COMMENT BY L.VENKATESAN CHENNAI 600 020 Comment by L.Venkatesan Chartered Accountant New no 23 ol No 13 28th Cross Indira nagar Chennai 600 0-20 PRESENTATION OF ITEMS OF OTHER COMPREHENSIVE INCOME refer to paragraphs Statement of profit or loss and other comprehensive income 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? REPLY; THE WORD OTHER COMPREHENVIE INCOME SHOULD BE RENAMED AS CAPITAL PROFIT OR AS UNREALISED FAIR VALUATION INCOME 10, BC21 Question 2 The proposals would require entities to present a statement of 12, 81, BC17-BC19 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? REPLY I AGREE WITH THIS ARGUMENT BUT INFORMATION IS NEEDED ON REALISED AND UNREALISED GAINS DUE TO CAHNGES IN FAIR VALUE Presentation of items of other comprehensive income 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? REPLY THIS IS A GOOD MOVE BUT DETAILS OF REALISED AND UNREALISED VALUE TO BE IN DICATED 82A, BC25 and BC26 Question 4 The exposure draft also proposes to require that income tax on 91, BC27-BC29 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? REPLY THIS IS A CORRECT APPRAOCH Benefits and costs Question 5 In the Board’s assessment: (a) BC32-BC36 the main benefits of the proposals are: (i) presenting all non-owner changes in equity in the same statement. REPLY ; THIS HAS NOT COME OUT IN THE PREPOSED CHANGES PLEASE RECHECK ONCE AGAIN (ii) improving comparability by eliminating options currently in IAS 1. REPLY : COMPRESHENSIVE INCOME IS NOT AN INCOME ATALL HENCE IT SHOULD BE DIRECTLY CREDITED TO RESER AS IS BEING DONE IN INDIA NOW (iii) maintaining a clear distinction between profit or loss and items of other comprehensive income. REPLY : WE SHOULD ALSO MAINTAIN DISTINCTION BETWEEN REALISED AND UNREALISED GAIN (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. REPLY THIS IS A CORRECT MOVE (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. REPLY ; THIS IS A NECESSARY CAHNGE HENCE COST IS NOT A CONSIDERATION THIS WILL IMPROVE PESENTATION Do you agree with the Board’s assessment? Why or why not? Other comments Question 6 Do you have any other comments on the proposals? REPLY : DIVIDEND DISTRIBUTION SHOULD BE TREATED AS AN ADJUSTUNG EVENT IN ADDITION TO EPS , ROI ALSO SHOULD BE PUBLISHED AS MANY OF THE COMPANIES DO NOT DISRTIBUTE DIVIDEND BUT PLOUGH BACK INCOME . IN SUCH A SITUATION EPS IS NOT THE RIGHT WAY OF MEASURING THE PERFORMANCE EPS SHOULD BE PRESENT ED SEPARATELY FOR REALISED AND UNREALISED INCOME THE STATEMENT , STATEMENT OF FINACIAL POSITION SHOULD ALSO BE CHANGED TO BALANCE SHEET FILES MEANT FOR COMMENT SHOULD ALWAYS BE A WORD FILE © Copyright IASCF PRESENTATION OF ITEMS OF OTHER COMPREHENSIVE INCOME [Draft] Amendments to IAS 1 Presentation of Financial Statements Paragraph 7 is amended (new text is underlined). Notes contain information in addition to that presented in the statement of financial position, statement of profit or loss and other comprehensive income, … Paragraph 12 is deleted. Paragraph 10, the headings above paragraphs 81 and 82 and paragraphs 81, 82 and 83 are amended (new text is underlined and deleted text is struck through). Paragraphs 82A and 82B are added and paragraph 84 is deleted. Complete set of financial statements 10 A complete set of financial statements comprises: (b) a statement of profit or loss and other comprehensive income for the period; An entity may use titles for the statements other than those used in this Standard. For example, an entity may use the title ‘statement of comprehensive income’ instead of ‘statement of profit or loss and other comprehensive income’. COMMENT USING INCOME FOR BOTH THE STATEMENT IS NOT CORRECT . COMPREHENSIVE INCOME SHOULD BE CALLED CAPITAL RECIPT OR CAPITAL INCOME TO DISTINGUISH FROM REVENUE INCOME 12 [Deleted] As permitted by paragraph 81, an entity may present the components of profit or loss either as part of a single statement of comprehensive income or in a separate income statement. When an income statement is presented it is part of a complete set of financial statements and shall be displayed immediately before the statement of comprehensive income. COMMENT A SINGLE STATEMENT OF TWO ITEMS ONE REVENUE AND OTHER CAPITAL IN NATURE IS NOT CORRECT . THERE SHOULD BE TWO STATEMENT TO DISTINGUSH THE SAME Statement of profit or loss and other comprehensive income 81 An entity shall present all items of income and expense recognised in a period: (a) in a single statement of comprehensive income, or 9 (b) 81 © Copyright IASCF in two statements: a statement displaying components of profit or loss (separate income statement) and a second statement beginning with profit or loss and displaying components of other comprehensive income (statement of comprehensive income). A statement of profit or loss and other comprehensive