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Deloitte agrees with the proposed amendments, but suggests some enhancements to the wording to better clarify the proposals.

Deloitte has published its comment letter on the IASB´s ED/2014/3 'Recognition of Deferred Tax Assets for Unrealised Losses'.

The IASB's proposed amendments aim at clarifying the following aspects:

Unrealised losses on debt instruments measured at fair value and measured at cost for tax purposes give rise to a deductible temporary difference regardless of whether the debt instrument's holder expects to recover the carrying amount of the debt instrument by sale or by use
The carrying amount of an asset does not limit the estimation of probable future taxable profits
Estimates for future taxable profits exclude tax deductions resulting from the reversal of deductible temporary differences
An entity assesses a deferred tax asset in combination with other deferred tax assets. Where tax law restricts the utilisation of tax losses, an entity would assess a deferred tax asset in combination with other deferred tax assets of the same type

In general, Deloitte agrees with the proposed amendments; however, it suggests some enhancements to the wording to better clarify the proposals.