Page 1 of 3Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
2 December 2015Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2015/4 Updating References to the Conceptual FrameworkThe Hong Kong Institute of Certified Public Accountants is the only body authorised bylaw to set and promulgate standards relating to financial reporting, auditing, and ethics forprofessional accountants, in Hong Kong. We are grateful for the opportunity to provideyou with our comments on ED/2015/4.We are concerned about the possible unintended consequences of the proposedamendments, given that some of the proposals in the ED/2015/3 Conceptual Frameworkfor Financial Reporting are in conflict with the existing IFRSs. Therefore, we suggestcross-reference should be made to paragraph 11 of IAS 8 Accounting Policies, Changesin Accounting Estimates and Errors instead of the revised Conceptual Framework. Wealso believe the proposed amendments in ED/2015/4 are editorial in nature only andaccordingly would not require an effective date.Our responses to the questions raised in ED/2015/4 are set out in more detail in theAppendix.If you have any questions regarding the matters raised in this letter, please contact me orBen Lo, Associate Director in the Standard Setting Department, at ben@hkicpa.org.hk.Yours sincerely,Christina NgHead of Financial Reporting, Standard Setting DepartmentCN/BLEncl.Page 2 of 3Detailed comments on IASB ED/2015/4 Updating References to the ConceptualFrameworkQuestion 1 – Replacing references to the Conceptual FrameworkThe IASB proposes to amend IFRS 2, IFRS 3, IFRS 4, IFRS 6, IAS 1, IAS 8, IAS 34,SIC-27 and SIC-32 so that they will refer to the revised Conceptual Frameworkonce it becomes effective.Do you agree with the proposed amendments? Why or why not?We are concerned about the possible unintended consequences of the proposedamendments (in particular, for the proposed amendments to IFRS 3 BusinessCombinations and IFRS 6 Exploration for and Evaluation of Mineral Resources) andthe introduction of potential diversity in practice given that some of the proposals inED/2015/3 Conceptual Framework for Financial Reporting are in conflict with theexisting IFRSs (especially regarding the definition of a liability).Following current IFRS hierarchy, we consider that if preparers need to use judgmentin identifying or applying accounting policies, they should first make reference to therequirements in existing standards that deal with similar and related issues beforereferring to the definitions, recognition criteria and measurement concepts in therevised Conceptual Framework. Accordingly, we consider that the standards referredto above should only refer to the revised Conceptual Framework in a mannerconsistent with paragraph 11 of IAS 8 Accounting Policies, Changes in AccountingEstimates and Errors and should not include direct references only to the revisedConceptual Framework.We also suggest that the IASB deletes the sentence 'The Conceptual Framework doesnot allow the recognition of items in the balance sheet which do not meet the definitionof assets or liabilities' in the proposed amendments to IAS 34 Interim FinancialReporting. We consider reference should be made to IAS 8 (as mentioned above)
instead of the revised Conceptual Framework.Question 2 – Effective date and transitionThe IASB proposes that:
(a) a transition period of approximately 18 months should be set for theproposed amendments. Early application should be permitted.(b) the amendments should be applied retrospectively in accordance with IAS 8,except for the amendments to IFRS 3. Entities should apply theamendments to IFRS 3 prospectively, thereby avoiding the need to restateprevious business combinations.Do you agree with the proposed transition provisions and effective date? Why orwhy not?As mentioned in our comments on Question 1 above, we consider that any referenceto the revised Conceptual Framework should be only by way of a reference toparagraph 11 of IAS 8 instead of directly. That is, when applying the existing IFRS thatAppendixPage 3 of 3deals with the same or similar items, they should proceed to use the IAS 8 hierarchyand not directly refer to the revised Conceptual Framework.We would consider this to be a housekeeping exercise, which does not affect theadoption of the existing standards. Accordingly, we do not think it is necessary to setan effective date in those standards for such an exercise.If in fact the IASB intends this to be significantly more than a housekeeping exercise,and intends that entities may make changes of accounting policies simply on the basisof the revised Conceptual Framework being issued, then we consider this exposuredraft is premature as the IASB has not yet carried out an assessment of the extent towhich the revised Conceptual Framework is intended to directly introduce changes intocurrent IFRS, ahead of new or amended standards being based on the revisedConceptual Framework.Question 3 – Other commentsDo you have any other comments on the proposals?We have no other comments on the proposals.~ End ~
ED/2015/3 Conceptual Framework for Financial Reporting — ED/2015/4 Updating References to the Conceptual Framework
