Thursday, 12 July 2007

Peer Review by Head of Turkish International Accounting Standards Department of Real Value Accounting. r

Dear Mr. Smith,
As we have talked on the phone, you can find my interpretation about your book, attached to this e-mail.
Please do not hesitate to contact for any point.
Best regards,
Head of Accounting Standards Department
Capital Markets Board of Turkey

Dear Nick Smith,

I examined your book and understood that Real Value Accounting™ is based on the continuous updating of non-monetary units in terms of the Consumer Price Index to today’s real value.

Theoretically, I totally agree with you. But, as you know, there is a trend toward the acceptance of International Accounting Standards and International Financial Reporting Standards issued by the International Accounting Standards Board all over the world. For example, the International Organization of Securities Commissions (IOSCO) recommends harmonization of national accounting standards with IAS and IFRS. Also, the European Union introduced the requirement that from 2005 onwards, all listed companies have to prepare their consolidated accounts in accordance with IAS and IFRS adopted for application within the European Community. Considering international developments and as a candidate country for full membership, Turkey has issued a communiqué involving all IAS and IFRS and began application of them from the beginning of 2005 (As you know, we began application of IAS 29 in 2003).

In this regard, we can change over to real value accounting when there is a change in IAS/IFRS toward real value accounting or there is a trend toward real value accounting all over the world.

Regarding to tax regulation, I want to emphasize that tax regulation required restatement of assets and liabilities according to inflation (in terms of IAS 29) for the date of 31.12.2003 but taxes were not taken according to restated values in 2003. In 2004, financial statements were restated and taxes were taken based on restated values. In 2005, tax authority declared that high inflation period has ended, so entities did not do restatement according to inflation in first, second and third quarter of 2005. At the end of 2005, both Board and tax authority will evaluate economic conditions again and decide whether there is a need to restatement according to inflation.

Lastly, you stated in your book “publicly held companies and capital market institutions must account for perhaps an estimated 80 percent of the Turkish economy”. Unfortunately, I couldn’t give such statistical information. Besides, I attached a file that includes information about market value of publicly held companies. As you can see in that file, total market value of publicly held companies is approximately $ 174.3 billion and market value of floating part is about $ 54 billion. Total portfolio value of the investment funds is about $ 20 billion where brokerage firms have an estimated market value of $ 2 billion.

On the other hand, I can say that when there is hyperinflation in terms of IAS 29, with some exceptions (small firms), most of the Turkish companies have to restate their assets and liabilities according to regulation of the CMB and the tax authorities.

Best regards.

Reviewed 12-04-16

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