income shall be presented in two sections: (a) profit or loss; and (b) other comprehensive income. COMMENT : IT SHOULD ALWAYS BE PRESENTED IN TWO SECTIONS Information to be presented in the statement of profit or loss and other comprehensive income 82 As a minimum, the profit or loss section of the statement of profit or loss and other comprehensive income shall include line items that present the following amounts for the period: (a) revenue; (aa) gains and losses arising from the derecognition of financial assets measured at amortised cost; (b) finance costs; (c) share of the profit or loss of associates and joint ventures accounted for using the equity method; (ca) if a financial asset is reclassified so that it is measured at fair value, any gain or loss arising from a difference between the previous carrying amount and its fair value at the reclassification date (as defined in IFRS 9); (d) tax expense; (e) a single amount comprising the total of: (i) the post-tax profit or loss of discontinued operations and (ii) the post-tax gain or loss recognised on the measurement to fair value less costs to sell or on the disposal of the assets or disposal group(s) constituting the discontinued operation; (e) a single amount for the total of discontinued operations (see IFRS 5); and (f) profit or loss.; (g)-(i) [deleted] © Copyright IASCFRESENTATION OF ITEMS OF OTHER COMPREHENSIVE INCOME (g) each component of other comprehensive income classified by nature (excluding amounts in (h)); (h) share of the other comprehensive income of associates and joint ventures accounted for using the equity method; and (i) total comprehensive income. COMENT ; THE TOTAL OF PROFIT AND LOSS ACCOUNT SHOULD BE DIVIDED INTO REALISED PROFIT AND UNREALISED PROFIT LIKE CHANGES IN FAIR VALUE WHICH IS NOT A REAL PROFIT THERE SHOULD BE A BAR ON DISTRIBUTION OF UNREALISED PROFIT INCLUDING ISSUE OF BONUS SHARES 82A As a minimum, the other comprehensive income section shall include line items that present the following amounts for the period: (a) items of other comprehensive income grouped into those that, in accordance with other IFRSs: (i) will be reclassified subsequently to profit or loss when specific conditions are met, and (ii) will not be reclassified subsequently to profit or loss. (b) share of the other comprehensive income of associates and joint ventures accounted for using the equity method; and (c) total other comprehensive income. COMMENT; THE TOTAL SHOULD ALOS BE BIFERCATED INTO REALISED AND UNREALISED PROFIT. THERE SHOULD BE A BAR IN DISTRIBUTING UNREALISED PROFIT TO SHAREHOLDERS INCLUDING DISTRIBUTION OF BONUS SHARES 82B The statement shall also display the total of profit or loss and other comprehensive income. COMMENT THERE SHOULD BE SEPARATE TOTAL FOR REALISED AND UNREALISED PROFIT 83 An entity shall disclose the following items in the statement of profit or loss and other comprehensive income as allocations for the period: (a) (b) 84 profit or loss for the period attributable to: (i) non-controlling interests, and (ii) owners of the parent. comprehensive income for the period attributable to: (i) non-controlling interests, and (ii) owners of the parent. [Deleted] An entity may present in a separate income statement (see paragraph 81) the line items in paragraph 82(a)-(f) and the disclosures in paragraph 83(a). In paragraphs 85-87, 100 and 115 the references to ‘the separate income statement (if presented)’ are deleted and ‘statement of comprehensive income’ is replaced with ‘statement of profit or loss and other comprehensive income’. 11 © Copyright IASCF EXPOSURE DRAFT MAY 2010 In paragraphs 90 and 94 ‘statement of comprehensive income’ is replaced with ‘statement of profit or loss and other comprehensive income’. Paragraph 91 is amended (new text is underlined and deleted text is struck through). Paragraph 139G is added. 91 An entity may present items components of other comprehensive income either: (a) net of related tax effects, or (b) before related tax effects with one amount shown for the aggregate amount of income tax relating to those components. If an entity elects alternative (b) above, then it must allocate the tax between the items that might be reclassified subsequently to the profit or loss section and those that will not be reclassified subsequently to the profit or loss section. 139G Presentation of Items of Other Comprehensive Income (amendments to IAS 1), issued in [date], amended the terminology used throughout IFRSs. In addition it amended paragraphs 10, 82, 83 and 91, added paragraphs 81A, 82A and 82B, and deleted paragraphs 12, 81 and 84. An entity shall apply those [draft] amendments for annual periods beginning on or after [date to be inserted after exposure]. Earlier application is permitted. © Copyright IASCF 12