## Summary of Consultation Responses: Proposed Recommendations - Group 2

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### Background and context
- Consultation on twelve Proposed Recommendations for updating the Government Finance Statistics Manual 2014 (GFSM 2014) based on changes agreed for implementation in the 2025 SNA and BPM7 ran from April 11 – May 2, 2025.
- The consultation results summarized here relate to the IMF Government Finance Statistics Advisory Committee meeting in Brasilia, Brazil, May 13–15, 2025 (Paper: GFSAC/2025/05/13A).

### Respondents and participation
- Total responses: 37.
- Responses from country authorities: 32 (in 28 different countries).
- Independent GFS experts: 5.
- Geographical spread: almost equal numbers from Asia & Pacific, Africa, and the Western Hemisphere; slightly fewer from Europe and Middle East & Central Asia.
- Areas of organization affiliation:
  - Ministry of Finance (MoF): 15
  - National Central Bank (NCB): 4
  - National Statistics Institute (NSI): 13
  - Independent Expert (Expert): 5
  - Total: 37
- Main interest/relationship with GFS:
  - GFS compilation: 24
  - Compilation of other macroeconomic statistics (e.g., national accounts, balance of payments): 7
  - Policymaking: 1
  - GFS analysis and use (e.g., analyst, academic): 2
  - Other (2 compilers, 1 user and compiler): 3
- Most respondents (89 percent) indicated engagement in macroeconomic statistical compilation (predominantly of GFS); remaining respondents reported they were users of GFS data. One respondent noted they were both compiler and user.
- Around two thirds of respondents (24 respondents) had provided responses to the first global consultation on proposed recommendations (Group 1).

### Overall agreement with Proposed Recommendations
- All twelve Proposed Recommendations were agreed for inclusion in the update of the GFS manual by the majority of respondents who expressed an opinion (excluding "no comment" responses).
- PR 1.21 Islamic finance: agreed unanimously by all respondents who expressed an opinion, without any caveats.
- Five Proposed Recommendations had a single respondent selecting “No” without comment:
  - PR 1.10 Super dividends and reinvested earnings of public corporations
  - PR 1.28 Work-in-progress, transfer of ownership and capital services
  - PR 1.30 Distinction between maintenance and capital repairs for intangible assets
  - PR 1.31 Treatment of the transfer of leased assets at the end of the lease period
  - PR 1.36 Treatment of precious metal accounts

### Detailed disagreements and substantive concerns
- PRs attracting more substantive disagreements:
  - PR 1.17 Debt concessionality
    - Rejected by 2 respondents.
    - Key arguments against: excluding grant elements of concessional loans from core GFS statements undermines transparency; concessional lending can materially affect public debt and fiscal balances and should be recorded above-the-line or disclosed as expenses such as interest equalization.
    - Supporting arguments for the proposal: recognizing concessionality only through supplementary information avoids distortions in debt statistics and supports faithful fiscal liability representation; maintaining concessionality as supplementary allows users to adjust data and preserves main fiscal aggregates.
    - Additional points: some support for excluding transfer element for concessional lending by central banks given monetary policy role; support for exception for employer loans to employees.
  - PR 1.27 Consistency in the application of the sum-of-costs approach
    - Rejected by 3 respondents.
    - Key concerns: inclusion of a net return on capital for nonmarket production is seen as an accounting concept that may disconnect from sum-of-costs methodology, complicate GFS compilation, and rely on a default real rate of return ("2% per year") benchmarked to the EU that may not suit many countries.
    - Requests: guidance on alternative country-specific rates; GFSM Update research project 2.1 should include guidelines for estimating net return to capital.
    - Supporting arguments for the proposal: inclusion of net return and rent payable makes data more complete, enhances conceptual consistency with national accounts, reduces asymmetries between market and non-market units, and standardized parameters facilitate implementation.
  - PR 1.29 Clarifications on treatment of terminal costs during ownership transfer
    - Rejected by 2 respondents (one without comment).
    - Key argument against: GFS focuses on fiscal reporting; full SNA treatment on capital services and ownership transfer costs could overcomplicate GFS and a cross-reference to SNA chapters would suffice.
    - Supporting arguments: maintain GFSM 2014 treatment of writing off terminal costs over whole life to avoid negative value at end of asset life; alignment with 2025 SNA reinforces conceptual consistency.
- Other noted disagreements or concerns:
  - PR 1.20 Payments for nonproduced knowledge-based capital (marketing assets): two respondents voted “No”; one argued measurement challenges in identification and valuation in the public sector if marketing assets were moved from nonproduced to produced assets. The proposal, however, is not to change current treatment (marketing assets remain nonproduced), so that comment effectively supports PR 1.20’s intent.
  - PR 1.25 Relationship between SNA and IPSAS/IFRS: one respondent argued for more detailed GFSM guidance than in the 2025 SNA; PR 1.25 intends to take that work forward under GFSM Update Research Project 2.27 (Relationship between GFS and IPSAS/IFRS).

