Whether the requirements for a contractor to disclose the aggregate of progress billings and advances received and receivable in respect of construction contracts should be maintained.

The G100 does not consider this disclosure to be so fundamental to Australian practice to warrant its retention. The G100 believes that the retention of an existing disclosure requirement or the inclusion of disclosures additional to those in IASB Standards must be strongly justified.
 

The G100 believes that there is no compelling reason not to adopt IAS 11. While AASB 1009 provides more detailed guidance than IAS 11 in some instances the G100 believes that the guidance in IAS 11 is adequate.

However, we note that IFRIC is presently addressing issues relating to segmenting and aggregating/combining contracts and that this guidance will enhance that in IAS 11.

Any regulatory issues or other issues arising in the Australian environment that may affect the implementation of the proposals, particularly any issues relating to:

i) not-for-profit entities;
ii) public sector entities

No comment.
 

Whether the proposals are in the best interests of the Australian economy.

Refer covering letter.
 

The G100 is not aware of any impediments to the implementation of IAS 14 in Australia as the basis of the approach and the disclosures required are consistent with AASB 1005 ‘Segment Reporting’.
  

No comment.
 

No comment.
 

Whether the proposal to not require not-for-profit entities that measure assets at fair value to disclose the carrying amount of the asset had it been measured at cost is appropriate and workable.

No comment.
 

Whether the proposal to eliminate one option in relation to the treatment of accumulated depreciation at revaluation date is appropriate and workable.

The G100 believes that IAS 16 should be adopted as it stands and, as such, the option should not be eliminated.
 

Whether the AASB 1040 ‘Statement of Financial Position’ requirement to disclose the current valuations of land and buildings should be included in the Australian equivalent of IAS 16.

No. The G100 believes that there must be compelling reasons for retaining existing disclosure requirements not in the equivalent IASB Standards or for including disclosures additional to those in IASB Standards. Before deciding whether to retain this requirement the Board should undertake a cost benefit analysis to determine whether the disclosure is justified. We do not believe that this disclosure can be justified.
 

Whether any of the other features of Australian equivalent requirements identified as different from IAS 16 in the comparison in this Preface should be included in the proposed Australian equivalent of IAS 16 and if so, which features.

No. In the context of adoption of IASB Standards we do not see any compelling reason to depart from the requirements of IAS 16.
 

i) not-for-profit entities
ii) public sector entities

No comment.
 

Refer covering letter.
 

The proposed numbering approach to Australian Standards appears reasonable and workable. However, while retaining the proposed numbering system for the Australian equivalents of International Financial Reporting Standards (IFRSs), which are those developed by the IASB, these Standards could be described as Australian Financial Reporting Standards. A consequence of this approach would be that the Australian equivalents of IASs, those Standards issued by the IASC, could take the same number as its IASB equivalent.

While acknowledging the Board’s desire to issue sector-neutral standards the G100 has concerns about how this impacts on the format and presentation of standards, particularly where there is a significant volume of not-for-profit material included in a standard. From the point of view of preparers subject to the Corporations Act the inclusion of not-for-profit material is potentially distracting and our preference would be for this material to be located elsewhere.