3 April 2006

Mr Robert Garnett
Chairman IFRIC
International Accounting Standards Board
30 Cannot Street
London EC4M 6XH
UNITED KINGDOM

Dear Mr Garnett

D18 Interim Financial Reporting and Impairment

The Group of 100 (G100) is pleased to comment on the IFRIC Draft Interpretation. The G100 represents the interests of the CFOs of Australia’s major business enterprises.

The G100 does not support the proposed approach in IFRIC D18 and believes that the general principle underlying interim financial reporting that frequency of reporting within an annual period should not affect the measurement of results for the annual reporting period. As such the G100 considers that estimation made in respect of an interim reporting period should be able to be confirmed or corrected when preparing the annual financial statements.

Yours sincerely
 

Tom Honan
National President