This Comment Letter was sent by BDO Global Coordination B.V. on behalf of BDO International, to EFRAG Supervisory Board on 6 October, 2005:
Dear Sirs,
Achieving Consistent Application of IFRS in the EU: a Discussion Paper
We thank you for the opportunity to comment on the proposed ‘mechanisms’ for achieving consistent application of IFRS in the EU.
We agree with your paragraphs 4.6 through 4.9. We do not support the proposals that Europe could issue interpretative or implementation guidance. We do not agree with your paragraph 4.10. We would much prefer that if urgent issues exist, then they should be addressed by IFRIC urgently. Rather than creating a separate body to analyse issues and propose solutions for IFRIC, why not provide the resources to IFRIC itself so that it can address it’s workload on a timely basis?
We do not agree with your paragraph 4.11. Certainly, if a support mechanism were created, it would be essential that it operated in a transparent way. We believe this would require the suggested solution sent to IFRIC to be published in addition to the issues and meeting minutes. To do otherwise would disadvantage those preparers, audit firms, and other constituents not represented in the process.
We hope the above comments are of assistance. If you wish to discuss any of the points raised in our submission please contact Helen Thomson on +32-2-779-0130.
Yours faithfully,
BDO Global Coordination B.V.
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EFRAG Paper, Issued 27 July 2005: