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The ED proposed the following amendments:
In its comment letter, EFRAG broadly agrees with most of the proposals in the ED, but is concerned that amending IAS 12 without providing guidance on how to determine whether the payments are distributions of profits may not lead to a significant improvement in consistent application compared to the current situation.
In relation to the proposed amendments to IAS 28, EFRAG supports the IASB's decision to address the issue before IFRS 9 becomes effective. EFRAG also considers the proposed amendments to be a practical solution, in that they codify an acceptable interpretation of existing guidance and do not involve extensive changes to that guidance. However, EFRAG also considers that the IASB should provide guidance on the application of the proposed amendments. Moreover, EFRAG considers that this should be regarded only as a temporary solution and that the treatment of long-term interests should be considered more broadly in the IASB's equity method research project.
Lastly, whilst EFRAG understands the benefits from aligning the effective date of the amendments to IAS 28 with the effective date of IFRS 9, EFRAG is concerned about the short time period between the expected date of issuing the amendments and the proposed effective date of 1 January 2018. EFRAG considers that this will create difficulties for all jurisdictions with a translation or endorsement process, including the EU. Therefore, EFRAG considers that the IASB should propose an effective date of 1 January 2019, with earlier application permitted and provide transition provisions for entities that will not be able to apply the amendments at the same time as they apply IFRS 9.