This comment letter, which reflects the views of the international BDO network of independent member firms, was sent by BDO IFR Advisory Limited to the IFRS Interpretations Committee on 14 October 2011.
A copy of the IFRIC Update - September 2011 is attached at the foot of this page.
Mr Wayne Upton
Chairman
IFRS Interpretations Committee
30 Cannon Street
London
EC4M 6XH |
14 October 2011
Dear Mr Upton
Tentative agenda decision: IAS 12 Income Tax – corporate wrapper
We are pleased to respond to the IFRS Interpretations Committee’s (the Committee) publication of the above tentative agenda decision.
We note that the Committee has tentatively concluded, in the second paragraph of its tentative agenda decision, that the requirements of IAS 12 in relation to assets held in corporate wrappers are clear. This conclusion might be viewed as being inconsistent with the text of the final paragraph, which notes that there are wider concerns relating to the issue that need to be resolved by the IASB through broader consideration of the principles involved.
We agree that there are wider concerns, and believe that these do not fall within the remit of the Committee to resolve. Consequently, the Committee’s tentative agenda decision might be amended such that the analysis of IAS 12 is described as being one that might reflect a valid interpretation of the requirements of that standard, but also notes the broader concerns and indicates that the issue will be referred to the IASB for consideration in the context of an amendment to IAS 12.
We hope that you will find our comments and observations helpful. If you would like to discuss any of them, please contact Andrew Buchanan at +44 (0)20 7893 3300.
Yours sincerely
BDO IFR Advisory Limited