### Responses by Proposed Recommendation (counts of Yes / No / Partially / No Comment)
- PR 1.8 Valuation of unlisted equity: Yes 33, No 0, Partially 3, No Comment 1 (Total 37)
- PR 1.10 Super dividends and reinvested earnings of public corporations: Yes 31, No 1, Partially 1, No Comment 4 (Total 37)
- PR 1.17 Debt concessionality: Yes 28, No 2, Partially 6, No Comment 1 (Total 37)
- PR 1.20 Payments for nonproduced knowledge-based capital (marketing assets): Yes 25, No 2, Partially 3, No Comment 7 (Total 37)
- PR 1.21 Islamic finance: Yes 26, No 0, Partially 0, No Comment 11 (Total 37)
- PR 1.25 Relationship between SNA and IPSAS/IFRS: Yes 29, No 1, Partially 2, No Comment 5 (Total 37)
- PR 1.27 Consistency in the application of the sum-of-costs approach: Yes 23, No 3, Partially 5, No Comment 6 (Total 37)
- PR 1.28 Work-in-progress, transfer of ownership and capital services: Yes 27, No 1, Partially 5, No Comment 4 (Total 37)
- PR 1.29 Clarifications on the treatment of terminal costs during ownership transfer for different types of assets: Yes 25, No 2, Partially 2, No Comment 18 (Total 37)
- PR 1.30 Distinction between maintenance and capital repairs for intangible assets: Yes 29, No 1, Partially 3, No Comment 4 (Total 37)
- PR 1.31 Treatment of the transfer of leased assets at the end of the lease period: Yes 28, No 1, Partially 4, No Comment 4 (Total 37)
- PR 1.36 Treatment of precious metal accounts: Yes 31, No 1, Partially 1, No Comment 4 (Total 37)

### Reasons for partial agreement (high-level themes)
- Practical implementation challenges were the most common rationale for partial agreement across most PRs.
- Conceptual concerns raised most notably for:
  - PR 1.8 Valuation of unlisted equity: worries about negative valuations, valuation consistency, ambiguity in preferred valuation methods (transaction prices vs. market capitalization), and need for guidance on deriving indicative prices.
  - PR 1.17 Debt concessionality: concerns over transparency and recording of concessional loan elements in core GFS.
  - PR 1.27 Sum-of-costs approach: concerns about appropriateness and robustness of including a net return on capital, applicability of a "2% per year" default real rate benchmark, and need for country-specific guidance.

### Next steps and use of feedback
- All feedback, including comments from those who agreed with the Proposed Recommendations, will be carefully considered when advancing each research project and drafting Notices of Decision for the GFSM update.