下载原件Page 1 of 3Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
2 December 2015Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2015/4 Updating References to the Conceptual FrameworkThe Hong Kong Institute of Certified Public Accountants is the only body authorised bylaw to set and promulgate standards relating to financial reporting, auditing, and ethics forprofessional accountants, in Hong Kong. We are grateful for the opportunity to provideyou with our comments on ED/2015/4.We are concerned about the possible unintended consequences of the proposedamendments, given that some of the proposals in the ED/2015/3 Conceptual Frameworkfor Financial Reporting are in conflict with the existing IFRSs. Therefore, we suggestcross-reference should be made to paragraph 11 of IAS 8 Accounting Policies, Changesin Accounting Estimates and Errors instead of the revised Conceptual Framework. Wealso believe the proposed amendments in ED/2015/4 are editorial in nature only andaccordingly would not require an effective date.Our responses to the questions raised in ED/2015/4 are set out in more detail in theAppendix.If you have any questions regarding the matters raised in this letter, please contact me orBen Lo, Associate Director in the Standard Setting Department, at ben@hkicpa.org.hk.Yours sincerely,Christina NgHead of Financial Reporting, Standard Setting DepartmentCN/BLEncl.Page 2 of 3Detailed comments on IASB ED/2015/4 Updating References to the ConceptualFrameworkQuestion 1 – Replacing references to the Conceptual FrameworkThe IASB proposes to amend IFRS 2, IFRS 3, IFRS 4, IFRS 6, IAS 1, IAS 8, IAS 34,SIC-27 and SIC-32 so that they will refer to the revised Conceptual Frameworkonce it becomes effective.Do you agree with the proposed amendments? Why or why not?We are concerned about the possible unintended consequences of the proposedamendments (in particular, for the proposed amendments to IFRS 3 BusinessCombinations and IFRS 6 Exploration for and Evaluation of Mineral Resources) andthe introduction of potential diversity in practice given that some of the proposals inED/2015/3 Conceptual Framework for Financial Reporting are in conflict with theexisting IFRSs (especially regarding the definition of a liability).Following current IFRS hierarchy, we consider that if preparers need to use judgmentin identifying or applying accounting policies, they should first make reference to therequirements in existing standards that deal with similar and related issues beforereferring to the definitions, recognition criteria and measurement concepts in therevised Conceptual Framework. Accordingly, we consider that the standards referredto above should only refer to the revised Conceptual Framework in a mannerconsistent with paragraph 11 of IAS 8 Accounting Policies, Changes in AccountingEstimates and Errors and should not include direct references only to the revisedConceptual Framework.We also suggest that the IASB deletes the sentence 'The Conceptual Framework doesnot allow the recognition of items in the balance sheet which do not meet the definitionof assets or liabilities' in the proposed amendments to IAS 34 Interim FinancialReporting. We consider reference should be made to IAS 8 (as mentioned above)
instead of the revised Conceptual Framework.Question 2 – Effective date and transitionThe IASB proposes that:
(a) a transition period of approximately 18 months should be set for theproposed amendments. Early application should be permitted.(b) the amendments should be applied retrospectively in accordance with IAS 8,except for the amendments to IFRS 3. Entities should apply theamendments to IFRS 3 prospectively, thereby avoiding the need to restateprevious business combinations.Do you agree with the proposed transition provisions and effective date? Why orwhy not?As mentioned in our comments on Question 1 above, we consider that any referenceto the revised Conceptual Framework should be only by way of a reference toparagraph 11 of IAS 8 instead of directly. That is, when applying the existing IFRS thatAppendixPage 3 of 3deals with the same or similar items, they should proceed to use the IAS 8 hierarchyand not directly refer to the revised Conceptual Framework.We would consider this to be a housekeeping exercise, which does not affect theadoption of the existing standards. Accordingly, we do not think it is necessary to setan effective date in those standards for such an exercise.If in fact the IASB intends this to be significantly more than a housekeeping exercise,and intends that entities may make changes of accounting policies simply on the basisof the revised Conceptual Framework being issued, then we consider this exposuredraft is premature as the IASB has not yet carried out an assessment of the extent towhich the revised Conceptual Framework is intended to directly introduce changes intocurrent IFRS, ahead of new or amended standards being based on the revisedConceptual Framework.Question 3 – Other commentsDo you have any other comments on the proposals?We have no other comments on the proposals.~ End ~