SAS Quadra 05. Bloco J. CFC
Brasília, Distrito Federal - Brazil www.cpc.org.br
September 30, 2010
International Accounting Standards Board
30 Cannon Street
London EC4M 6XH
United Kingdom
RE: Exposure Draft on Presentation of Items of Other Comprehensive Income.
Dear Sir/Madam,
The “Comitê de Pronunciamentos Contábeis” - CPC welcomes the opportunity to comment on the Exposure Draft named Presentation of Items of Other Comprehensive
Income.
We are a standard-setting body engaged in the study, development and issuance of accounting standards, interpretations and guidance for Brazilian companies. Our members are nominated by the following entities: a) the São Paulo Stock Exchange; b) c) the Federal Accounting Council; the Brazilian Association of Listed Companies; d) e) the Brazilian Institute of Independent Auditors; the Research Institute of Accounting, Actuarial and Financial Foundation; and f) the National Association of Capital Market Investment Professionals and
Analysts.
This response summarizes the views of our members, which may be supported by the opinions of external parties, sent to us for analysis and to enhance the discussion on the subject matter. We have also made efforts to encourage other external parties to send comments directly to the IASB.
If you have any questions about our comments, please contact Geraldo Toffanello
(geraldo.toffanello@gerdau.com.br).
Yours sincerely,
Edison Arisa Pereira
Technical Coordinator
Comitê de Pronunciamentos Contábeis (CPC)

SAS Quadra 05. Bloco J. CFC
Brasília, Distrito Federal - Brazil www.cpc.org.br
Consultation Questions
Question 1
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 propose?
Comment:
The main aspect in this change is not only the title of the statement, but the elimination of the option to present the statement of profit or loss and other comprehensive income in two statements. We agree with the proposal and acknowledge the Board’s efforts to eliminate options with the objective of improving consistency and comparability. However, as described in question 5, below, we believe that the option to present two statements, one statement of profit or loss and the second one with other comprehensive income items would be permitted. To improve consistency in this
case one statement should be follow by the other one.
Question 2
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?
Comment:
We agree with the proposal and we also believe this change will provide more consistency in presentation and make financial statements more comparable.
Question 3
The exposure draft proposes to require entities to present items of other comprehensive income (OCI) that will be reclassified to profit or loss (recycled) in subsequent periods upon derecognition separately from items of OCI that will not be reclassified to profit or loss. Do you support this approach? Why or why not? What alternative do you propose, and why?
Comment:
We support this approach, because presenting separately these items will be more useful to the users of financial statements to identify the items of other comprehensive income that will impact profit or loss in subsequent periods. We suggest the inclusion of guidance related to the items that have to be presented in OCI as well as identifying

SAS Quadra 05. Bloco J. CFC
Brasília, Distrito Federal - Brazil www.cpc.org.br
items that might be subsequently reclassified to profit or loss and those that will not be reclassified subsequently to profit or loss.
Question 4
The exposure draft 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?
Comment:
We support this proposal. The change in the presentation should include the separate presentation of the related tax effects, since these effects in some situations are relevant to the correct measurement and understanding of the financial statements.
Question 5
In the Board’s assessment:
(a) the main benefits of the proposals are:
(i) presenting all non-owner changes in equity in the same statement.
(ii) improving comparability by eliminating options currently in IAS 1.
(iii) maintaining a clear distinction between profit or loss and items of other comprehensive income.
(iv) improving clarity of items presented in OCI by requiring them to be classified into items that might be reclassified subsequently to profit or loss and items that will not be reclassified subsequently to profit or loss.
(b) the costs of the proposals should be minimal because in applying the existing version of IAS 1, entities must have all the information required to apply the proposed amendments.
Do you agree with the Board’s assessment? Why or why not?
Comment:
We agree with the Board’s assessment related to the main benefits expected with these proposed changes. However we believe that the option to present two statements, one statement of profit or loss and the second one with other comprehensive income items should be permitted considering that:
Many jurisdictions, as in Brazil, dividends are calculated based on the profit and loss amount, which is considering one of the main elements of the financial statements to measure Company’s financial performance. When companies prepare only a single
statement with these two elements (profit and loss and other comprehensive income) the Profit and Loss amount is only one of the items in the statement.

SAS Quadra 05. Bloco J. CFC
Brasília, Distrito Federal - Brazil www.cpc.org.br
Additionally, as it is also the Brazilian case, the Profit and Loss Statement as a single
Statement is required by Law (Brazilian Corporate Law), considering its relevance to shareholders and investors.
Question 6
Do you have any other comments on the proposals?
Comment:
We suggest the disclosure of the current year gain or loss and reclassification adjustment be presented compulsorily in the body of the statement and not in notes, because these information, if presented in the statement, would be more relevant to improve the ability of measurement on the comprehensive income and impacts on gain or loss.
We also suggest the elimination of the option to present items of OCI net or gross of
tax improving comparability and eliminate options in IFRS
We also recommend that entities do not be obliged to apply this revised standard before 2013, as a way of allowing entities to have more time to implement this change.