Name of Submitter: Mark Omona Organisation: Institute of Certified Public Accountants of Uganda Country / jurisdiction: Uganda Correspondence address and/or email: , Ref Question Response (Please indicate your response a, b, c, etc) Reasoning (Please give clear reasoning to support your response) S1 Use by publicly traded entities (Section 1) The IFRS for SMEs currently prohibits an entity whose debt or equity instruments are traded in a public market from using the IFRS for SMEs (paragraph 1.3(a)). The IASB concluded that all entities that choose to enter a public securities market become publicly accountable and, therefore, should use full IFRSs. Some interested parties believe that governments and regulatory authorities in each individual jurisdiction should decide whether some publicly traded entities should be eligible to use the IFRS for SMEs on the basis of their assessment of the public interest, the needs of investors in their jurisdiction and the capabilities of those publicly traded companies to a To enable enhanced disclosures, publicly traded entities should be required to apply full IFRS.
Recently the guidance on fair value in full IFRSs has been consolidated and comprehensively updated by IFRS 13 Fair Value Measurement. Some of the main changes are: • an emphasis that fair value is a market-based measurement (not an entity-specific measurement); • an amendment to the definition of fair value to focus on an exit price (fair value is defined in IFRS 13 as “the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date”); and • more specific guidance on determining fair value, including assessing the highest and best use of non-financial assets and identifying the principal market. The guidance on fair value in Section 11 is based on the guidance on fair value in IAS 39. The IAS 39 guidance on fair value has been replaced by IFRS 13. In straightforward cases, applying the IFRS 13 guidance on fair value would have no impact on the way fair value measurements are made under the IFRS for SMEs. However, if the new guidance was to be incorporated into the IFRS for SMEs, SMEs would need to re-evaluate
Ref General Questions Response (Please indicate your response a, b, c, etc) Reasoning (Please give clear reasoning to support your response) G1 Consideration of minor improvements to full IFRSs The IFRS for SMEs was developed from full IFRSs but tailored for SMEs. As a result, the IFRS for SMEs uses identical wording to full IFRSs in many places. The IASB makes ongoing changes to full IFRSs as part of its Annual Improvements project as well as during other projects. Such amendments may clarify guidance and wording, modify definitions or make other relatively minor amendments to full IFRSs to address unintended consequences, conflicts or oversights. For more information, the IASB web pages on its Annual Improvements project can be accessed on the following link: http://go.ifrs.org/AI Some believe that because those changes are intended to improve requirements, they should naturally be incorporated in the IFRS for SMEs where they are relevant. Others note that each small change to the IFRS for SMEs would unnecessarily increase the reporting burden for SMEs because SMEs would a It is useful when an entity wants to move to full IFRSs