GAAP ALERT No.19/2008 To read on line click here
31 October
Reclassify non-derivative financial assets (other than those designated at fair value through profit or loss by the entity upon initial recognition) out of the fair-value-through-profit-or-loss category when the financial asset is no longer held for the purpose of selling or repurchasing in the near future, and either of the following apply: there are rare circumstances; or it would have met the definition of loans and receivables (if the financial asset had not been required to be held for trading at initial recognition), and
Transfer from the available-for-sale category to the loans and receivables category a financial asset that would have met the definition of loans and receivables (if the financial asset had not been designated as available for sale), if the entity has the intention and ability to hold that financial asset for the foreseeable future.
Whether the amendments should apply to financial assets backing insurance liabilities and whether there should be amendments to AASB 1023 ‘General Insurance Contracts’ and AASB 1038 ‘Life Insurance Contracts’ will be discussed at November AASB meeting.
Professor David Boymal, Chairman of the AASB, noted that the IASB had not undertaken its normal due process in issuing the amendments. “In this current economic crisis, the AASB considers it necessary, in the best interests of the Australian economy, to follow the conduct of the IASB and take urgent action to make the international accounting treatments available immediately to Australian constituents”.
The AASB generally has a policy of setting effective dates that are in the future to allow time for constituents to deal with the changes. The amendments have an element of retrospectivity in the application back to 1 July 2008. However, because the amendments provide a choice (and some would say 'relief' from existing requirements), this element of retrospective application is acceptable under Australian legislative protocols.
“Whilst the option to reclassify is available, the decision to move a financial asset out of the fair-value-through-profit-or-loss category to the held-to-maturity category needs to be thoroughly considered to ensure it is consistent with the entity’s long-term objective for these financial assets. There are rules in AASB 139 that still apply, which prohibit financial assets from being taken back out of the held-to-maturity category in the future,” Professor Boymal said.
“These amendments ensure Australian entities are able to use accounting treatments consistent with those available in other jurisdictions and I welcome the AASB’s role in this internationally co-ordinated set of actions,” Minister Sherry concluded.
Additionally, the AASB has issued an IASB exposure draft that proposes enhancements to disclosure about fair value measurement and about liquidity risks. The AASB requests comments by 1 December 2008. “The IASB is currently undertaking a number of projects in response to the current economic environments, and is to be commended on its efforts and the timeliness of its response,” Professor Boymal said.
IASB Guidance on Fair Value Measurement for Inactive Markets
The IASB published educational guidance on the application of fair value measurement when markets become inactive. The summary document sets out the context of the expert advisory panel report and highlights important issues associated with measuring the fair value of financial instruments when markets become inactive. It is consistent with recent documents issued by the FASB (10 October) and by the Office of the Chief Accountant of the SEC and FASB staff (30 September).
In the report the panel identified practices that experts use for measuring the fair value of financial instruments when markets become inactive. The report provides useful information and educational guidance about the processes used, and judgements made, when measuring and disclosing fair value.
The feedback from the panel was incorporated in the preparation of the exposure draft (ED) proposing improvements to IFRS 7 ‘Financial Instruments: Disclosures’ (October 2007), and will be used in the development of the forthcoming standard on fair value measurement. The IASB expects to publish an exposure draft of that standard in 2009.
Commenting on the publication of the report, Sir David Tweedie, Chairman of the IASB, said “The expert advisory panel has provided useful input to a number of projects and we are moving quickly to incorporate their valuable contributions into our standards. Round-table discussions in Asia, Europe and the United States, to be held jointly with the FASB, will provide additional opportunities to gather views on where further enhancements may be required. Added to this, the joint IASB–FASB high level advisory group now being set up will provide advice to both boards on the reporting lessons from the credit crisis.”
“Much needs to be done by preparers and auditors in revisiting their understanding of complex and rule-based financial instruments standards in the current environment”, says Colin Parker FCA, Principal of GAAP Consulting and a member of the AASB. “They are lessons to be learnt from implementation of AASB 7, understanding the recent reclassification amendments, the IASB educational guidance, the proposed AASB 7 revisions, as well as, the basic rules in AASB 139 ‘Financial Instruments: Recognition and Measurement”, he concluded.
