Response 3 - KPMG
KPMG LLP Audit 15 Canada Square London E14 5GL United Kingdom
Pauline Wallace Chair UK Endorsement Board 6th Floor 10 South Colonnade London E14 4PU
Our ref DJL/CWA/SAH
By email to: [email protected]
2 July 2024
Dear Ms Wallace
We welcome the opportunity to respond to the UK Endorsement Board's (UKEB) invitation to comment on the UKEB Draft Comment Letter on the above mentioned IASB's Exposure Draft.
We appreciate the IASB's efforts, in response to stakeholders' concerns, to improve the information provided about acquisitions and their subsequent performance, including the recognition of impairments on a timely basis.
KPMG LLP is part of a global network of firms. Views on IFRSs are developed globally by KPMG International Standards Group. The KPMG network of firms' response to this Request for Information has not yet been finalised and will be provided publicly to the IASB in due course. In advance of the finalisation of global network views, the comments in this letter are the preliminary views of KPMG LLP in the UK only.
KPMG in the UK broadly agree with the proposals in relation to IAS 36.
Regarding the proposals in relation to IFRS 3, we believe further consideration should be given to some aspects of the proposals. With reference to the UKEB's draft comment letter, this includes:
- The threshold for disclosing strategic business combinations.
- The application of the disclosure exemption.
- Transition relief for first time adopters.
- The practicalities of preparing and auditing certain of the additional disclosures, including in relation to expected synergies.
Yours sincerely

KPMG LLP
KPMG LLP, a UK limited liability partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.
Registered in England No OC301540 Registered office: 15 Canada Square, London, E14 5GL For full details of our professional regulation please refer to 'Regulatory information' under 'About' at www.kpmg.com/uk
DJL/CWA/SAH