International Accounting
Standards Board
30, Cannon Street, London EC4M 6XH, United Kingdom
11 March 2008
Comments of the Exposure Draft of Proposed
Amendments to IFRS 2 Share-based Payment
and IFRIC 11 IFRS 2 –Group and Treasury
Share Transactions
Dear Sirs,
The Bank of Russia has considered the Exposure Draft of Proposed Amendments to IFRS
2 Share-based Payment and IFRIC 11 IFRS 2 –Group and Treasury Share Transactions Group
Cash-settled Share-based Payment Transactions and informs the following.
Question 1. We agree with the proposal as the IFRS 2 (see paragraph 2(b) of IFRS 2)
provides for using of fair value of liability in the form of equity instrument at making of payment
for the received goods or services in the form of basic asset in order to determine the transaction
price (fair value of the goods).
Transactions listed in paragraphs 3A of IFRS 2 and 11A of IFRIC 11 are most likely
within the scope of IFRS 2 (see paragraph 2 of IFRS 2), namely, an entity shall apply this IFRS
for all share-based payment transaction for the goods and services received.
Inclusion of transactions entered into on the terms of payments and defining of their price
stated in paragraphs 3A of IFRS 2 and 11A of IFRIC 11 increases the scope of IFRS 2
appropriately by extending it to the liabilities of all participants of the group (one or several
participants) arising from supplying of the goods or services to one (or several) of the group
participants.
We think it would be expedient to consider the matter of additional inclusion in the list of
participants of the transaction stated in paragraphs 3A of IFRS 2 and 11A of IFRIC 11 the
persons that are defined as related parties (see paragraph 9 of IAS 24 «Related Parties
Disclosures»).
Question 2. We agree with the proposal of applying of proposed amendments to IFRS 2
and IFRIC 11 retrospectively, subject to the transitional provisions of IFRS 2, that corresponds
to the requirement of paragraphs 55 and 58 of IFRS 2, namely, for liabilities arising from sharebased payment transactions existing at the effective date of this IFRS, the entity shall apply the
IFRS retrospectively. For these liabilities, the entity shall restate comparative information,
including adjusting the opening balance of retained earnings in the earliest period presented for
which comparative information has been restated, except that the entity is not required to restate
comparative information to the extent that the information relates to a period or date that is
earlier than 7 November 2002.
Proposed for the discussion amendments to IFRS 2 and IFRIC 11 mention the changes in
the applied basis of estimation, namely, from the fair value of liabilities that is change in
accounting policies (see paragraph 35 of IAS «Accounting Policies, Changes in Accounting
Estimates and Errors»).
Yours sincerely,
L. Gudenko
Chief Accountant of the Bank of Russia –
Director of Accounting and Reporting Department