### Section 2 — Selected respondent comments by Proposed Recommendation
- PR 1.10 Super dividends and reinvested earnings of public corporations (1)
  - Not opposed conceptually but suggest that flexibility should be allowed depending on country circumstances.
- PR 1.17 Debt concessionality (6)
  - Concerns about complexity of identifying and reporting concessional elements and suggestion to focus on core reporting requirements to avoid burdensome data collection.
  - Calls to identify nature of all loans as sub-items for fiscal analysis rather than mere memorial items.
  - Suggestion to use a present value approach to capture repayment and grace period impacts.
  - Note that IPSAS classifies transfer element of concessional loans as a subsidy and suggestion to display subsidy separately.
  - Agreement in principle but concerns about divergence between GFS and accounting standards; requests more detail on memorandum treatments and consideration of expanding recognition beyond employer loans to employees.
  - Not opposed conceptually but suggest flexibility depending on country circumstances.
- PR 1.20 Payments for nonproduced knowledge-based capital (marketing assets) (3)
  - Support for conceptual direction but recommend maintaining alignment with 2025 SNA given that the UN Statistical Committee did not incorporate the change.
  - Concern about practical experience in identifying and valuing government marketing assets; suggestion to split current combined code for marketing assets and goodwill (61442) into distinct codes (614421 and 614422) and to rewrite GFSM 2014 paras. 7.115-116.
- PR 1.21 Islamic finance (0)
  - Not applicable (no comments).
- PR 1.25 Relationship between SNA and IPSAS/IFRS (2)
  - Agreement with proposal but request explicit acknowledgement that public corporations may apply IFRS as well as IPSAS.
  - Not opposed conceptually but recommend waiting for conclusion of GFSM Research Project 2.27.
- PR 1.27 Consistency in the application of the sum-of-costs approach (5)
  - Practical reservations about prescribing a specific rate and the frequency of updates; endorsement if GFSM language permits deviation with strong rationale.
  - Concerns that the approach could introduce complexity, distort macro aggregates, and impose methodological burdens on data providers.
  - Requests for clear guidance on rate of return and valuation of nonfinancial assets and clarification of market test implications.
- PR 1.28 Work-in-progress, transfer of ownership and capital services (5)
  - Agreement in principle but concerns about measurement issues, data sourcing, and divergence from accounting policy; request more detailed coverage for cultivated biological resources.
  - Practical implementation challenges described where work-in-progress projects are bundled and source data do not provide timing or valuation detail.
  - Suggest flexibility depending on country circumstances.
- PR 1.29 Clarifications on the treatment of terminal costs during ownership transfer for different types of assets (2)
  - Agreement conceptually but expected challenges in estimating terminal costs and request for more detailed guidance in upcoming manual.
- PR 1.30 Distinction between maintenance and capital repairs for intangible assets (3)
  - Agreement in principle but concerns about practicality given government administrative data sources and need for alignment with IPSAS/IFRS.
  - Suggest ensuring GFSM consistency with the Handbook on Measuring Data where default treatment may be to record as a capital transaction if separation cannot be made.
- PR 1.31 Treatment of the transfer of leased assets at the end of the lease period (4)
  - Not opposed conceptually but request additional guidance and flexibility for country circumstances.
  - Concerns about measurement/estimation of future asset value for long-life assets and divergence between GFS and accounting policy.
  - Support where source data support the treatment, e.g., large PPPs and single infrastructure assets.
- PR 1.36 Treatment of precious metal accounts (1)
  - Not opposed conceptually but note compilation challenges in valuing precious metals.

*Prepared by the Statistics Department, INTERNATIONAL MONETARY FUND for the IMF Government Finance Statistics Advisory Committee meeting in Brasilia, Brazil, May 13–15, 2025 (Paper: GFSAC/2025/05/13A).*

### Section 1

### Summary of Consultation Responses: Proposed Recommendations - Group 2

### Background and context
- Consultation on twelve Proposed Recommendations for updating the Government Finance Statistics Manual 2014 (GFSM 2014) based on changes agreed for implementation in the 2025 SNA and BPM7 ran from April 11 – May 2, 2025.
- The consultation results summarized here relate to the IMF Government Finance Statistics Advisory Committee meeting in Brasilia, Brazil, May 13–15, 2025 (Paper: GFSAC/2025/05/13A).

