Europaudvalget 2009-10
EUU Alm.del Bilag 283
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EUROPEAN COMMISSIONInternal Market and Services DGFREE MOVEMENT OF CAPITAL, COMPANY LAW AND CORPORATE GOVERNANCEFinancial reporting
DIRECTORATEGENERAL FORINTERNALMARKET ANDSERVICES
CONSULTATION ON THEINTERNATIONALFINANCIALREPORTINGSTANDARD FORSMALL ANDMEDIUM-SIZEDENTITIES
Please send this answer sheet only.Consultation deadline:12 March 2010Preferred form of submission – email to:[email protected]
Postal address:European CommissionDG Internal Market and ServicesFinancial Reporting Unit-F3SPA 2/JII - 01/112B-1049 BrusselsBelgium.
Submissions after the deadline will not be considered.
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 29 65 199.http://ec.europa.eu/internal_market/accounting/sme_accounting/review_directives_en.htmE-mail: [email protected]
Please provide the following details together with your response:You are:Preparer:small companymedium-sizedcompanylarge companyUser:bank/creditproviderprivate personPublic authority:Accountants andAuditors:Other:audit/marketregulatoraccounting firmanalystOtherorganisation ofstakeholdersOther (pleasespecify)Legal Form:unlimited liabilitylimited liability
investor/investororganisationGovernmentMinistry/Agencyaudit firmother(please specify)organisation ofaccountants andauditors
(please specify)Ministry of Economic and Business Affairs/
Name of your organisation / company:Danish Commerce and Companies Agency
Country where your organisation / company is located:Name and location of parent company:N/A
Denmark
Contact details incl. e-mail address:Deputy Director General, Mr. Niels Henrik Englev.[email protected]
Short description of the general activity of your organisation / company:N/A
Do you trade cross-border?Is your organisation registered in the Interest Representative Register?
YesYes
NoNo
If yes, please specify the address of your organisation and the Register ID number in theInterest Representative Register1:Publication:
1
If your organisation is not registered, you have the opportunity to register here(https://webgate.ec.europa.eu/transparency/regrin/welcome.do?locale=en#en) before you submit yourcontribution. Responses from organisations not registered will be published separately from theregistered organisations.2
Do you object to publication of the personal data on the grounds thatsuch publication would harm your legitimate interests?
I object

Question 1:

Do you think the IFRS for SMEs is suitable for widespread use within Europe?YESNODon't know
Please comment, indicating whether there are any type(s) or size(s) of company thatwould benefit from adopting the Standard:small2medium3large4
other criteria (please explain)Please see below.
Please comment:The interest and need for the SME Standard seems to be more related to the specific kind ofcompany (e.g. companies with international stakeholders, subsidiaries of listed companies) thanto the size of the company.

Question 2:

If you are a preparer of company accounts can you indicate any costs (both one-off andrecurring) or benefits, and any other effects of adopting the IFRS for SMEs?Please comment:N/A
In particular, do you think increased international comparability of accounts preparedunder the IFRS for SMEs will benefit your business?YESPlease comment:NODon't know
2
Generally companies with turnover less than €4.4 million, balance sheet total less than €8.8 million and50 or fewer employees (see Fourth Company Law Directive)Generally companies with turnover less than €17.5 million, balance sheet total less than €35 millionand 250 or fewer employees (see Fourth Company Law Directive)
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4
Generally companies with turnover greater than €17.5 million, balance sheet total greater than €35million and more than 250 employees (see Fourth Company Law Directive)3

Question 3:

If you are a user of accounts (for example a bank) do you think the IFRS for SMEs willprovide more useful information than national GAAP accounts?YESPlease comment:N/A
NO
Don't know

Question 4:

Does increased international comparability of accounts prepared under the IFRS forSMEs benefit users?YESPlease comment:Many companies give/obtain credit and/or enters into long time operating relationships withcompanies in different contries. For these companies it will reduce the burdens if the accountsare prepared using the same accounting standard. The stakeholdes will have to use lessresources on reading and understanding the specific accounts and on comparing account fromdifferent Regions of the EU.
NO
Don't know

Question 5:

Do you think adoption of the IFRS for SMEs should be provided for within the EUaccounting legal framework?YESPlease comment:Use of the SME Standard might be an option according to the 4 Directive or an option accordingto a Regulation, like the options in the existing IFRS Regulation.th
NO
Don't know

Question 6:

If yes, should such an option be limited to a Member State option (i.e. that each MemberStates would have a possibility but no obligation to accept IFRS for SME)?YESNO4
Don't know
Please comment:Preferable, the option to use the SME Standard should apply directly to all the relevant companiesin the EU. This solution will ensure that all the relevant companies can benefit from the option -and ensure equal possibilities for all EU-companies.If this solution is not achievable, the possibility to use the SME Standard should at least be aMember State Option. A Member State Option will pay regards to those EU countries where theuse of the SME Standard would be fundamentally in conflict with the existing accounting regimeand those who want to limit the use of the SME Standard.If the permission on EU-level to use the standard is limited to certain types of companies oraccounts (i.e. consolidated accounts), the Member States should have the option to permit othertypes of companies to use the standards (and also allow it to be used in the annual accounts).

Question 7:

Do you have other views on the possible adoption of the IFRS for SMEs within the EUaccounting framework?Please comment:

Question 8:

Is there a case for giving companies, at EU level, an option to adopt the IFRS for SMEs?YESIf yes, for which categories:smallother criteria (please explain)mediumlargeNODon't know
Please comment:Please see our comments on question 6.

Question 9:

What should be done, in your view, where there is incompatibility between the Directivesand the IFRS for SMEs?Please comment:It should be ensured that the Directive is not in conflict with the SME Standard. This will also allowthe Member Stats to adjust the national accounting requirements to the SME Standard.5

Question 10:

In the light of the publication of the IFRS for SMEs, do you see a need for "rules-based"Accounting Directives in the future?YESNODon't know
If yes, for what type(s) or size(s) of company are detailed rules required?smallother criteria (please explain)mediumlarge
Other than the 5 items listed in paragraph 4.3 of the consultation document, whataspects of financial reporting should the revised Directives address, and to what level ofdetail?Please comment:
Other commentsWe have not fully considered this issue yet. However, we do find it appropriate to consider whatkind of companies which need to be included in the Accounting Directives and consider howspecific the regulation in the directives should be.It is our preliminary view that the Accounting Directives should not be more “ruled-based” in thefuture than they are today.

Question 11:

Are there any elements of the IFRS for SMEs that should be incorporated within revisedDirectives?Please comment:Please see our comments on question 9.

Question 12:

Do you have any other observations or comments on the IFRS for SMEs or the project tooverhaul the Accounting Directives?Please comment:Please see our comments on question 10.

Thank you for your contribution

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