20 July 2005

Dear Sir

IFRIC Draft Interpretation
D16 'Scope of IFRS 2'

The Group of 100 (G100) is an organisation representing the interests of Chief Financial Officers of Australia’s largest business enterprises and is pleased to provide comment on the proposals in D16.

The G100 supports the proposals. However, we are surprised that an issue of this nature is being addressed by the IFRIC at a time when significant issues arising in the transition to IFRSs are not being addressed.

The G100 suggests that the illustrative example should outline the entries relating to the granting of shares and the asset/expense that is enjoyed by the entity as a result of granting the shares. We consider that this is necessary to demonstrate unequivocally that the entity has, or will, receive services in consideration and in compliance with paragraphs 8 and 9. The G100 encourages the inclusion of illustrative examples in interpretations because they provide preparers with valuable implementation guidance.

Yours sincerely

Tom Honan
National President

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