### Respondents
- Total responses: 37.
- Responses from country authorities: 32 (in 28 different countries).
- Independent GFS experts: 5.
- Geographical spread: almost equal numbers from Asia & Pacific, Africa, and the Western Hemisphere; slightly fewer from Europe and Middle East & Central Asia.
- Areas of organization affiliation:
  - Ministry of Finance (MoF): 15
  - National Central Bank (NCB): 4
  - National Statistics Institute (NSI): 13
  - Independent Expert (Expert): 5
  - Total: 37
- Main interest/relationship with GFS:
  - GFS compilation: 24
  - Compilation of other macroeconomic statistics (e.g., national accounts, balance of payments): 7
  - Policymaking: 1
  - GFS analysis and use (e.g., analyst, academic): 2
  - Other (2 compilers, 1 user and compiler): 3
- Most respondents (89 percent) indicated they were engaged in macroeconomic statistical compilation (predominantly of GFS); remaining respondents reported they were users of GFS data. One respondent noted they were both compiler and user.
- Around two thirds of respondents (24 respondents) had provided responses to the first global consultation on proposed recommendations (Group 1).

### Overall agreement with Proposed Recommendations
- All twelve Proposed Recommendations were agreed for inclusion in the update of the GFS manual by the majority of respondents who expressed an opinion (excluding "no comment" responses).
- PR 1.21 Islamic finance: agreed unanimously by all respondents who expressed an opinion, without any caveats.
- Five Proposed Recommendations had a single respondent selecting “No” without comment:
  - PR 1.10 Super dividends and reinvested earnings of public corporations
  - PR 1.28 Work-in-progress, transfer of ownership and capital services
  - PR 1.30 Distinction between maintenance and capital repairs for intangible assets
  - PR 1.31 Treatment of the transfer of leased assets at the end of the lease period
  - PR 1.36 Treatment of precious metal accounts

### Detailed disagreements and substantive concerns
- PRs attracting more substantive disagreements:
  - PR 1.17 Debt concessionality
    - Rejected by 2 respondents.
    - Key arguments against: excluding grant elements of concessional loans from core GFS statements undermines transparency; concessional lending can materially affect public debt and fiscal balances and should be recorded above-the-line or disclosed as expenses such as interest equalization.
    - Supporting arguments: recognizing concessionality only through supplementary information avoids distortions in debt statistics and supports faithful fiscal liability representation; maintaining concessionality as supplementary allows users to adjust data and preserves main fiscal aggregates.
    - Some support for excluding transfer element for concessional lending by central banks given their monetary policy role, and support for exception for employer loans to employees.
  - PR 1.27 Consistency in the application of the sum-of-costs approach
    - Rejected by 3 respondents.
    - Key concerns: inclusion of a net return on capital for nonmarket production is seen as an accounting concept that may disconnect from sum-of-costs methodology, complicate GFS compilation, and rely on a default real rate of return (2% per year) benchmarked to the EU that may not suit many countries; calls for guidance on alternative country-specific rates and for GFSM Update research project 2.1 to include guidelines for estimating net return to capital.
    - Supporting arguments: inclusion of net return and rent payable makes data more complete, enhances conceptual consistency with national accounts, reduces asymmetries between market and non-market units, and standardized parameters facilitate implementation.
  - PR 1.29 Clarifications on treatment of terminal costs during ownership transfer
    - Rejected by 2 respondents (one without comment).
    - Key argument against: GFS focuses on fiscal reporting; full SNA treatment on capital services and ownership transfer costs could overcomplicate GFS and a cross-reference to SNA chapters would suffice.
    - Supporting arguments: maintain GFSM 2014 treatment of writing off terminal costs over whole life to avoid negative value at end of asset life; alignment with 2025 SNA reinforces conceptual consistency.
- PR 1.20 Payments for nonproduced knowledge-based capital (marketing assets)
  - Two respondents voted “No”; one argued measurement challenges in identification and valuation in the public sector if marketing assets were moved from nonproduced to produced assets. The proposal, however, is not to change current treatment (marketing assets remain nonproduced), so that comment effectively supports PR 1.20’s intent.
- PR 1.25 Relationship between SNA and IPSAS/IFRS
  - One respondent argued for more detailed GFSM guidance than in the 2025 SNA; PR 1.25 intends to take that work forward under GFSM Update Research Project 2.27 (Relationship between GFS and IPSAS/IFRS).

