Sir David Tweedie
The Chairman
New South Wales
TREASURY
International Accounting Standards Board
30 Cannon Street
London EC4M 6XH
United Kingdom
Dear Sir David
IIII~II~II~~II~
* 1 6 30- 1 00*
LETTER OF COMMENT NO. l-lo
Contact: Barbara Richardson
Telephone: (02) 92284832
OUf Reference: T05/1897
Your Reference:
30 March 2009
lASH Discussion Paper Preliminary Views on
Financial Statement Presentation
New South Wales Treasury welcomes the opportunity to provide comments on the above
Discussion Paper.
We have several areas of concern:
1. Although you can read the discussion paper and think the objectives sound quite
reasonable, we feel the discussion paper does not provide what users really want. The sub
classification of balance sheet and income statement items into business (operating and
investing) and financing activities seems unnecessarily complex. Most users want to see
what the "underlying" profit is. And they want underlying profit and remeasurements to be
separately identified on the face of the income statement (rather than as a note disclosure
to a cash flow reconciliation schedule).
2. The discussion paper fails to fully address issues closely linked to presentation, especially
the different nature of items in other comprehensive income; i.e. remeasurements. Closely
linked to OUr first concern, the paper does not address why some items of remeasurement
are in profit while others are in other comprehensive income. This classification is
confusing and results in a document that does not adequately or completely cover all
aspects of presentation.
3. The scope of the project is even more limited than previous IASB projects. This approach
does not encourage neutrality in accounting and may also lead to less than robust
outcomes; i.e. better outcomes may be achieved by looking at a wider scope of entities.
4. The limited scope leads to questions about the potential applicability to not-for-profit
entities and public sector entities in the future when the boards consider t