6 September 2010
Sir David Tweedie
International Accounting Standards Board
30 Cannon Street
London EC 4M 6XH
Dear Sir David
ED/2010/5 Presentation of items of other comprehensive income
The Group of 100 (G100) is an organization of chief financial officers from Australia's largest business enterprises with the purpose of advancing Australia's financial competitiveness. The G100 is pleased to provide comments on this Exposure Draft.
The G100 does not support the proposal to mandate a single report and remove the current flexibility which enables an entity to separately present a report on its performance and a report containing items of other comprehensive income (OCI). We do support the proposal to classify items of OCI.
The Board proposes to change the title of the statement of
comprehensive income to 'Statement of profit or loss and other
comprehensive income' when referred to in IFRSs and its other
publications. Do you agree? Why or why not? What alternative do you
The G100 does not object to the proposed change of title
where an entity chooses to present a single statement. The G100 does not
believe there is a need to change from the existing permissive approach
in IAS 1 'Presentation of Financial Statements' under which the entity
can choose to provide a single statement or separate statements.
The proposals would require entities to present a statement of profit or loss
and other comprehensive income with two sections ' profit or loss and items of
other comprehensive income. The Board believes this will provide more
consistency in presentation and make financial statements more comparable. Do
you agree? Why or why not? What alternative do you propose?
While the G100
supports the concept of a single statement of comprehensive income (however
described) we favour retaining the existing approach in IAS 1. We are not
convinced that the combined statement will facilitate comparability as the
information is already provided to users and the presentation changes are
The ED proposes to require entities to present items of other comprehensive
income (OCI) that will be reclassified to profit or loss. Do you support this
approach? Why or why not? What alternative do you propose and why?
The G100 believes that classifying and presenting items of OCI in this way will
be useful to users of the financial statements.
The ED also proposes to require that income tax on items presented in OCI
should be allocated between items that might be subsequently reclassified to
profit or loss and those that will not be reclassified subsequently to profit or
loss, if the items in OCI are presented before tax. Do you support this
proposal? Why or why not? What alternative do you propose and why?
G100 supports the proposal which results in the tax being classified in the same
section as the related OCI item.
In the Board's assessment:
Do you agree with the Board's assessment? Why or why not?
The G100 agrees that as the proposed changes are essentially cosmetic the
costs of compliance are likely to be minimal. The G100 does not accept the basis
of the Board's assessment and justification for the proposed mandating of a
single statement particularly given that the information is adequately presented
under current requirements. The G100 believes that the separate classification
of OCI items (whether in a single statement or in a separate statement) will
help clarify the nature of items for users.
Do you have any other comments on the proposals?
Group of 100 Inc