Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
8 August 2017Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2017/2Improvements to IFRS 8 Operating SegmentsThe Hong Kong Institute of Certified Public Accountants is the only body authorised by lawto set and promulgate standards relating to financial reporting, auditing, and ethics forprofessional accountants, in Hong Kong.First of all, HKICPA appreciates your consideration of our feedback on the 2012 Request forInformation Post-implementation Review: IFRS 8 Operating Segments. ED/2017/2addressed most of our feedback.HKICPA supports most of the proposals in ED/2017/2. In particular:
The identification of segments, is based on how an entity's operations are reported tothe 'chief operating decision maker' (CODM) as a function, and not necessarily amanager with a specific title. HKICPA therefore supports the proposals in paragraphs 7,7A, 7B and 22(c). HKICPA also supports including paragraph BC25 in the finalamendments to explain the usefulness of disclosing the title and role of CODM. Inaddition, HKICPA and our stakeholders are aware that some or all of the informationproposed to be required under paragraphs 7, 7A, 7B and 22(c) may already bedisclosed in other parts of the annual report. Therefore, we recommend that the IASBconsiders allowing those information to be cross-referenced in the financial reports toavoid duplication.HKICPA also supports the proposed paragraph 45A in IAS 34 Interim FinancialReporting — we do not think this is a new requirement as this is consistent with the'retrospective application' requirement in IAS 8 Accounting Polices, Changes inAccounting Estimates and Errors and paragraph 29 of IFRS 8. HKICPA thereforerecommends the IASB to include in the basis for conclusions that the proposedamendment in IAS 34 is not a new requirement. HKICPA would also like to inform theIASB that one of our stakeholders commented that the restatement may not reflect howthey manage their business in prior periods and therefore this stakeholder does notsupport the 'retrospective application'.Consistent with the statement in proposed paragraph 19A, HKICPA and ourstakeholders consider that an entity is expected to identify the same reportablesegments in its financial reports as in other parts of its annual reporting package. Thisfollows the 'management approach' reporting underlying IFRS 8. Therefore, wedisagree with the proposed disclosure in paragraph 22(d). We consider the way inwhich proposed paragraph 22(d) is drafted implies that the segment disclosure infinancial reports can deviate from other parts of an entity's annual reporting package.If there is a difference between the financial report and the annual reporting package itmay be because of multiple sets of components that meet the characteristics inparagraph 5 (analogous to the situation contemplated by paragraph 10). The IASBcould consider expanding the requirements in paragraphs 22(a) and 22(aa) to explainsuch situations.If you have any questions regarding the matters raised in this letter, please contact me orAnthonyWong,AssociateDirectoroftheStandardSettingDepartment(anthonylwwong@hkicpa.org.hk).Yours sincerely,Christina NgDirector, Standard Setting Department
IASB Exposure Draft ED/2017/2 Improvements to IFRS 8 Operating Segments
下载原件Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
8 August 2017Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2017/2Improvements to IFRS 8 Operating SegmentsThe Hong Kong Institute of Certified Public Accountants is the only body authorised by lawto set and promulgate standards relating to financial reporting, auditing, and ethics forprofessional accountants, in Hong Kong.First of all, HKICPA appreciates your consideration of our feedback on the 2012 Request forInformation Post-implementation Review: IFRS 8 Operating Segments. ED/2017/2addressed most of our feedback.HKICPA supports most of the proposals in ED/2017/2. In particular:
The identification of segments, is based on how an entity's operations are reported tothe 'chief operating decision maker' (CODM) as a function, and not necessarily amanager with a specific title. HKICPA therefore supports the proposals in paragraphs 7,7A, 7B and 22(c). HKICPA also supports including paragraph BC25 in the finalamendments to explain the usefulness of disclosing the title and role of CODM. Inaddition, HKICPA and our stakeholders are aware that some or all of the informationproposed to be required under paragraphs 7, 7A, 7B and 22(c) may already bedisclosed in other parts of the annual report. Therefore, we recommend that the IASBconsiders allowing those information to be cross-referenced in the financial reports toavoid duplication.HKICPA also supports the proposed paragraph 45A in IAS 34 Interim FinancialReporting — we do not think this is a new requirement as this is consistent with the'retrospective application' requirement in IAS 8 Accounting Polices, Changes inAccounting Estimates and Errors and paragraph 29 of IFRS 8. HKICPA thereforerecommends the IASB to include in the basis for conclusions that the proposedamendment in IAS 34 is not a new requirement. HKICPA would also like to inform theIASB that one of our stakeholders commented that the restatement may not reflect howthey manage their business in prior periods and therefore this stakeholder does notsupport the 'retrospective application'.Consistent with the statement in proposed paragraph 19A, HKICPA and ourstakeholders consider that an entity is expected to identify the same reportablesegments in its financial reports as in other parts of its annual reporting package. Thisfollows the 'management approach' reporting underlying IFRS 8. Therefore, wedisagree with the proposed disclosure in paragraph 22(d). We consider the way inwhich proposed paragraph 22(d) is drafted implies that the segment disclosure infinancial reports can deviate from other parts of an entity's annual reporting package.If there is a difference between the financial report and the annual reporting package itmay be because of multiple sets of components that meet the characteristics inparagraph 5 (analogous to the situation contemplated by paragraph 10). The IASBcould consider expanding the requirements in paragraphs 22(a) and 22(aa) to explainsuch situations.If you have any questions regarding the matters raised in this letter, please contact me orAnthonyWong,AssociateDirectoroftheStandardSettingDepartment(anthonylwwong@hkicpa.org.hk).Yours sincerely,Christina NgDirector, Standard Setting Department