Вопросы от IASB по изменениям в IAS 16 (письмо от 25.01.2018)

Dear Mrs Sukhareva,

We would like to thank you for your comment letter on the Exposure Draft IAS 16 – Proceeds before Intended Use sent to us in October 2017. Your letter was useful in preparing the feedback we presented last month to the Board (this summary can be found on the following link:http://www.ifrs.org/-/media/feature/meetings/2017/december/international-accounting-standards-board/ap12d-ias-16.pdf).

Your letter included the Interpretation R-57/2015 on Testing and Commissioning of Property, Plant and Equipment resulting in production you translated in English for our perusal. We appreciated your explanations on that interpretation as well as its translation in English. We have the following questions in relation to this interpretation:

-          We understand that if the entity sells items (before a tangible fixed asset is available for use) that are similar to those sold in its ‘normal operations’, the entity would measure the cost of the items sold at an amount similar to the cost of items sold in the ‘normal operations’.

o   Would the cost of items sold before the asset is available for use include a depreciation expense related to the tangible fixed asset?

o   Does this requirement mean that your Russian constituents do not face significant practical issues in pricing the cost of the items sold when such circumstances arise? 

-          We also understand if the entity sells items (before a tangible fixed asset is available for use) that are dissimilar to those sold in its ‘normal operations’, the entity would need to measure the cost of the items. The interpretation does not specify any method as its Basis for Conclusions says there is ‘no-one-size-fits-all solution for all circumstances). Your accompanying letter however says that the cost of items sold could be equal to their estimated NRV (considered as their deemed cost) in many cases.

o   Could you explain to us more precisely why, in your view, the NRV of items would be their most appropriate measurement basis?

o   During the discussion among members of your interpretation committee, did it come up that performing a cost allocation would be very challenging? Have you identified specific practices in relation to that point?

Your letter also mentioned that the issue of ‘hot commissioning’ gave rise to ‘heated debates’ among members of your interpretation committee. Was it because the issue is widespread or is significant for some industries located in your country? If appropriate, is there any fact patterns you considered during the discussions?

As you may know, some respondents to the Exposure Draft said the proposed amendments would create application difficulties. Consequently, we welcome any useful input that could help us gain an in-depth understanding of those difficulties. The thorough command of the issue your committee gained on this issue would be very helpful in that regard.

Should you need any additional information, please do not hesitate to contact us.

It may be preferable to set-up a conference call at your convenience to discuss our questions. If this is something you would be open to, please let us know and we will make the necessary arrangements.

We look forward to hearing from you.

Best regards,

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Vincent Louis | Practice Fellow

International Accounting Standards Board (IASB)
30 Cannon Street | London EC4M 6XH | UK

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vlouis@ifrs.org | www.ifrs.org 

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