SEC Comment Letter for GSK (GSK) — Jan 18, 2007
GSK plc
Date: Jan. 18, 2007 · CIK: 0001131399 · Accession: 0000000000-07-002635
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Via Facsimile and U.S. Mail Mail Stop 6010 January 18, 2007 Mr. JP Garnier Chief Executive Officer GlaxoSmithKline plc 980 Great West Road Brentford, Middlesex TW8 9GS England Re: GlaxoSmithKline plc Form 20-F for Fiscal Year Ended December 31, 2005 Filed March 3, 2006 File No. 1-15170 Dear Mr. Garnier: We have reviewed your October 20, 2006 response to our September 19, 2006 letter and have the following comment.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. We have read your response to prior co mment 1. Paragraph 20 of IAS 7 states that “Under the indirect method, the net cash flow from operating activities is determined by adjusting profit or loss”. We acknowledge that profit or loss is not specifically defined in IAS 7. The guidan ce in IAS 8 directs management to refer to the requirements and guidance in sta ndards dealing with similar and related issues in the absence of a standard that specifically applies. As management made their determinations as to what was meant by “profit or loss” in the context of IAS 7, it is unclear to us why consider ation would not have been given to the definition of profit and loss found in IAS 1. It is also unclear, based upon your response, why you believe it is not appropria te to use the definition in IAS 1, and instead believe that a more appropriat e presentation would use a measure that excludes certain items of income and expense. Please confirm to us that in future filings, you will revise your presentation to start with net profit or loss, or if
Mr. JP Garnier GlaxoSmithKline plc January 18, 2007 Page 2 applicable, net profit or loss attribut able to continuing operations, with retrospective application to all periods presented. We would not object if the presentation begins with profit before taxation.
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furn ish your response via EDGAR under the form type label CORRESP that keys your respons es to our comment and provides any requested information. Detailed letters grea tly facilitate our revi ew. Please understand that we may have additional comments afte r reviewing your response to our comment. You may contact Lisa Vanjoske, Assist ant Chief Accountant, at 202-551-3614 if you have questions regarding the comment. In th is regard, do not hesitate to contact me, at (202) 551-3679.
S i n c e r e l y , Jim B. Rosenberg Senior Assistant Chief Accountant
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Via Facsimile and U.S. Mail Mail Stop 6010 January 18, 2007 Mr. JP Garnier Chief Executive Officer GlaxoSmithKline plc 980 Great West Road Brentford, Middlesex TW8 9GS England Re: GlaxoSmithKline plc
Form 20-F for Fiscal Year Ended December 31, 2005
Filed March 3, 2006 File No. 1-15170 Dear Mr. Garnier:
We have reviewed your October 20, 2006 response to our September 19, 2006
letter and have the following comment.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. We have read your response to prior co mment 1. Paragraph 20 of IAS 7 states
that “Under the indirect method, the net cash flow from operating activities is
determined by adjusting profit or loss”. We acknowledge that profit or loss is not
specifically defined in IAS 7. The guidan ce in IAS 8 directs management to refer
to the requirements and guidance in sta ndards dealing with similar and related
issues in the absence of a standard that specifically applies. As management
made their determinations as to what was meant by “profit or loss” in the context of IAS 7, it is unclear to us why consider ation would not have been given to the
definition of profit and loss found in IAS 1. It is also unclear, based upon your
response, why you believe it is not appropria te to use the definition in IAS 1, and
instead believe that a more appropriat e presentation would use a measure that
excludes certain items of income and expense. Please confirm to us that in future
filings, you will revise your presentation to start with net profit or loss, or if
Mr. JP Garnier
GlaxoSmithKline plc January 18, 2007 Page 2
applicable, net profit or loss attribut able to continuing operations, with
retrospective application to all periods presented. We would not object if the
presentation begins with profit before taxation.
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furn ish your response via EDGAR under the form
type label CORRESP that keys your respons es to our comment and provides any
requested information. Detailed letters grea tly facilitate our revi ew. Please understand
that we may have additional comments afte r reviewing your response to our comment.
You may contact Lisa Vanjoske, Assist ant Chief Accountant, at 202-551-3614 if
you have questions regarding the comment. In th is regard, do not hesitate to contact me,
at (202) 551-3679.
S i n c e r e l y ,
Jim B. Rosenberg
Senior Assistant Chief Accountant