ASCG comment letter on tentative agenda decisions taken by the IFRS IC in September 2025

On 25 November 2025, the ASCG has submitted its comment letter on tentative agenda decisions taken by the IFRS Interpretations Committee in its September 2025 meeting.

As regards the tentative agenda decision on IFRS 16 Leases (Economic Benefits from Use of a Battery under an Offtake Arrangement), we agree with the IFRS IC’s view and the respective conclusions.

As regards the tentative agenda decision on IFRS 18 Presentation and Disclosure in Financial Statements (Classification of a Foreign Exchange Difference from an Intragroup Monetary Liability (or Asset)), we disagree with the IFRS IC’s view. In our comment letter, we express the view that the fact pattern assumed in the tentative agenda decision is too simplistic and disregards the economic rationale of such intragroup transactions. The technical analysis in the tentative agenda decision focuses on an intragroup liability (or asset) alone and disregards the fact that those intragroup transactions are usually entered into as part of an external group financing transaction.

Applying the tentative agenda decision would in practice result in income and expenses from a comprehensive group financing transaction being classified in different categories in the statement of profit or loss. In our view, however, such transactions should be classified in their entirety in a single category of the statement of profit or loss. In our comment letter, we therefore recommend the IFRS IC revisit its tentative agenda decision and consider whether a presentation that reflects the economic substance of the underlying transactions as a whole (including an intragroup loan) can be achieved within the remit of the current requirements of IFRS 18.