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IAS 12
Deloitte agrees with the IFRS Interpretations Committee's decision not to add this item onto its agenda for the reasons set out in the tentative agenda decision. However, Deloitte recommends that the tentative agenda decision be expanded to state that the determination of whether interest and penalties are, in fact, in the scope of IAS 12 should be made based on the specific facts and circumstances in which they are incurred.
IAS 19
Deloitte agrees with the IFRS Interpretations Committee's decision not to add this item onto its agenda for the reasons set out in the tentative agenda decision, however Deloitte suggests several amendments in the attached letter that we think could help make the tentative agenda decision clearer.
IAS 32
Deloitte agrees with the IFRS Interpretations Committee's decision not to add this item onto its agenda for the reasons set out in the tentative agenda decision.
IAS 33
Deloitte agrees with the IFRS Interpretations Committee's decision not to add this item onto its agenda for the reasons set out in the tentative agenda decision.
IAS 41
Deloitte agrees with the IFRS Interpretations Committee's decision not to add this item onto its agenda for the reasons set out in the tentative agenda decision. However, Deloitte notes that there exist a number of conceptual issues arising from the requirement of IAS 41 to split a single living organism into two units of account. Deloitte recognises that addressing such issues is outside the scope of the Interpretation Committee’s activities, but in the absence of clarity the valuation of growing produce on bearer plants will continue to be problematic and diversity in practice will continue. As such, Deloitte recommends that the Board consider these issues, as part of the Post-implementation Review of IFRS 13.
IFRS 1
Deloitte agrees with the IFRS Interpretations Committee's decision not to add this item onto its agenda for the reasons set out in the tentative agenda decision. However, Deloitte recommends that the Board consider whether a narrow scope amendment to that standard extending the exemption in paragraph D16 to the calculation of cumulative translation differences at a subsidiary’s date of transition to IFRSs would be appropriate.
IFRS 9
Deloitte recommends that this issue would be better addressed via a formal Interpretation rather than an agenda decision as this would allow for suitable transition provisions to be applied to adjustments arising from modifications that may have occurred some years ago.