25 October 2005

Mr David Boymal
Chairman
AASB
PO Box 204
COLLINS STREET WEST VIC 8007

Dear David

Amendments to IFRS 3 - Business Combinations

The Group of 100 (G100) submission to the IASB is attached.

The G100 is concerned that these proposals represent a significant departure from the Framework itself in respect of the replacement of the probability approach to recognition of liabilities. We strongly believe that changing the concepts should be first resolved before those changes are reflected in proposed amendments to IFRSs.

However, if the IASB persists with this approach in making changes to IAS 37, these amendments should be adopted by the AASB for application in Australia. We believe failure to adopt changes made by the IASB puts at risk the benefits flowing from implementing the FRC’s strategic directive and would not be in the best interests of the Australian economy.

Yours sincerely

Tom Honan
National President

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