Octber 8, 2014 Dr. Heather Smith Deputy Secretary, G20 Sherpa C/ G20 Taskfrce Department f the Prime Minister and Cabinet PO Bx 6500 CANBERRA ACT 2600 AUSTRALIA By e-mail: Heather.Smith@pmc.gv.au SUPPORTING ECONOMIC GROWTH AND BUILDING ECONOMIC RESILIENCE RECOMMENDATIONS FOR THE G-20 LEADERS SUMMIT NOVEMBER 15-16, 2014 Dear Dr. Smith, The Internatinal Federatin f Accuntants (IFAC) 1 ffers the fllwing recmmendatins fr discussin and endrsement by gvernment leaders at the G-20 Leaders Summit n Nvember 15-16, 2014, in Brisbane, Australia. 2 They fcus n actins aimed at achieving strng, sustainable, and balanced grwth, ensuring a mre rbust and resilient ecnmy; and addressing causes f the glbal financial crisis thrugh financial regulatry refrm and enhancing the internatinal taxatin system. The accuntancy prfessin s skills and experience are essential fr advancing ecnmic stability, strengthening financial systems and architecture, and prmting accuntability and lng-term sustainability and grwth grwth and stability that require integrity in the recgnitin, measurement, prcessing, and reprting f financial transactins. In fact, a strng, vibrant accuntancy prfessin is essential acrss all parts f the glbe. IFAC, in cllabratin with its member bdies, ther key internatinal rganizatins (e.g., the Wrld Bank, multilateral develpment banks, etc.), and the dnr cmmunity, has initiated a variety f supprt activities aimed tward enhancing and develping the capacity f the prfessin wrldwide and, in particular, in develping and emerging natins. As nted n the Australian G-20 website, accrding t the Internatinal Mnetary Fund, emerging market and develping ecnmies cntribute mre than tw thirds f glbal grwth. 3 1 IFAC is the glbal rganizatin fr the accuntancy prfessin dedicated t serving the public interest by strengthening the prfessin and cntributing t the develpment f strng internatinal ecnmies. IFAC cmprises 179 members and assciates in 130 cuntries and jurisdictins, representing apprximately 2.5 millin accuntants in public practice, educatin, gvernment service, industry, and cmmerce. 2 This letter fllws previus submissins t the G-20 in each f the last five years. Refer t IFAC website. 3 Refer t Australia 2014 G20 Website
This letter fllws previus submissins t the G-20 in each f the last five years. 4 A number f recmmendatins included in these previus submissins are still relevant and cntinue t be prmted by IFAC. They are listed in the appendix t this letter and include recmmendatins fr supprting the Internatinal Integrated Reprting Cuncil (IIRC) s wrk n develping a framewrk fr integrated reprting, as well as fr strengthening the accuntancy prfessin in develping and emerging ecnmies. Recmmendatins Trust and transparency are essential elements fr strengthening financial systems and architecture and fr prmting ecnmic stability, accuntability, lng-term sustainability, and grwth. IFAC recmmends that G-20 cuntries direct their attentin tward specific areas that inspire greater levels f trust and transparency, including: (i) glbal cnsistency where needed t achieve sund financial regulatin; (ii) enhanced financial management, reprting, transparency, and accuntability by gvernments; and (iii) effective taxatin systems. 1. Glbal Cnsistency fr Sund Financial Regulatin There is grwing recgnitin f the impacts f the increasing pace and vlume f regulatry refrm that has taken place in the financial arena in the last five t six years. It is imprtant t ensure that refrms are undertaken in line with principles f gd regulatin and recgnize that there is a balance t be struck between reducing risks in capital markets and impsing unreasnable regulatry burdens. Refrms shuld be addressed in a glbally cnsistent manner t the extent pssible and apprpriate if they are t be effective in mitigating future glbal crises, r t assist in respnding t such crises when they ccur. Natinal regulatry refrms need t carefully cnsider the extra-territrial impacts and unintended cnsequences that culd create uneven playing fields and might prmte regulatry arbitrage. Specifically, fr financial infrmatin and financial reprting, glbally cnsistent and effective regulatin requires the glbal adptin and implementatin f high-quality standards, which assists in facilitating crss-brder activity, prmting ecnmic and financial stability, and strengthening transparency and accuntability. Internatinal Financial Reprting Standards (IFRSs) and Internatinal Standards n Auditing (ISAs) are tw sets f standards that the Financial Stability Bard (FSB) has identified, acrss 12 plicy areas, as key fr sund financial systems and deserving f timely implementatin. Ntwithstanding the pinin, expressed by several cmmentatrs, that the pprtunity fr cnvergence f IFRS and US Generally Accepted Accunting Principles has passed, IFAC supprts the G-20 psitin previusly expressed that there is a need fr a single set f high-quality, glbally accepted financial reprting standards. 4 Refer t the IFAC website. 2