AASB November Meeting Agenda
The agenda for 13 and 14 November meeting includes:
Superannuation Plans and ADFs: Continue consideration of the proposed Exposure Draft
Insurance Standards: Consider implications of amendments to allow reclassification of financial assets
Related Party Disclosures in the Public Sector: Consider the scope of project
Business Combinations in NFPs: Consider potential Aus paragraphs
IPSASB Report: Receive verbal report
Non-exchange Income: Consider project status
Policy Statements: Consider withdrawal and replacement of policy statements
Interpretations: Consider draft Interpretation on Superannuation Contributions Tax
Modifying IFRSs for NFPs: Consider NZ developments
Conceptual Framework: Consider IPSASB Consultation Paper
Borrowing Costs: Consider IPSASB ED
Differential Reporting: Consider issues relating to general purpose financial reports
Annual Improvements: Consider submissions on ED 165 and draft submission to IASB, and
Presentation of Financial Statements: Consider issue of IASB Discussion Paper.
G100 Guide to ASX Risk Principle 7
‘Recognise and Manage Risk – A Guide to Compliance with ASX Principle 7’ (28 pages), produced jointly by the Group of 100 and Deloitte, has been developed to provide general guidance in relation to compliance with ASX Principle 7. It is the second edition and follows the release in August 2007 of the revised principles.
APESB Paper on Financial Advisory Services
The Accounting Professional and Ethical Standards Board (APESB) issued a Consultation Paper ‘Review of Miscellaneous Professional Statement APS 12 Financial Advisory Services Standards’. This is the first stage in a project to revise and reissue APS 12 as APES 335 Financial Advisory Services. Submissions are sought by 31 December 2008.
IASB October Meeting Highlights
Highlights of the 13-17 October IASB meeting included: Annual Improvements: In respect to the definition of a derivative as proposed in the ED on ‘Improvements to International Financial Reporting Standards’ (2007), decided not to proceed with the proposed amendment, but will consider addressing this issue in a future project. In respect of the effective interest method, decided that: a floating rate financial instrument is an instrument with contractual variable cash flow amounts arising from changes in market variables; and expectations (and changes in expectations) of future cash flows are not considered when calculating the effective interest rate for floating rate instruments Fair Value Measurement: In the context of progressing deliberations on the fair value measurement discussion paper, decided not to preclude the use of mid-market pricing or another pricing convention as a practical expedient for a fair value measurement within a bid-ask spread; specify that the bid-ask spread guidance applies in all levels of the fair value hierarchy; and not to include guidance on offsetting positions Financial Instruments with Characteristics of Equity: Considered an analysis on submissions on the discussion paper ‘Financial Instruments with Characteristics of Equity’ (February 2008); no decisions were made Insurance Contracts: Discussed measurement approaches to be applied to insurance liabilities; no decisions were made Share-based Payment: Discussed submissions on the ED ‘Group Cash-settled Share-based Payment Transactions’ (December 2007) that addressed how an entity that receives goods and services from its suppliers should account in its separate financial statements for share-based payment arrangements that are settled in cash by a group entity on its behalf. Confirmed the proposal in the ED to include all forms of group share-based payments in the scope of IFRS 2 ‘Share-based Payment’, but amend some of the defined terms in IFRS 2 rather than amend IFRIC 11 ‘IFRS 2 – Group and Treasury Share Transactions’ Global Credit Crisis: Continued discussion of a draft of ED on consolidation; and held an education session on the proposed amendments to FASB Interpretation 46(R) ‘Consolidation of Variable Interest Entities’. Discussed two possible approaches to derecognition of financial assets; and considered a report on the activities of the Expert Advisory Panel on illiquid markets IFRS for Private Entities: Made the following decisions:
Consolidation (Temporary Control) – An exemption from consolidation is added for subsidiaries where on acquisition there is evidence that control is intended to be temporary (i.e., there is an intention to dispose of the subsidiary within twelve months and management is actively seeking a buyer)
Options as Hedging Instruments – Purchased options are not permitted as hedging instruments. This would not prevent private entities from using purchased options to hedge risks or from disclosing the effect of doing so; it would only prohibit hedge accounting for those transactions
Operating Leases – Modified the application of the straight-line method by lessees for operating leases if minimum lease payments are structured to compensate the lessor for expected inflation, and
Classification of Equity/Liability: Incorporate the amendment to IAS 32 ‘Financial Instruments: Presentation’ issued (February 2008) on puttable instruments and obligations arising on liquidation.
