International Accounting
Standards Board
30, Cannon Street, London EC4M 6XH, United Kingdom
17 September 2010
On the Exposure Draft
ED/2010/5 Presentation of Items
of Other Comprehensive Income
Dear Sir/Madam,
The Bank of Russia has considered the Exposure Draft ED/2010/5 Presentation of Other
Comprehensive Income – Proposed amendments to IAS 1 and informs the following.
Question 1
We are of the opinion that changing of the title of the single statement of
comprehensive income to statement of profit or loss and other comprehensive income (paragraph
10 of the exposure draft) when referred to in IFRSs and other publications is appropriate because
it will reflect the content of this statement more precisely and give rise clarity and
understandability of the whole financial statements.
Question 2
We propose to consider the possibility to remain the existing way (paragraph 81 of IAS
1 Presentation of Financial Statement) that provide the possibility to the reporting entities to
present in their financial statements either single statement of comprehensive income or two
statements: separate income statement and statement of other comprehensive income.
We think that rejection of the possibility of presentation of two statements (separate
income statement and statement of comprehensive income), as it is proposed by the paragraph 81
of the exposure draft, will not lead to the improvement of comparability because in practice no
new information will be presented in the single statement. At the same time current possibility of
presenting profit and loss and other comprehensive income in separate statements give the
possibility to distinguish this two components more clear.
Profit or loss is a certain and stable independent element that describes the results of
performance of a reporting entity (paragraph AV5 of the exposure draft).
Question 3
We support the proposal to present consistently the items of other comprehensive
income that will be reclassified to profit or loss separately from those that will not be reclassified
in the future with presenting subtotals for them, as it is described in the examples in the guidance
on implementing of the exposure draft, because such format of the information presentation will
help users of financial statements to distinguish the changes in items that will not be reclassified
to profit or loss of the reporting entity in the future.
Question 4
We support the proposal to present income tax separately on items presented in other
comprehensive income that might be subsequently reclassified to profit or loss and those that
will not be reclassified because such format of information presentation will help users of the
financial statement to separate changes in the items and related to them income tax that
subsequently will not be included in the income statement of the reporting entity.
Separate presentation of income tax on the items of other comprehensive income, that
could be reclassified, and separation of income tax on the items, that couldn’t be reclassified,
will support the improvement of understanding of the information presented in the financial
statements.
Question 5
We propose to consider the possibility to remain existing way (paragraph 81 of IAS 1
Presentation of Financial Statement) that provide the possibility to the reporting entities to
present in their financial statements either single statement of comprehensive income or two
statements: separate income statement and statement of other comprehensive income.
We support the following proposals among the proposals presented in the exposure
draft:
the changing of the title of the single statement of comprehensive income to statement
of profit or loss and other comprehensive income (paragraph 10 of the exposure draft) because it
will reflect the content of this statement more precisely;
the separate presentation of the items of other comprehensive income and related to
them income tax that might be subsequently reclassified to profit or loss and those that will not
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be reclassified because such separation will support the improvement of clarity and
understandability of the whole financial statements.
Question 6
We propose to consider the possibility of information presentation about changes of the
items of other comprehensive income in the notes to the financial statements in the form of
disclosures to the corresponding items of the statement of changes in equity because such
presentation of information will support the improvement of clarity and understandability of the
whole financial statements. At the same time we propose to exclude the items of other
comprehensive income from income statement, i.e. to return to the approaches concerning
information presentation in income statement existed before amendments to IAS 1 Presentation
of Financial Statements that shall be applied for annual periods on or after 1 January 2009.
Besides choosing of the single format of presentation of income tax with regard to the
items of other comprehensive income, i.e. presenting all items either before tax or after tax will
result in improvement of clarity and understandability by the users of the financial statements. It
will improve comparability because users of the financial statements will not have to take into
account the existing differences of the presentation income tax in other comprehensive income.
Expenses on these proposals will be minimal as on implementing current requirements
of IAS 1 entities should have all the information needed for implementing suggested proposals.
Yours sincerely,
Deputy Director of Accounting and Reporting Department
Bank of Russia
V. Volkov
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