Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
3 July 2015Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2015/2 Effective Date of IFRS 15The Hong Kong Institute of Certified Public Accountants is the only body authorised bylaw to set and promulgate standards relating to financial reporting, auditing, and ethicsfor professional accountants, in Hong Kong. We are grateful for the opportunity toprovide you with our comments on this Exposure Draft (ED).We are supportive of the proposal to defer the effective date of IFRS 15 Revenue fromContracts with Customers to 1 January 2018. Our support is consistent with our letterdated 16 March 2015 to the IASB in relation to the effective date of IFRS 15. A copy ofthe letter is attached as Annex 1 to this submission.We agree with the factors set out in paragraph BC6 of the ED as the basis for deferringthe effective date of IFRS 15. In particular, we consider that a one-year deferral wouldhelp improve the quality of implementation of IFRS 15 in light of the IASB's forthcomingexposure draft which include clarifying the guidance on licences and adding examplesillustrating the guidance on identifying performance obligations, which are issues thatwere repeatedly raised at the IASB and FASB's joint Transition Resource Group forRevenue Recognition (TRG).We note that, in May 2015, the FASB proposed clarifications and new guidance to itsnew revenue standard in relation to licenses of intellectual property and identifyingperformance obligations to address implementation issues in the US that were raisedat the TRG. We also note that the IASB intends to propose some, but not all, of theamendments that the FASB has. We are aware that the IASB's and FASB's revenuestandards are virtually the same even though they are not written in the same way.However, we are concerned that the use of non-converged language or dissimilaramendments put through to the IASB and FASB revenue standards would lead todivergence in application between IFRS and US GAAP users. Accordingly, werecommend that the IASB exposes similar proposals as the FASB has, as long asthose proposals would improve the implementation and application of IFRS 15, and areconsistent with the principles of IFRS 15. It would be helpful if the IASB's forthcomingexposure draft also includes an analysis of whether the FASB's proposals (written in itsown form) would lead to differences in accounting under IFRS 15.We have not formed our views on the FASB's proposed amendments that were issuedin May 2015. We will be commenting on the IASB's forthcoming exposure draft inrelation to IFRS 15 with consideration on the FASB's proposed amendments.If you have any questions regarding the matters raised in this letter, please contact meor Winnie Chan, our Associate Director of Standard Setting atwinniechan@hkicpa.org.hk.Yours sincerely,Christina NgHead of Financial ReportingCN/WCEnclAnnex 1
Institute comments on IASB Exposure Draft ED/2015/2 Effective Date of IFRS 15
下载原件Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
3 July 2015Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2015/2 Effective Date of IFRS 15The Hong Kong Institute of Certified Public Accountants is the only body authorised bylaw to set and promulgate standards relating to financial reporting, auditing, and ethicsfor professional accountants, in Hong Kong. We are grateful for the opportunity toprovide you with our comments on this Exposure Draft (ED).We are supportive of the proposal to defer the effective date of IFRS 15 Revenue fromContracts with Customers to 1 January 2018. Our support is consistent with our letterdated 16 March 2015 to the IASB in relation to the effective date of IFRS 15. A copy ofthe letter is attached as Annex 1 to this submission.We agree with the factors set out in paragraph BC6 of the ED as the basis for deferringthe effective date of IFRS 15. In particular, we consider that a one-year deferral wouldhelp improve the quality of implementation of IFRS 15 in light of the IASB's forthcomingexposure draft which include clarifying the guidance on licences and adding examplesillustrating the guidance on identifying performance obligations, which are issues thatwere repeatedly raised at the IASB and FASB's joint Transition Resource Group forRevenue Recognition (TRG).We note that, in May 2015, the FASB proposed clarifications and new guidance to itsnew revenue standard in relation to licenses of intellectual property and identifyingperformance obligations to address implementation issues in the US that were raisedat the TRG. We also note that the IASB intends to propose some, but not all, of theamendments that the FASB has. We are aware that the IASB's and FASB's revenuestandards are virtually the same even though they are not written in the same way.However, we are concerned that the use of non-converged language or dissimilaramendments put through to the IASB and FASB revenue standards would lead todivergence in application between IFRS and US GAAP users. Accordingly, werecommend that the IASB exposes similar proposals as the FASB has, as long asthose proposals would improve the implementation and application of IFRS 15, and areconsistent with the principles of IFRS 15. It would be helpful if the IASB's forthcomingexposure draft also includes an analysis of whether the FASB's proposals (written in itsown form) would lead to differences in accounting under IFRS 15.We have not formed our views on the FASB's proposed amendments that were issuedin May 2015. We will be commenting on the IASB's forthcoming exposure draft inrelation to IFRS 15 with consideration on the FASB's proposed amendments.If you have any questions regarding the matters raised in this letter, please contact meor Winnie Chan, our Associate Director of Standard Setting atwinniechan@hkicpa.org.hk.Yours sincerely,Christina NgHead of Financial ReportingCN/WCEnclAnnex 1