The IASB also held a joint meeting with the US FASB on 20 and 21 October, highlights included: Global Credit Crisis: Decided to create a global advisory group to help ensure that reporting issues arising from the global economic crisis are considered in an internationally co-ordinated manner. Three round tables are to be held to provide input on reporting issues arising from the current global financial crisis. Emphasised the commitment to developing common solutions aimed at providing greater transparency and reduced complexity in the accounting for financial instruments Conceptual Framework: Adopted the working definitions of an asset and of a liability for Phase B (recognition and measurement) Consolidation: Discussed developing common standards on consolidation Derecognition: Discussed the following proposed derecognition principle for financial assets: “An entity should derecognise a financial asset or component thereof when it no longer qualifies as an asset of the entity (i.e., when the economic benefits no longer exist or the economic benefits exist but the entity ceases to have the ability to (a) obtain the future economic benefits inherent in the asset/component and (b) restrict others access to those benefits).” Discussed how to make the principle operational Other: Discussed emissions trading schemes, fair value measurement, the IASB’s discussion paper ‘Reducing Complexity in Reporting Financial Instruments and the FASB’s ED ‘Accounting for Hedging Activities: an amendment of FASB Statement No. 133’; no decisions were made Financial Instruments With Characteristics of Equity: Commenced discussions Liabilities – Uncertainties, and Expected Cash Flows: Discussed the role of expected cash flows in recognition and measurement decisions; and decided:
Expected outcome approaches do not play a role in recognition decisions (they are a measurement tool to be used after the decisions about recognition)
Decisions on measurement should be independent of decisions about recognition, and
Measurements under conditions of uncertainty should take account of the range of possible outcomes and their relative probabilities (as in an expected outcomes approach).
IASB and FASB Proposed Enhancements to Presentation of Financial Statements
The IASB and the US FASB released a discussion paper on financial statement presentation that contains an analysis of the current issues in financial statement presentation and presents the boards’ initial thinking on how those issues could be addressed in a possible future format. The objective of the project is to develop a standard that requires entities to organise financial statements in a manner that clearly communicates an integrated financial picture of the entity. The project is about how best to display assets, liabilities, income, expense, cash flows and related information in financial statements. It does not address how these items are recognised or measured. The discussion paper is open for comment until 14 April 2009. The IASB intends to issue an exposure draft of proposed revisions to IAS 1 by 2010.
IFRSs and US GAAP provide only limited presentation guidance. In addition, presentation guidelines in US GAAP are dispersed across standards. Moreover, users of financial statements have often expressed dissatisfaction that information is not linked across the different statements and that dissimilar items are in some cases aggregated in one number.
To address these issues the IASB and the FASB propose to introduce cohesiveness and disaggregation as the two main objectives for financial statement presentation. Cohesiveness would ensure that a reader of financial statements can follow the flow of information through the different statements of an entity; disaggregation would ensure that items that respond differently to economic events are shown separately. To achieve these main objectives the boards have developed a principle-based format that is presented in the discussion paper. The discussion paper proposes a consistency between income statement, balance sheet, and cash flow statement by classifications of operating, financing and investing; discontinued operations; and income tax.
The IASB and the FASB seek views from interested parties on both the objectives for the presentation of financial statements and the proposed format.
Introducing the discussion paper, Sir David Tweedie, Chairman of the IASB said “The credit crisis has highlighted the need for clear presentation of financial information that is often complex. Early staff drafts of the paper that included an option to eliminate the ‘net income’ line were widely reported. However, the boards have chosen to proceed with proposals that build on established practice. If you have an interest in the future presentation of financial information, now is the time to get involved.”
GAAP Consulting Network Member David Sauer considers many of the proposals are not radical. He says “Many preparers are likely to face more mandatory disclosures, for example with greater detail required for expenses. However, a preparer could implement the proposed principles on cohesiveness and disaggregation now and see a much more understandable financial report, and still be compliant with the current versions of the standards. The requirements for consistent allocation of items to groups such as operating and financing are positives”.
IASB and FASB Form Advisory Group to Review Credit Crisis Reporting
The IASB and FASB have announced that they will create a global advisory group comprising regulators, preparers, auditors, investors and other users of financial statements that will help to ensure that reporting issues arising from the global economic crisis are considered in an internationally co-ordinated manner. At a joint meeting on 20 and 21 October, the boards discussed the initial topics for the advisory group to consider; how they can appoint the group and schedule its first meeting.
