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30/04/2024 - EFRAG’S Draft Comment Letter on the IASB's ED Business Combinations—Disclosures, Goodwill and Impairment

EFRAG has published its draft comment letter (‘the DCL’) on the IASB’s ED/2024/03 Business Combinations—Disclosures, Goodwill and Impairment (Proposed amendments to IFRS 3, IAS 36) (‘the ED’).
Comments to the EFRAG DCL may be submitted until 28 June 2024.


In its draft comment letter, EFRAG welcomes the IASB's effort in trying to achieve the right balance to improve the disclosure requirements in IFRS 3 and goodwill impairment test in IAS 36 at a reasonable cost to preparers. However, there are still significant concerns on which EFRAG seeks additional feedback and includes questions to constituents. The input from constituents will support EFRAG in reaching a position in its final comment letter to the IASB. In this regard, EFRAG is seeking additional input from constituents on:

  • specific aspects of the package of new disclosures, including application of the exemption, and proposed threshold approach to identify a strategic business combination;
  • the proposal to provide quantitative information on expected synergies; and
  • whether, in addition to the proposal to remove the requirement to use pre-tax cash flows and pre-tax discount rates in calculating value in use, the IASB should deal with existing tax issues, including the treatment of deferred taxes.

The EFRAG Secretariat is in the process of planning outreach activities to obtain feedback on EFRAG’s preliminary views.

EFRAG's draft comment letter can be found here. The deadline for comments is 28 June 2024.