In its draft comment letter, EFRAG generally agrees with the IASB’s assessment of the issues and with its proposed amendments to address them as we believe that they provide practical solutions that would reduce divergences in application.

In relation to the second amendment, EFRAG believes that the proposed classification reflects the economic substance of the plan, and therefore should not be characterised as an exception. EFRAG also recommends including an example to illustrate the accounting for the payment of the withholding tax, consistently with the analysis that the plan is in substance an equity-settled plan.

EFRAG supports that the amendments are applied in accordance with the requirements in IAS 8, that is requiring retrospective application unless it is impracticable.

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