Chartered Accountants ANZ supports the intention behind the proposals as they seek to address a gap in IFRS 16 Leases when accounting for leases involving sale and leaseback transactions that include a variable lease. However, we consider it is not appropriate to introduce an amendment to IFRS 16 at this stage when preparers, auditors and others are still dealing with the first time implementation challenges associated with IFRS 16.
Our submission also emphasizes that there are other gaps in the standard that are equally pertinent (e.g. accounting for various types of lease incentives) where further guidance may be necessary. We appreciate that it is important for the IASB to provide guidance where there is a definite need for it however, the IASB should collate all issues and concerns that have been identified by preparers, auditors and other stakeholders over the initial implementation period of IFRS 16 and address these collectively as part of the post-implementation review of the Standard.