11. March 2019

ASCG comment letter to the Discussion Paper “Non-Exchange Transfers”

Today, the ASCG submitted its comment letter on the discussion paper Non-exchange Transfers (‘NETs’): A role for societal benefit? to EFRAG.

We disagree with the proposed objective of the project and the proposed scope of NETs in our comment letter. We have especially concerns that the proposed definition of NETs would cover a much wider range of transfers compared to those addressed in the DP.

Besides unintended consequence for existing IFRS guidance, we do not consider an immediate need for changing existing IFRS guidance in large parts.

Furthermore, we also have concerns regarding the proposed 4-step-approach regarding the recognition of NETs.