe that the proposals will fail to achieve the goals set by the Board.

Exposure Draft ED/2009/03 Derecognition - Proposed Amendments to IAS 39 and IFRS 7 (10 July 2009) (143 KB)

Grant Thornton LLP supports the Board's decision to review the derecognition requirements of IAS 39 Financial Instruments: Recognition and Measurement (IAS 39). We share the Board's concern that these requirements are unduly complex and give rise to frequent application issues. Further, we believe that IAS 39's 'continued recognition to the extent of continuing involvement' outcome can lead to double-counting and may not generally provide useful information.

Discussion Paper: Preliminary Views on Revenue Recognition in Contracts with Customers (18 June 2009) (62 KB)

Grant Thornton LLP supports the Boards' reasons for undertaking a comprehensive review of revenue recognition principles. The case for change has been well articulated by the Boards and we welcome the development of a converged solution.

Discussion Paper: Preliminary Views on Financial Statement Presentation (9 April 2009) (222 KB)

Grant Thornton LLP supports the project and commends the Boards for developing joint proposals. In particular, we support improving the alignment of items within and across primary statements. We also support the introduction of a reconciliation schedule to provide better information on the linkage between primary statements. However, we have a number of significant concerns on some aspects of the proposals that we consider will need significant reworking in order to achieve improvements in practice.

Review of the Constitution: Identifying Issues for Part 2 of the Review (25 March 2009) (171 KB)

Grant Thornton International is pleased to comment on the IASC Foundation's Consultation Document Review of the Constitution: Identifying Issues for Part 2 of the Review (Part 2 of the Constitution Review). We welcome the opportunity to comment at this relatively early stage of Part 2 of the Constitution Review. In the following paragraphs we offer some broad themes that we believe should be considered by the IASC Foundation (the Foundation) in developing more detailed proposals. Our responses to the specific questions raised by the Trustees are set out in the Appendix to this letter.

Exposure Draft 10 Consolidated Financial Statements (18 March 2009) (169 KB)

Grant Thornton International welcomes the Board's efforts to unify IAS 27 and SIC-12 based on a clear principle. This should eliminate tension between the two models and uncertainty as to which model applies to some entities. We also support ED10's broad approach - in particular its clear focus on control as the basis for consolidation of another entity. However, we do have some significant concerns which are explained.

Exposure Draft Relationships with the State (9 March 2009) (105 KB)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft of Relationships with the State (the ED). We have considered the ED, as well as the accompanying draft Basis for Conclusions. Our responses to the questions in the ED's Invitation to Comment are set out in the attached.

Exposure Draft Post-implementation Revisions to IFRIC Interpretations (proposed amendments to IFRIC 9 and IFRIC 16) (26 February 2009) (126 KB)

Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft Post-implementation Revisions to IFRIC Interpretations (the ED). We have considered the ED, as well as the accompanying draft Basis for Conclusions. Our responses to the questions in the ED's Invitation to Comment are set in this letter.

Proposed Amendments to IFRIC 9 and IAS 39 (20 January 2009) (106 KB)

Grant Thornton International supports the Board's decision to clarify the interaction between IFRIC 9 and the recent reclassification amendments to IAS 39. We also agree that financial assets reclassified out of the fair value through profit or loss category should not escape IAS 39's requirements on embedded derivatives.

Exposure Draft Additional Exemptions for First-time Adopters - Proposed Amendments to IFRS 1 (16 January 2009) (107 KB)

Grant Thornton International supports the proposals of the International Accounting Standards Board's Exposure Draft Additional Exemptions for First-time Adopters - Proposed Amendments to IFRS 1 (the ED).

Proposed Amendments to IFRS 5 (16 January 2009) (109 KB)

Grant Thornton International is generally supportive of the specific proposals. However, we believe that the proposed definition of a discontinued operation may need to be refined to be more consistent with its underlying rationale. We also have a concern that the proposed disclosures relating to disposals of other components may capture too many transactions.

Exposure Draft Investments in Debt Instruments - Proposed Amendments to IFRS 7 (14 January 2009) (99 KB)

Grant Thornton International has considered the Exposure Draft along with the accompanying draft Basis for Conclusions. In summary, we believe there is a good case for requiring disclosures that enable users to better understand the nature of impairment losses recognised on available for sale debt assets. We are not convinced that this is an urgent matter. However, should the Board decide that fast track amendments are necessary we would prefer a more limited disclosure requirement that focuses more narrowly on this specific matter.