The Accounting Professional and Ethical Standards Board (APESB) called for submissions on exposure draft (ED) Proposed Amendments to Fee-Related provisions of APES 110 Code of Ethics for Professional Accountants (including Independence Standards). 

CA ANZ continues to support a principles-based Code which addresses qualitative behaviours of professional accountants. Consistent with previous submissions, CAANZ does not support arbitrary thresholds in principles-based standards. 

The ED proposed three options regarding the type of review to be undertaken where fee dependency extends beyond five consecutive years. Consistent with other provisions, references and terminology used in the Code, CA ANZ supports Option 1, to require a review by an Appropriate Reviewer, which is a term already defined and used in the Code. With respect to the definitive nature of self-interest and/or intimidation threats created by ongoing fee-dependency, CA  ANZ supports a definitive response. A pre-issuance review in accordance with the timeframes specified in the proposed requirements better reflects public interest concerns. Considering who can perform the review, it is CA ANZ’s view that where fee dependency is for an Engagement Partner or an Office of the Firm, the review should be performed by a reviewer who was not involved in the Audit Engagement and is from another Office of the Firm.