The Association of Corporate Treasurers (ACT) welcomes the fact that the IASB has reviewed and reconsidered this particular topic. The subject of hedging of forecast intragroup transactions is one that we specifically raised with the IASB in February 2004 and therefore your exposure draft designed to address our concerns is much appreciated.
In the previous version of IAS 39 the interpretation IGC 137-14 allowed a forecast intragroup transaction to be designated as a hedged item in a foreign currency cash flow hedge in consolidated accounts, but we understand that this was deliberately removed. In your Basis for Conclusions, BC 6, you note that one option was to reinstate the specific IGC 137-14 exception, but in BC7 you reject this since it does not fit in with the normal rationale that entities can only obtain hedge accounting for a transaction that will eventually result in an exposure that is not fully eliminated on consolidation.