### Responses by Proposed Recommendation (counts of Yes / No / Partially / No Comment)
- PR 1.8 Valuation of unlisted equity: Yes 33, No 0, Partially 3, No Comment 1 (Total 37)
- PR 1.10 Super dividends and reinvested earnings of public corporations: Yes 31, No 1, Partially 1, No Comment 4 (Total 37)
- PR 1.17 Debt concessionality: Yes 28, No 2, Partially 6, No Comment 1 (Total 37)
- PR 1.20 Payments for nonproduced knowledge-based capital (marketing assets): Yes 25, No 2, Partially 3, No Comment 7 (Total 37)
- PR 1.21 Islamic finance: Yes 26, No 0, Partially 0, No Comment 11 (Total 37)
- PR 1.25 Relationship between SNA and IPSAS/IFRS: Yes 29, No 1, Partially 2, No Comment 5 (Total 37)
- PR 1.27 Consistency in the application of the sum-of-costs approach: Yes 23, No 3, Partially 5, No Comment 6 (Total 37)
- PR 1.28 Work-in-progress, transfer of ownership and capital services: Yes 27, No 1, Partially 5, No Comment 4 (Total 37)
- PR 1.29 Clarifications on the treatment of terminal costs during ownership transfer for different types of assets: Yes 25, No 2, Partially 2, No Comment 18 (Total 37)
- PR 1.30 Distinction between maintenance and capital repairs for intangible assets: Yes 29, No 1, Partially 3, No Comment 4 (Total 37)
- PR 1.31 Treatment of the transfer of leased assets at the end of the lease period: Yes 28, No 1, Partially 4, No Comment 4 (Total 37)
- PR 1.36 Treatment of precious metal accounts: Yes 31, No 1, Partially 1, No Comment 4 (Total 37)

### Reasons for partial agreement (high-level themes)
- Practical implementation challenges were the most common rationale for partial agreement across most PRs.
- Conceptual concerns raised most notably for:
  - PR 1.8 Valuation of unlisted equity: worries about negative valuations, valuation consistency, ambiguity in preferred valuation methods (transaction prices vs. market capitalization), and need for guidance on deriving indicative prices.
  - PR 1.17 Debt concessionality: concerns over transparency and recording of concessional loan elements in core GFS.
  - PR 1.27 Sum-of-costs approach: concerns about appropriateness and robustness of including a net return on capital, applicability of a 2% default real rate benchmark, and need for country-specific guidance.

### Next steps and use of feedback
- All feedback, including comments from those who agreed with the Proposed Recommendations, will be carefully considered when advancing each research project and drafting Notices of Decision for the GFSM update.

*Prepared by the Statistics Department, INTERNATIONAL MONETARY FUND for the IMF Government Finance Statistics Advisory Committee meeting in Brasilia, Brazil, May 13–15, 2025 (Paper: GFSAC/2025/05/13A).*

### Section 2

### Summary of responses to Group 2 consultation on GFSM update — Section 2

### PR 1.10 Super dividends and reinvested earnings of public corporations (1)
- Not opposed conceptually but suggest that flexibility should be allowed depending on country circumstances.

