ED/2015/6 Clarifications to IFRS 15

Our letter is in response to the IASB's Exposure Draft (ED) 2015/6 'Clarifications to IFRS 15'.

In this ED the IASB has proposed a number of clarifications to IFRS 15 with respect to licensing, identifying performance obligations, and determining whether an entity is acting as a principal or an agent in a transaction.  The IASB also proposes to provide transition relief for both modified contracts and completed contracts.  Overall, we agree with the substance of the proposed amendments, subject to some detailed  comments set out in our responses to the questions asked by the ED.  We also agree with the IASB's decision not to undertake further amendments in a number of specific areas including collectability, non-cash consideration,  and the presentation of sales taxes.

In addition to our overall message of support, we express concern about differences in wording between IFRS 15 and ASC Topic 606 that will result if the FASB proceeds with its own amendments in these areas.  We urge the Boards to continue their efforts to maintain convergence, to ensure that identical language is used in situations where similar results are intended, and to consider that wherever texts vary, divergence in practice may result.