4.2 Analysis of comment letters to Discussion paper and Exposure Draft of the
4.2.1 Developing countries and their needs
The IASB said it was developing the SME standard for both SMEs in developed and developing economies, but the Discussion Paper asked no questions specific to developing countries. Further, the staff summary prepared by the IASB based on responses to the Discussion Paper did not report any comments about developing countries (Ram, 2012). However, comments on the Discussion Paper highlighted issues of accessibility, comprehensibility, language barriers and the applicability of international accounting standards to developing countries. There was also a call to
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involve developing country professional bodies in the project (Singh & Newberry, 2009). Respondents to the Staff Questionnaire argued that the recognition and measurement requirements arising from fair value accounting were complex and burdensome because developing countries lacked active markets, expertise, and resources. Although the ED did not seek responses on developing country issues, 19 submissions mentioned these concerns. Five of these submissions were from developing countries, 10 from developed countries, three from international organisations, and one from an international accounting firm. Table 10 provides a summary of responses to ED of the accounting standard IFRS for SMEs commenting on developing countries.
Eight respondents to the ED commented that developing countries lacked active markets to allow fair value determinations of most of their assets. For example, the International Network of Accountants and Auditors (2007, p. 10) highlighted that “many SMEs, particularly in emerging economies, do not have access to working markets from where they could obtain information regarding the fair value of their assets”. Others argued that some developing countries do not have the support of specialists needed to assist in fair value determination, thus potentially undermining the credibility and reliability of information through lack of precision and excessive subjectivity (International Federation of Accountants, 2007; Singh & Newberry, 2009; South African Institute of Chartered Accountants, 2007).
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Table 9 : Summary of responses to Exposure Draft IFRS for SMEs commenting on developing countries
Organisation Country Affiliation Developing countries’ needs Small entities Lack of market Lack of expertise/ resources Language barrier Access to IFRS
Responses from developing countries University of Cape Town South
Africa Academic X
Fiji Institute of Accountants Fiji Professional
Body X
South African Institute of Chartered Accountants
South Africa
Professional
Body X
Malaysian Accounting Standards
Board Malaysia
Standard
Setter X
Federation Argentina de Consejos Profesionales de Ciencias
Economicas
Argentina Professional
Body X X
Responses from developed countries, international organisations and accounting firms Inter-American Accounting
Association Canada/US
Professional
Body X
Institute of Chartered Accountants
of Scotland UK
Professional
Body X
New York Society of CPA’s US Professional
Body X
Certified General Accountants
Association of Canada Canada
Professional
Body X
Ernst & Young Global Accounting
70 Table 9: continues
Organisation Country Affiliation
Developing countries’ needs Small entities Lack of market Lack of expertise/ resources Language barrier Access to IFRS Consiglio Nazionale dei Dottori
Commercialisti and the Consiglio Nazionale dei Ragionieri
Italy Professional
Body X
Association of Chartered Certified
Accountants (UK) UK
Professional
Body X X
International Network of Accountants and Auditors UK
Professional
Body X X
European Accounting Association EU Regional
Body X X
The Confederation of Asian and Pacific Accountants
Regional
Body X X X
Hong Kong Institute of Certified
Public Accountants Hong Kong
Professional Body X International Federation of Accountants International Body X X
Institute of Chartered Accountants
of Barbados Barbados
Professional
Body X X X
London Society of Chartered
Accountants UK
Professional
Body X
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Six respondents commented on the applicability of IFRS for SMEs to small entities in developing countries (Singh & Newberry, 2009). The Hong Kong Institute of Certified Public Accountants (2007) and Association of Chartered Certified Accountants (2007) argued that the proposed IFRS was not for small entities at all, but rather was directed at medium-sized non-publicly accountable entities. As a consequence, the International Federation of Accountants (2007, p. 4) state that “it may prove ill-suited on cost-benefit grounds for application by the great majority of small entities that produce general purpose financial statements for external users, especially those operating in developing nations”.
Six respondents suggested developing countries may lack the resources, expertise, and access to information necessary to prepare financial statements in accordance with the IFRS (International Network of Accountants and Auditors, 2007). The ED’s cross-references to the IFRS would, therefore, increase the burden on those in developing countries because they would need to know the IFRS to apply the SME requirements (Confederation of Asian and Pacific Accountants, 2007).
Several submissions highlighted specific consideration of developing countries’ needs. The ED omitted simplifications of several matters including hyperinflation and agriculture because these were deemed not relevant for SMEs. The IASB proposed cross-reference to the IFRS, if SMEs should encounter such issues. Ernst & Young (2007)argues that those matters are relevant in developing countries, and therefore that simplified accounting guidance on accounting in hyperinflationary economies and on agriculture is necessary. In this context, Institute of Chartered Accountants of Barbados (2007, p. 1) notes:
The burden of complying with full IFRS is clearly greater for SMEs in developing markets operating in emerging economies. The SME standards as drafted do very little to reduce this burden. The Board’s concern in the SME accounting project should be to develop standards for those jurisdictions where the need is greatest and not for jurisdictions which already have their own standards and standard-setting bodies.
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