### PR 1.17 Debt concessionality (6)
- “While the recommendation encourages supplementary details on the impacts of concessional lending, including imputed capital transfers, the complexity of accurately identifying and reporting these elements could pose significant challenges. Given the practical difficulties in distinguishing between various types of concessional loans and their economic effects, it may be more effective to focus on core reporting requirements rather than introducing additional, potentially burdensome data collection.”
- “I believe that for fiscal analysis, it is important to identify the nature of all loans (not just those to employees) as a sub-item. This is important information when analyzing fiscal accounts and merits more relevance than a mere "memorial item."”
- “The discussion on concessional loans focuses on the interest rate differential between loans at market rates and loans at concessional rates. This approach is limited, because it ignores the impact of concessions in terms of repayment and grace periods. A present value approach could be an option. The differential between the present value of a market loan and the present value of a concessional loan can be calculated, and the differential allocated over the life of the loan.”
- “IPSAS classifies the transfer element of concessional loans as a subsidy. The general government has a lot of concessional loans, so it is important to display the subsidy separately. I wonder if GFS plans to apply IPSAS accounting for concessional loans.”
- “Agree conceptually but note concerns about potential for divergence between GFS and accounting standards and impact on providers... [Accounting standards] report concessional elements as an expense on initial recognition and unwound over the loan term. Also, consideration on expanding scope of recognition of transfer element for concessional loans beyond the specific case of employer loans to employees could reduce the divergence between international accounting standards and GFS and may better reflect the economic reality of concessional loans. More detail on how to apply the memorandum treatments could support consistency of decision making on when to apply those treatments.”
- Not opposed conceptually but suggest that flexibility should be allowed depending on country circumstances.

### PR 1.20 Payments for nonproduced knowledge-based capital (marketing assets) (3)
- “Agree with the conceptual direction of recognizing marketing assets as produced assets, especially to reflect their role in modern economies. However, since the UN Statistical Committee has decided not to incorporate this change in the 2025 SNA and to keep the topic on the research agenda, we suggest that GFS maintains alignment and does not yet implement this recommendation. Premature incorporation could create inconsistencies across macroeconomic frameworks. Further research and practical experience, especially in identifying and valuing government marketing assets, are still needed before integrating this into the GFS manual.”
- “This recommendation was not endorsed in the 2025 SNA. Therefore, we consider it advisable to maintain consistency between the GFS Manual and the updated SNA framework by not incorporating it into the GFSM.”
- “At this point marketing assets and goodwill are recorded under the same code (61442). I do not think this is because they are deemed the same but because both of them jointly are estimated (calculated) as a residual (value of the enterprise minus (value of assets minus value of the liabilities)) when it comes to statistical recording. So, they are now statistically indistinguishable by now, but this occurs as a way to simplify their recording. Then, a move in the right direction, might be to establish a clearer boundary between goodwill and marketing assets, and to split them in two codes (614421 and 614422) which means that, at the very least, GFSM 2014, paras. 7.115-116 should be rewritten. Also, a recommendation should be made on how to estimate the value of marketing assets.”

### PR 1.21 Islamic finance (0)
- Not applicable

### PR 1.25 Relationship between SNA and IPSAS/IFRS (2)
- “We agree with the proposal but note that it appear to focus on IPSAS. In our experience, instances where public corporations are required to apply IFRS rather than IPSAS are not that rare globally, and this should be acknowledged in the GFSM.”
- Not opposed conceptually but suggest waiting for the conclusion of GFSM Research Project 2.27.

