Dear Madam, dear Sir,

SwissHoldings, the Swiss Federation of Industrial and Services Groups in Switzerland, represents 61 Swiss groups, including most of the country’s major industrial and commercial enterprises. We very much welcome the opportunity to provide comments to this Exposure Draft (ED).

Our association welcomes IASB’s work on this topic generally and supports the modifications to existing paragraph 72A and the proposed principles laid out in paragraph 72B.

We would however like to highlight three main areas of concern:

  • The rule proposed in paragraph 72C(b) should not apply to all situations of uncertainty in the black and white manner as the draft currently foresees.
  • The volume of disclosure required in the notes, particularly as some of this information is forward-looking, is too extensive.
  • It should not be required to present separately liabilities subject to covenants in the balance sheet on a systematic basis.

We provide our comments in relation to the specific questions raised in the ED following the position of BUSINESSEUROPE in the annex.

If you require any further information upon these matters, please do not hesitate to contact us.

Download full comment letter [pdf]

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