David Tweedie, Chairman of the IASB, said “Recent statements from the G7 and other world leaders highlight the need for an internationally co-ordinated policy response to the credit crisis. The IASB has acted quickly to issue amendments on reclassifications, fair value measurement guidance for illiquid markets, and disclosures. We are pleased that the European Union has acted quickly to accept our amendments on reclassifications. The new advisory group will help the boards to develop rapidly a co-ordinated response to the economic crisis, and will provide additional global perspective to both standard-setting organisations as we address the increasingly complex issues that investors are facing”.
Mr. Robert Herz, Chairman of FASB, added “Ongoing developments in the global financial crisis and actions by governments and regulators are reshaping the financial markets here and around the world. All of this is likely to raise important issues in financial reporting, both here in the US and across the international capital markets. The advisory group that we and the IASB are establishing is aimed at helping both boards identify reporting issues arising from ongoing developments in the global financial markets so that we can develop common solutions that promote sound reporting and enhance transparency”.
IASB and FASB Commit to Global Approach to Enhance Market Confidence
The IASB and the FASB announced further details on their joint approach to dealing with reporting issues arising from the global financial crisis. They reiterated the importance of working cooperatively and in an internationally coordinated manner to consider accounting issues emerging from the global crisis. The Boards also emphasised the role of high quality financial reporting in helping enhance confidence in the financial markets by responding in a timely manner that improves transparency and provides greater global consistency in financial reporting.
Building on their announcement regarding the establishment of a joint advisory group, they agreed to the following measures: Appointment of a High-level Advisory Group: Agreed that the advisory group will be comprised of senior leaders with broad international experience with financial markets. It will consider how improvements in financial reporting could help enhance investor confidence in financial markets, and will be charged with identifying the accounting issues requiring urgent and immediate attention of the Board as well as issues for longer-term consideration Public Roundtables: Three roundtables will be organised (in Asia, Europe, and North America) for the purpose gathering input on reporting issues emanating from the current global financial crisis, and Common Long-term Solutions to Reporting of Financial Instruments: In addition to considering the potential for short-term responses to the credit crisis, both Boards emphasised their commitment to developing common solutions aimed at providing greater transparency and reduced complexity in the accounting of financial instruments. They will use their joint discussion paper ‘Reducing Complexity in Reporting Financial Instruments’, the responses received, and the deliberations of the high-level advisory group as starting points for this longer term objective.
AUASB October Meeting Highlights
Highlights of 27-28 October meeting of the AUASB included: ASA Redrafting (‘Clarity’ Format) Project Update: Project is on track for completion of the redrafting of the ASAs in October 2009, and revised ASAs will be operative for reporting periods commencing on or after 1 January 2010 Approval of First Group of Redrafted ‘Clarity’ Auditing Standards: The following standards were cleared for later approval
ASA 240 ‘The Auditor’s Responsibilities Relating to Fraud in an Audit of a Financial Report’
ASA 260 ‘Communication with Those Charged with Governance’
ASA 315 ‘Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and its Environment’, and
ASA 330 ‘The Auditor’s Procedures in Response to Assessed Risk’
Approval of the Release of Third Group of Exposure Drafts: The following EDs in ‘Clarity’ format, were approved with comments sought by 12 December
ED 15/08 ASA 200 ‘Objective and General Principles Governing an Audit of a Financial Report’
ED 16/08 ASA 250 ‘Considerations of Laws and Regulations in an Audit of a Financial Report’
ED 17/08 ASA 320 ‘Materiality and Audit Adjustments’
ED 18/08 ASA 450 ‘Evaluation of Misstatements Identified During the Audit’
ED 19/08 ASA 510 ‘Initial Engagements – Opening Balances’
ED 20/08 ASA 550 ‘Related Parties’
ED 21/08 ASA 580 ‘Management Representations’ and
ED 22/08 ASA 720 ‘Other Information in Documents Containing Audited Financial Reports’
Amendments to Auditing Standards and Guidance Statements: Considered various amendments to Guidance Statement GS 001 ‘Concise Financial Reports with Guidance Statement’ that will be released in mid- November. Also approved minor editorial amendments to ASAE 3500 ‘Compliance Engagements’.
