24 July 2006
International Accounting Standards Board
30 Cannon Street
LONDON EC4M 6XH
UNITED KINGDOM
commentletters@iasb.org
Dear Sir/Madam
Proposed Amendments to IAS 23 Borrowing Costs
The Group of 100 which represents the interests of CFOs of major business enterprises in Australia is pleased to provide comment on ED 149.
| 1. | The Exposure Draft proposes to eliminate the option in IAS 23 of
recognising immediately as an expense borrowing costs directly
attributable to the acquisition, construction or production of a
qualifying asset. Do you agree with the proposal? If not, why? What
alternative would you propose and why? Yes. The G100 supports the capitalisation of borrowing costs as part of the cost of a qualifying asset. No. |
| 2. |
The Exposure Draft proposes that entities should apply the amendments to borrowing costs for which the commencement date for capitalisation is on or after the effective date. However, an entity would be permitted to designate any date before the effective date and to apply the proposed amendments to borrowing costs relating to all qualifying assets for which the commencement date for capitalisation is on or after that date. Do you agree with the proposal? If not, why? What alternative would you propose and why? Yes. While the G100 supports proposals to permit an entity to select an earlier date to adopt the amended requirements. However, where an entity avails itself of application of the requirements from an earlier date than the effective date this will mean that items that have previously been expensed will be reinstated and included in the carrying amount of the qualifying asset. We believe that the Basis for Conclusions should discuss the acceptable treatment of these reinstatements under IAS 8 ‘Accounting Policies, Changes in Estimates and Errors’. |
Yours sincerely
Tom Honan
National President