14 January 2009

International Accounting Standards Board
30 Cannon Street
London EC 4M 6XH
UNITED KINGDOM
commentletters@iasb.org.uk

Dear Sir/Madam

“Discontinued Operations”

The Group of 100 (G100) is an organization of chief financial officers from Australia’s largest business enterprises with a purpose of advancing Australia’s financial competitiveness. The G100 is pleased to provide comments on the Exposure Draft.

Q1a Do you agree with the proposed definition? Why or why not? If not, what definition would you propose, and why?

Yes. The G100 agrees that for an operation to qualify as discontinued it should comprise a significant part of the entity and constitute a strategic shift in its operations. Operations that qualify as an operating segment would normally be regarded as a significant part of an entity.
 

Q1b If an entity is not required to apply IFRS 8, is it feasible for the entity to determine whether the component of an entity meets the definition of an operating segment? Why or why not? If not, what definition would you propose for an entity that is not required to apply IFRS 8, and why?

Yes. Entities that are applying IAS 36 ‘Impairment of Assets’ will be familiar with the notion of an operating segment.
 

Q2

Do you agree that the amounts presented for discontinued operations should be based on the amounts presented in the statement of comprehensive income? Why or why not? If not, what amounts should be presented and why?

Yes. The G100 considers that the amounts disclosed should be prepared on the same basis as the information on the face of the financial statements.
 

Q3a Do you agree with the proposed disclosure requirements? Why or why not? If not, what changes would you propose, and why?

The G100 is concerned that additional disclosures are mandated with each new Standard or as part of the amendments to a Standard without determining whether such disclosures meet disclosure principles. While the disclosures individually, may seem reasonable and meet a user need, the Basis for Conclusions does not address the proposed additional disclosures in the context of the overall disclosure load for entities. For example, there are several requirements in IFRSs to provide reconciliations of amounts/effects of changes and the proposed reconciliation is not justified.
 

Q3b Do you agree with the disclosure exemptions for businesses that meet the criteria to be classified as held for sale on acquisition? Why or why not? If not, what changes would you propose, and why?

Yes.
 

Q4 Are the transitional provisions appropriate? Why or why not? If not, what would you propose and why?

The G100 supports the transitional provisions which are a pragmatic approach to implementing the changed requirements.

 

Yours sincerely

Tony Reeves
National President

 

 

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