COMMENT LETTER

Deloitte Touche Tohmatsu 180 Strand London WC2R 1BL United Kingdom Tel: +44 (0) 20 7936 3000 Fax: +44 (0) 20 7583 1198 www.deloitte.com Direct: +44 20 7007 0907 Direct Fax: +44 20 7007 0158 kwild@deloitte.co.uk Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH 29 February 2008 Dear Sir David, Proposed amendments to IFRS 1 First-time Adoption of International Financial Reporting Standards and IAS 27 Consolidated and Separate Financial Statements: Cost of an Investment in a Subsidiary, Jointly Controlled Entity or Associate Deloitte Touche Tohmatsu is pleased to comment on the Exposure Draft of proposed Amendments to IFRS 1 First-time Adoption of International Financial Reporting Standards and IAS 27 Consolidated and Separate Financial Statements: Cost of an Investment in a Subsidiary, Jointly Controlled Entity or Associate (herein referred to as the ‘exposure draft’). We agree with, and support, the majority of the proposals outlined in the exposure draft. However, we have a number of concerns with some of the proposals within the exposure draft which are outlined in our detailed responses to the specific questions for comment in Appendix A. In addition, we have included further comments and concerns on other aspects of the exposure draft in Appendix B to this letter. We agree with the proposals relating to the use of deemed cost ...