Reigniting mmentum fr regulatry cnsistency Recmmendatin 1 IFAC recmmends that the G-20 maintains its mmentum and ambitin fr regulatry refrm and cnvergence develped during the glbal financial crisis. Glbal cnsistency prmtes pprtunities fr measured and apprpriate respnses t avid glbal crises and prmtes greater pprtunities fr unrestricted crss-brder trade. Principles f high-quality regulatin Recmmendatin 2 IFAC recmmends that gvernments and regulatrs adhere t principles f high-quality regulatin, especially: clearly defined bjectives fr what the regulatin is intended t address; targeted, nn-discriminatry regulatin that is cnsistently and fairly implemented; prprtinate regulatin that takes accunt f the size and cmplexity f the rganizatins t which it is applied and the disprprtinate impacts it might have n different rganizatins; impact assessments t determine the likely impact f the intended regulatin n thse wh will be subject t it; brad cnsultatin with thse affected by the regulatin; cperatin and cllabrative dialgue with ther key regulatrs; and evidence-based regulatin, where apprpriate, and relevant research t infrm plicy making. Adptin and implementatin f glbally accepted, high-quality internatinal standards Recmmendatin 3 IFAC recmmends that the G-20 wrks t supprt strengthened resurcing and gvernance arrangements fr internatinal regulatry rganizatins and standard setters that have clearly defined expectatins and respnsibilities. 3
Recmmendatin 4 IFAC recmmends the adptin and implementatin, acrss all jurisdictins, f: Internatinal Financial Reprting Standards; Internatinal Standards n Auditing; Auditr independence requirements set ut in the Cde f Ethics fr Prfessinal Accuntants, issued by the Internatinal Ethics Standards Bard fr Accuntants; and Internatinal Public Sectr Accunting Standards (IPSASs). 2. Financial Management, Reprting, Transparency, and Accuntability by Gvernments Despite increasing awareness f the issue ver the last few years, inadequate public sectr financial management and pr gvernment transparency and accuntability, in many parts f the wrld, remain a significant threat t glbal financial stability. Ecnmic and scial impacts f the widespread failures f fiscal management in the public sectr far exceeded the impact f lsses incurred by crprate failures in the first decade f this century. Gvernments require rbust financial management practices, funded n a bedrck f high-quality accrualbased financial reprting fr a sund tday, tmrrw, and lng-term sustainable future. A failure t act and make significant refrms will mean that many gvernments will cntinue t make decisins based n incmplete infrmatin. The ability t meet debt servicing bligatins, maintain apprpriate levels and quality f service delivery, and meet scial benefit prgram bligatins, will diminish, and the cnfidence f citizens, investrs, and ther stakehlders will be reduced. Fundamental refrms t imprve the level f transparency and accuntability are als needed urgently in many jurisdictins t create incentives fr gvernments t manage their finances in a manner that prtects citizens, the public interest, and investrs in gvernment debt. Refrms must fcus n issues such as: (i) timely publicatin f high-quality audited accrual-based financial reprting; (ii) budgeting, apprpriatins, and reprting n the same accrual basis; (iii) full transparency in fiscal psitins ahead f general electins, ensuring that vting is fully infrmed; and (iv) limitatins n deficit spending, r at least full transparency arund the reasns fr deficit spending, and explanatins f hw, ver an ecnmic cycle, fiscal balance will be restred. Recmmendatin 5 IFAC recmmends that the G-20 actively encurages and facilitates the adptin f accrualbased accunting by gvernments and public sectr institutins, which in turn wuld facilitate imprved financial management in the public sectr, better decisin making, and allw mnitring f gvernment debt and liabilities t determine their true ecnmic implicatins. 4
