KPMG International Comment letter on ED - Improvements to IFRSs

KPMG IFRG Limited Tel +44 (0)20 7694 8871 1-2 Dorset Rise Fax +44 (0)20 7694 8429 London EC4Y 8EN mary.tokar@kpmgifrg.com United Kingdom Mr Michael Kraehnke International Accounting Standards Board st1 Floor 30 Cannon Street Our ref MT/288 London Contact Mary Tokar EC4M 6XH 25 November 2009 Dear Mr Kraehnke Exposure Draft of Proposed Improvements to IFRSs We appreciate the opportunity to comment on the International Accounting Standards Board’s (IASB or the Board) Exposure Draft of Proposed Improvements to IFRSs (the ED) published in August 2009. This letter expresses the views of the international network of KPMG member firms. Appendix 1 to this letter contains our detailed responses to the proposals about which we have fundamental concerns, which are: • IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors – Change in terminology to the qualitative characteristics • IAS 27 Consolidated Financial Statements – Impairment of investments in subsidiaries, jointly controlled entities and associates in the separate financial statements of the investor • IAS 34 Interim Financial Reporting – Significant events and transactions • IAS 40 Investment Property – Change from fair value model to cost model We are particularly concerned with the proposed amendment to IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors, which is a consequential amendment resulting from the conceptual framework project. We believe that ...