Inconsistency between the definition of "accumulated impairment" in paragraphs 46 and 161

Does the definition of "accumulated impairment" includes only allowances as defined in paragraph 46 of Annex V (i.e. FINREP instructions) or both allowances and write-offs taken to Income Statement, as defined in paragraph 161 of the document EBA FINAL draft Implementing Technical Standards On Supervisory reporting on forbearance and non-performing exposures under article 99(4) of Regulation (EU) No 575/2013

Paragraph 161: “Accumulated impairment” and “accumulated changes in fair value due to credit risk” figures shall be reported in accordance with paragraph 46. “Accumulated impairment” means the reduction in the carrying amount either directly or through use of an allowance account. “Accumulated impairment” figures reported for nonperforming exposures shall not include incurred but not reported losses. Incurred but not reported losses shall be reported in “accumulated impairment” figures for performing exposures. Paragraph 46: [..]. “Accumulated impairment” shall include specific allowances for individually and collectively assessed financial assets as defined in paragraphs 36 and 37as well as “Collective allowances for incurred but not reported losses” as defined in paragraph 38 but do not include “Accumulated write-offs” amounts as defined in paragraph 49 of this Part. The definition of “accumulated impairment” in paragraph 161 and 46 are inconsistent because the first (i.e. paragraph 161) states that “accumulated impairment” includes both allowance accounts and write-offs recognized directly through income statement. While paragraph 46 states that write-offs are not included in the definition of “accumulated impairment”. Depending on which definition is used the reported numbers vary considerably. See following fact pattern: E.g. a loan granted by Bank A with notional amount equal to 100EUR have been tested for impairment as of 30-06-2013. Bank A assesses that there is objective evidence of impairment and provisions the loan for a total of 20 EUR through use of allowance account. As of 31-Dec-2013 the bank assesses that the loss on the loan is permanent and assesses the total loss to be equal to 30 EUR. Bank A, hence, writes-off the loan for a total of 30 EUR, of which 20 EUR are taken against allowance account previously used and 10 EUR against Income Statement. According to paragraph 161, the accumulated impairment is 30 EUR. According to paragraph 46, the accumulated impairment is zero (i.e. allowance account is zero).