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Such types of transfers (which ESBG understands may include sale contracts, financial assets originated such as loans and other types of transfers encompassing levies and other fees) require an adequate accounting treatment under IFRS.
However, ESBG considers that the main objective of the DP should have been to focus on those transfers whose accounting treatment will not be covered by the revised Conceptual Framework. In this context, ESBG believes that before developing any future proposal based on this DP, it is necessary to assess what will be the expected effects of the revised Conceptual Framework in relation to any applicable IFRS Standards (e.g. the effects on the current requirements underlying IFRIC 21 Levies and IAS 20 Government Grants), rather than developing a specific regulation for those transfers denominated NETs, which in many of the cases described, have already been regulated by different IFRS standards.
ESBG notes that this assessment has partly been made by way of the examples being provided, but in some of them the conclusion reached under the DP is different from the outcome that the revised Conceptual Framework will provide for. Such types of conclusions may question whether EFRAG disagrees with the fundamentals of the revised Conceptual Framework.
Accordingly, the objective of the DP should be to focus on dealing with those transactions that may not be covered by the revised Conceptual Framework, and any applicable IFRS Standard could consider the necessary changes in order to be aligned with the framework.