International Accounting
Standards Board
30, Cannon Street, London EC4M 6XH, United Kingdom
№ 18-2-2-14/1570
30 September 2009
On the Exposure Draft ED/2009/10
Discount Rate for Employee Benefits
Dear Sirs / Madams,
The Bank of Russia has considered the Exposure Draft ED/2009/10 Discount Rate for
Employee Benefits and informs the following.
Question 1
Discount rate for employee benefits
We agree with the proposal of the IASB concerning common approach application to
entities from differ jurisdictions in determining the discount rate for employee benefit
obligations using by reference to market yields on high quality corporate bonds because it results
in improved comparability of entities’ financial information.
In our view disclosure about the amount using in calculation the actuarial discount rate
and basis put in its determining will be useful for users of financial statements in its analyzing.
Question 2
Guidance on determining the discount rate for employee benefits
We agree with the proposal that entities in actuarial assumptions should refer to the
guidance in IAS 39 Financial Instruments: Recognition and Measurement for determining fair
value post-employment benefit obligations. In view of that approaches for determining fair value
for the discount rate in actuarial assumption (paragraph 73 (b [i]) of IAS 19) and rates for
financial assets and liabilities must be common, IAS 19 should refer to the guidance in IAS 39
concerning approaches taking into account determining a fair value of financial instruments
(paragraphs AG 69 - AG 70 of IAS 39).
Question 3
Transition
If the approach will be accept, entities should apply the proposed amendments
prospectively from the beginning of the period in which it initially applies them. In some cases
retrospective application may be difficult to accomplishment, for example in jurisdiction in
which there is no observable market price for high quality corporate bonds or no observable
inputs.
We agree that entity’s gains and losses arising from the change in accounting policy
should be recognised directly in retained earnings. Because the changes in the defined benefit
liability that arise from application of the proposed amendments to IFRSs are not concerned with
entities’ operation activities.
Best regards,
N. Litus
Acting Chief Accountant of the Bank of Russia –
Director of Accounting and Reporting Department