Audit Guidance Statement Promotes Rigorous Audits of SMSFs
Auditors will have greater awareness and understanding of their responsibilities when conducting audits of SMSFs, as the result of a Guidance Statement released by the AUASB. The 180 page Guidance Statement GS 009 ‘Auditing Self Managed Superannuation Funds (SMSFs)’ provides a road map to guide auditors through the application of AUASB standards and the complex requirements of the legislation and regulations governing the audits of SMSFs.
Merran Kelsall, Chairman of the AUASB, said the Guidance Statement will help improve the quality of audits conducted for SMSFs by identifying, clarifying and summarising the existing responsibilities of auditors. “The Guidance Statement assists auditors on matters which the auditor should consider when planning, conducting and reporting on the financial and compliance audits of an SMSF. “SMSF trustees, fund members and the Australian Taxation Office can now have greater confidence in the quality of audited information and governance arrangements of SMSFs,” Ms Kelsall said.
Justin Reid, Associate, GAAP Consulting, stated “The Guidance Statement is a very important source of information on how to conduct an audit of SMSF”. “GAAP Consulting will shortly be providing training courses and other tools to assist with understanding and implementing guidance”, he foreshadowed. Please register your interest.
Towards A Single Set of International Auditing Standards
The International Federation of Accountants (IFAC) issued a policy position titled ‘IFAC’s Support for a Single Set of Auditing Standards: Implications for Audits of Small and Medium-sized Entities”. The paper sets out IFAC’s view that International Standards on Auditing (ISAs) are designed to be applicable to audits of financial statements of entities of all sizes, and highlights the ways in which the IAASB considers the needs and perspectives of small and medium-sized entities (SMEs) in the development of those standards.
The paper emphasises that the consistent use of the ISAs is essential to meeting the public interest expectations of an audit. If auditors intend to issue an ISA audit report, they must comply with the ISAs. This enables a consistent level of assurance to be associated with the word “audit”, and allows users to make decisions in the light of a common understanding about the reliability of financial statements. The paper also emphasises the importance of professional judgment in determining the most effective approach for a particular audit.
The paper points out that SMEs have an alternative to obtaining an audit; they may obtain a review of their financial statements. International Standard on Review Engagements 2400 ‘Engagements to Review Financial Statements’, requires a different level of work effort by the practitioner and results in a different and lower level of assurance. The IAASB will be considering changes to this standard in light of the current needs of the marketplace. A new consultation paper ‘Matters to Consider in a Revision of International Standard on Review Engagements 2400, Engagements to Review Financial Statements’, commissioned by the IAASB and developed by staff of several national auditing standard setters, seeks input on the elements that would provide a relevant and cost-effective assurance service that is an alternative to an audit for SMEs in particular. IFAC encourages the broader accountancy community to assist the work of the IAASB by responding to this consultation paper.
IAASB Issues Seven Revised ISAs
The International Auditing and Assurance Standards Board (IAASB) released seven International Standards on Auditing (ISAs) that are in the new style following the conventions developed in the IAASB’s project to improve the clarity, and therefore the application, of its standards. Some of the standards released today have been substantively revised, while others have been redrafted to apply the new conventions.
The clarified ISAs include ISA 200 (Revised and Redrafted) ‘Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with International Standards on Auditing’. This fundamental ISA contains an overview of an audit to aid in understanding its purpose and scope; defines the respective authority of the requirements and guidance in ISAs; and contains the most fundamental requirements for auditors. It emphasises the importance of sound and consistent professional judgment by the auditor, and the necessity for sufficient audit evidence to support the auditor's opinion.
John Kellas, IAASB Chairman, explained, “The issuance of ISA 200 (Revised and Redrafted) is a milestone for the IAASB in that it codifies the principles underpinning the interpretation of standards drafted using the clarity conventions. As the overarching standard to all other ISAs, ISA 200 (Revised and Redrafted) establishes the basic objective and obligations of the auditor, and sets out how the objectives, requirements and guidance in all ISAs are to be understood.”