### PR 1.27 Consistency in the application of the sum-of-costs approach (5)
- “Depreciation (consumption of fixed capital) does not apply on inventories, so it will be difficult to apply the methodology described in para. 4.c to these nonfinancial assets.”
- “On the whole, we agree with the 2025 SNA approach. We had practical reservations around a specific rate being prescribed in a statistical standard at the time of the SNA consultation, noting how infrequently these standards are updated. As long as the GFSM language permits deviating from the rate where strong rationale exist, we endorse the proposal. With regards to the market test implications, we acknowledge the potential this change may have on some types of public units, notably infrastructure companies. We would find further research helpful but not essential in our national context, where the fiscal framework covers public sector as a whole.”
- “The benefits of applying a return on capital to non-market production, as introduced in the 2025 SNA, must outweigh the disadvantages of the method. This fact is questionable. The approach relies on assumptions that may not reflect local realities, introduces complexity, and could distort macroeconomic aggregates like GDP or national savings. While it seeks to enhance international comparability, the potential for inaccuracies and the added methodological burdens call into question its overall effectiveness.”
- Not opposed to the proposal but highlight the need for very clear guidance on the rate of return on capital and the value of nonfinancial assets used in production to ensure international comparability. Also suggest there is an opportunity to clarify the application of the market test given the inclusion of the return on capital.
- “Agree conceptually but note concerns about measurement issues, potential for divergence between GFS and accounting standards, and impact on providers. We note that the revisions to the definition of production costs may lead to an increase in costs and therefore may impact sector classifications due to the market/non-market test....This has the potential to create further estimation issues or burden on data providers as currently they do not incorporate a net return to capital in the valuation of own-account fixed assets.”

### PR 1.28 Work-in-progress, transfer of ownership and capital services (5)
- “Agree conceptually but note concerns about measurement issues, potential for divergence between GFS and accounting policy, and impact on providers.”
- “Agree in principle but it is hard to see how this can be implemented in practice. In reality work in progress values consist of many projects contracted to multiple providers, all starting and finishing at different times. The problem is, source data relating to these projects is bundled up so no information is available on them separately. As a result, it is impossible to know about timing of ownership change or valuation of each asset type within each project. We would imagine therefore, that in most cases we will need to adopt an approach where a contract of sale exists and regular ownership transfers are made from the work in progress "pool". We believe too that the producer will typically be recording stage/progress payments as part of their output and value added, so we need to maintain consistency.”
- “The manual should cover this topic in more detail, especially work-in-progress related to cultivated biological resources.”
- Not opposed conceptually but suggest that flexibility should be allowed depending on country circumstances.
- Note challenges in sourcing the data in order to correctly record the transactions.

### PR 1.29 Clarifications on the treatment of terminal costs during ownership transfer for different types of assets (2)
- Agree conceptually, but likely challenges in estimating the terminal costs.
- Agree conceptually, but notes “that it would be more useful if the upcoming manual contained detailed information on this issue”.

### PR 1.30 Distinction between maintenance and capital repairs for intangible assets (3)
- Agree in principle, however, “with government data largely coming from administrative sources, we are not sure how practical or implementable the proposal is unless it is sufficiently aligned with IPSAS/IFRS treatment”.
- Agree conceptually, but notes that the Handbook on Measuring Data recognizes difficulties in separating intermediate consumption from fixed capital formation and recommends that where no separation can be made then the default treatment should be to record as a capital transaction. As such, it is suggested to ensure GFSM consistency with the Handbook on Measuring Data.
- No rationale provided.

### PR 1.31 Treatment of the transfer of leased assets at the end of the lease period (4)
- Not opposed conceptually but suggest that additional guidance on applying the concept should be provided in the GFSM.
- Not opposed conceptually but suggest that flexibility should be allowed depending on country circumstances.
- “Agree conceptually but note concerns about measurement issues, ongoing divergence between GFS and accounting policy, and impact on providers. We expect significance challenges with measurement/estimation of future asset value particularly for assets with a long-life span at future point of transfer.”
- “We are content with the proposed text to the point that the source data supports this treatment, for example in the case of large individual public-private partnerships and other large single infrastructure assets.”

### PR 1.36 Treatment of precious metal accounts (1)
- Not opposed conceptually but note the compilation challenges in valuing precious metals.

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_Source: https://www.imf.org/-/media/files/data/statistics/gfsm/global-consultations/group-2/summary-of-responses-to-group2-consultation-on-gfsm-update-prs.pdf_