CA The Institute of PAKISTAN

Chartered Accountants of Pakistan HEAD OFFICE

(Submitted through the IFRS Foundation website)

April 17, 2015

International Accounting Standards Board

30 Cannon Street, London EC4M6XH United Kingdom

Subject: Exposure Draft: Disclosure Initiative (Proposed amendments to lAS 7) ­Proposed amendments to lAS 7 (ED/2014/6)

Dear Sir,

The Institute of Chartered Accountants of Pakistan is pleased to submit comments on the IASB's Exposure Draft ED/2014/6 Disclosure Initiative (Proposed amendments to lAS 7)

Our responses to the Questions to the Exposure Draft are given in the Appendix .

Yours truly,

Muhammad Owais Mukati, FCA

Senior Manager Technical Services

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(Established under the Chartered Accountants Ordinance, 1961 - X of 1961)

Chartered Accountants Avenue, Clifton, Karachi-75600 (Pakistan). Ph : (92-21) 111-000-422, Fax: 99251626

Website : www.icap.org .pk. E-mail : info@icap.org.pk

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Appendix: Responses to Invitation to Comment Questions

IASB Exposure Draft Disclosure Initiative (Proposed amendments to IAS 7)

Quest ion 1 - Disclosure Initiative amendments This Exposure Draft of proposed amendments to lAS 7 forms part of the disclosure Initiative. Its objectives are to improve:

(a) information provided to users of financial statements about an entity's financing activities, excluding equity items; and

(b) disclosures that help users of financial statements to understand the liquidity of an entity.

Do you agree with the proposed amendments (see paragraphs 44A and 50A)? Do you have any concerns about, or alternative suggestions for, any of the proposed amendments7

Response to Q-l

Our view is that the proposed amendments are not necessary and do not enhance the overall understanding of financial statements as most of the information is already required under IFRS.

To our understanding, the objective of the additional disclosures proposed in this Exposure Draft is to improve information about the liquidity of an entity by requiring the entity to provide net debt reconciliation to investors. The banks and other financial institutes are already providing sufficient liquidity information.

Question 2 - Transition provisions Do you agree with the proposed transition provisions for the amendments to lAS 7 as described in this Exposure Draft (see paragraph 59)? If not, why and what alternative do you propose?

Response to Q-2

We understand that that the proposed amendments do not affect recognition and measurement and only supplement disclosure in the financial statements, therefore we agree with the IASB's proposal to apply the amendments prospectively.

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Question 3­Do the proposed IFRS Taxonomy changes appropriately reflect the disclosures that are set out in

the proposed amendments to lAS 7 and the accompanying illustrative example? In particular:

(a) are the amendments reflected at a sufficient level of detail? (b) should any line items or members be added or removed?

(c) do the proposed labels of elements faithfully represent their meaning? (d) do you agree that the proposed list of elements to be added to the IFRS Taxonomy should

be limited to information required by the proposed amendments to lAS 7 or presented in the illustrative examples in lAS 7?

Question 4 - IFRS Taxonomy due process As referenced in paragraph SC20, the lASS is holding a trial of a proposal to change the IFRS

Taxonomy due process. Although not constituting a formal public consultation of the IFRS

Taxonomy due process, views are sought on the following:

(a) do you agree with the publication of the proposed IFRS Taxonomy Update at the same time

that an Exposure Draft is issued?

(b) do you find the form and content of the proposed IFRS Taxonomy Update useful? If not, why

and what alternative or changes do you propose?

Response to Q-3 & Q-4

We are of the view that combining the IFRS Taxonomy due process with that of the standard

setting due process would create complexity and divert resources to effectively review an

Exposure Draft. Therefore we suggest that lASS should not integrate the development of the

IFRS taxonomy in the lASS standard setting process, but it should be kept as a separate activity of the IFRS Foundation.

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