Recmmendatin 6 IFAC recmmends that the G-20 cmmissins urgent and fundamental wrk t cnsider the nature f institutinal changes needed in public sectr financial management t prtect the public and investrs in gvernment bnds and t prmte greater transparency and accuntability. Recmmendatin 7 IFAC recmmends that, in relatin t the FSB, the G-20: explicitly requires the FSB s rle t encmpass public sectr arrangements; establishes a wrking grup within the FSB architecture that is specifically tasked with examining enhanced public sectr financial reprting, transparency, and accuntability, including transparency arund deficit spending; and directs the FSB t include IPSASs as a set f standards key fr sund financial systems and deserving f timely implementatin. 3. Effective Taxatin Systems Sund, effective taxatin systems are essential fr the functining f mdern scieties and ecnmies. They ideally shuld have clear bjectives, prmte transparency, and, where pssible, be simple t apply and mnitr. Refrms t taxatin systems shuld be balanced and prperly cnsidered and encurage tax t be paid in jurisdictins where real ecnmic activity ccurs. The effectiveness f taxatin systems may be undermined where taxatin utcmes d nt reflect the ecnmic substance f transactins, r where taxatin cnsideratins are the primary justificatin fr the initiatin f investments r transactins that therwise wuld nt take place. Cperatin between jurisdictins, fr example, thrugh the use f internatinal treaties and infrmatin sharing arrangements, is imprtant t prmte the right accuntabilities and lng-term glbal sustainability and grwth. It is imprtant that the G-20 has identified taxatin as a pririty area and has requested that wrk be undertaken by the Organisatin fr Ecnmic C-peratin and Develpment (OECD) t identify actins that will allw gvernments t cllect the tax revenue they need t serve their citizens. Recmmendatin 8 IFAC recmmends that G-20 natins: enhance the design and effectiveness f taxatin systems, as they apply t rganizatins f all sizes, as a means f encuraging ecnmic grwth; and act cperatively t supprt the wrk f the OECD and address issues f base ersin and prfit shifting t enhance the transparency and integrity f taxatin systems and reprting, and that: 5
taxatin arrangements encurage tax t be paid in jurisdictins where real ecnmic activity ccurs; taxatin refrms are balanced, prperly cnsidered, practical, and implemented in a crdinated and cnsistent manner; cnsideratin is given t reaching internatinal agreement n a prperly resurced dispute reslutin mechanism; the impacts f jurisdictins using taxatin as incentives fr investment are recgnized, including the ptential that investment chices may be therwise distrted; and the needs f develping cuntries and emerging ecnmies are prperly cnsidered and addressed. Please cntact us shuld yu require further infrmatin n any f the recmmendatins included in this letter. IFAC welcmes the pprtunity t participate in, r cntribute t, activities that aim t further these recmmendatins and t assist the G-20 in achieving its bjectives. Yurs sincerely, Fayezul Chudhury Chief Executive Officer 6
APPENDIX SELECTED RECOMENDATIONS INCLUDED IN IFAC SUBMISSIONS TO THE G-20 IN 2009-2013 Integrated reprting IFAC recmmends that the G-20 frmally signal its supprt fr the wrk being undertaken by the Internatinal Integrated Reprting Cuncil (IIRC) with respect t develping a framewrk fr integrated reprting. Strengthening the accuntancy prfessin in develping and emerging ecnmies IFAC recmmends that G-20 natins supprt initiatives aimed at strengthening the accuntancy prfessin in develping and emerging cuntries. The develpment f sustainable rganizatins IFAC recmmends that gvernments and regulatrs adhere t principles f high-quality regulatin, especially ecnmic impact assessment, in implementing evidence-based regulatry refrm. IFAC encurages the G-20 t prmte the develpment f glbally cnsistent effective and integrated gvernance, risk management, and internal cntrl arrangements fr rganizatins. Greater accuntability and transparency in the management f public resurces IFAC recmmends that the G-20 cntinue t supprt the wrk f the Financial Actin Task Frce (FATF) with respect t the Internatinal Standards n Cmbating Mney Laundering and the Financing f Terrrism & Prliferatin (FATF Recmmendatins), which aim t cmbat mney laundering and terrrist financing.