In addition to ISA 200 (Revised and Redrafted), the IAASB also released:
ISA 320 (Revised and Redrafted) ‘Materiality in Planning and Performing an Audit’
ISA 450 (Revised and Redrafted) ‘Evaluation of Misstatements Identified during the Audit’
ISA 530 (Redrafted) ‘Audit Sampling’
ISA 610 (Redrafted) ‘Using the Work of Internal Auditors’
ISA 705 (Revised and Redrafted) ‘Modifications to the Opinion in the Independent Auditor’s Report’, and
ISA 706 (Revised and Redrafted) ‘Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report’.
“In clarifying the ISAs, the IAASB aimed to eliminate any possible ambiguity within the extant standards and to drive more consistent application by auditors. The revisions in particular upgrade the standards in the important areas of materiality and misstatements and reporting by the auditor,” noted Mr. Kellas.
These ISAs form part of the IAASB’s program to redraft existing standards following the clarity drafting conventions. To date, the IAASB has released 22 final clarity redrafted ISAs. The IAASB is on track to finalise its complete set of clarified ISAs by the end of this year. All clarified ISAs will be effective from a single date, for audits of financial statements for periods beginning on or after 15 December 2009.
Issue Paper on the IAASB’s Proposed Revision of Review Engagements
IFAC released a consultation paper ‘Matters to Consider in a Revision of International Standard on Review Engagements (ISRE) 2400, Engagements to Review Financial Statements’ developed by staff from the national auditing standard setters. It is expected that the responses to this paper will assist the IAASB in its consideration of a relevant and cost-effective assurance service that is an alternative to an audit for small and medium-sized entities in particular.
The paper, commissioned by the IAASB, focuses on a number of significant matters relevant to a revision of ISRE 2400, including the nature and extent of the work a practitioner should perform in an engagement to review financial statements, and how the level of assurance obtained should best be communicated to users.
Feedback on Justin Reid’s Audit Presentation: Brillant!
In October, Justin Reid, Associate, GAAP Consulting, presented a full day on Contemporary Auditing Issues and Risk Management with the resulting feedback: “Just got the evaluations back …. all scored either very satisfied or extremely satisfied; a brilliant result! Thank you very much” stated Brian Martin, Business Manager, The Institute of Chartered Accountants in Australia.
Outstanding Exposure Drafts
Accounting
7 November ‘Improvements to IFRS (Proposed Amendments to International Financial Reporting Standards’ – IASB
5 December ‘Simplifying Earnings per Share (Proposed Amendments to IAS 33)’ – IASB
5 December ED 167 ‘Discontinued Operations: Proposed Amendments to AASB 5’ – AASB
5 December Approved ED 168 ‘Additional Exemptions for First-time Adopters: Proposed Amendments to AASB 1’ – AASB
15 December ‘Improving Disclosures about Financial Instruments (proposed amendments to IFRS 7)’ – IASB
7 January, 2009 ED 35 ‘Borrowing Costs Revised 200X’ – IPSASB
23 January ‘Discontinued Operations – Proposed Amendment to IFRS 5’ – IASB
23 January ‘Additional Exemptions for First-time Adopters: Amendments to IFRS 1’ – IASB
31 March ‘Conceptual Framework for General Purpose Financial Reporting by Public Sector Entities’ – IPSASB
Auditing
12 December ED 15/08 ASA 200 ‘Objective and General Principles Governing an Audit of a Financial Report’, ED 16/08 ASA 250 ‘Considerations of Laws and Regulations in an Audit of a Financial Report’, ED 17/08 ASA 320 ‘Materiality and Audit Adjustments’, ED 18/08 ASA 450 ‘Evaluation of Misstatements Identified During the Audit’, ED 19/08 ASA 510 ‘Initial Engagements – Opening Balances’, ED 20/08 ASA 550 ‘Related Parties’, ED 21/08 ASA 580 ‘Management Representations’ and ED 22/08 ASA 720 ‘Other Information in Documents Containing Audited Financial Reports – AUASB
Please forward this GAAP Alert to a colleague for their information and use. GAAP Alert registrations can be made directly at http://www.gaap.com.au
Please click here if you wish to unsubscribe.
Consulting, Training, Information Services Our Brochure
© GAAP.COM.AU
While all reasonable care has been taken in the preparation of information contained in this newsletter, we take no responsibility for any action(s) taken on the basis of information contained herein or for any errors or omissions in that information. We expressly disclaim any liability whatsoever, to any person in relation to any reliance, in whole or in part, on such information. Readers should consult a suitably qualified professional adviser to obtain advice tailored to their particular circumstances.
|