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IFRS Adoption: The China Experience
By Richard Meyer — September 3, 2008
he United States isn’t the only economic superpower finally lurching into
the global accounting age. On the other side of the world, China is doing
much the same.
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Like many nations, China is adopting International Financial Reporting
Standards with considerable enthusiasm—and like many nations, is doing
so by issuing its own national interpretation of IFRS, rather than using
the “pure” standards published by the International Accounting
Standards Board in Brussels.
For the most part, the differences between IFRS and China’s home-grown
standards—the Accounting Standards for Business Enterprises, issued by
the Ministry of Finance in February 2006—are less than dramatic. Shortly
after the arrival of ASBE two years ago, Deloitte issued a document
outlining the differences between it and IFRS, which ran all of 50 pages.
Most of those 50 pages are filled with run-of-the-mill details: a few
technical differences in accounting for stock options, some quibbles
about how to expense the costs for securing construction contracts, and
other minor departures from IFRS.
But ASBE veers away from IFRS significantly in at least one area:
disclosure of related parties. IFRS generally requires related-party
transactions to be disclosed. In China, however, so many companies are
state-owned—and therefore related—that disclosing them all would leave
the footnotes to a financial statement hundreds of pages long.
As a result, under Chinese accounting rules, state control does not
necessarily trigger related-party disclosures.
“They are not a market economy in the same sense as the Western
economies are, so they have made slight alterations,” says
Stephen Taylor, a partner at Deloitte. “Chinese accounting
standards say that you are not related just because you are a
Taylor
state-controlled entity; you have to have influence „ Just
because you are a state-controlled entity, it doesn’t mean another
state-controlled entity can necessarily influence you.”
Taylor is quick to note that this provision makes some sense. The state
is so pervasive in China, he says, that it’s tough to buy plane tickets
or purchase office supplies without dealing with the government. If you
too are a state-controlled entity—and if you’re a Chinese business of
any size or import, there’s a fair chance that you are—you might end
up churning out reams of paperwork to disclose something not all that
useful.
IASB Efforts
Indeed, China’s stance about state-owned entities has struck so many as
a fair point that the International Accounting Standards Board is
considering revising its own standards for related-party transactions to
bring them closer to China’s line of thinking. The organization issued
an exposure draft in February 2007 that broached reducing the disclosure
requirements for entities that are related only because they are state
owned, and IASB plans to decide on the matter by the end of the year.
“What convergence means is that China will not just move toward
international standards. In some circumstances that might mean the IASB
moving closer to the [China] alternative,” says Taylor.
According to IASB, the proposed change sprung from routine discussions
with the Chinese rather than any concerted lobbying from Chinese
authorities. IASB also believes that a change in the standard will not
hinder reform in China by obscuring or protecting state involvement in
the economy. Rather, IASB spokesmen say, it will promote better accounting
practices in China and may actually help investors and non-Chinese
regulators get a better sense of what’s going on.
“We had a genuine concern that if you disclose so many parties as related
parties, you’ll get hundreds of pages of disclosure and the real related
parties will be masked,” says Alain Teixeira, director of technical
activities at IASB.
ASBE NO IFRS
Although the ASBEs are substantially in line with IFRSs, there are still some differences between
the ASBEs and IFRSs. Some of the key differences are:
ASBE 4 and ASBE 6 only allow the cost model for measurement of fixed assets and
intangible assets, while IAS 16 allows a revaluation model.
Under the ASBEs, land use rights are normally classified as intangible assets and not as
operating leases. Where the land use rights meet the criteria to be accounted for as an
investment property, the accounting is not restricted to the fair value model as in IAS 40.
The cost model may be used.
For jointly controlled entities, ASBE 2 only allows the equity method of accounting. IAS
31 also allows proportionate consolidation.
ASBE 8 prohibits the reversal of all impairment losses where IAS 36 only prohibits the
reversal of the impairment of goodwill.
Borrowing costs meeting the capitalization criteria should be capitalized. However, IAS
23 gives an option to expense all borrowing costs.
State-controlled entities are not regarded as related parties simply because they are
state-controlled. There is no exemption for state-controlled entities under IAS 24.
Biological assets shall be measured using the cost model unless there is evidence of a
reliable fair value under ASBE 5. This is in direct contrast to IAS 41 which requires fair
value to be used unless it is clearly unreliable.
Unlike IFRS 3, ASBE 20 includes and addresses within its scope business combinations
involving entities under common control. However, ASBE 20 does not cover reverse
acquisitions.
For presentation purposes, the ASBEs restrict certain options available under IFRSs, for
example, expenses shall be analysed by function for income statement presentation
purposes, the direct method is required for cash flow statements and only the gross
presentation is allowed for government grants related to assets.
Source
Comparing IFRS With Chinese Standards.
The more complex challenge for IASB will be to specify exactly what related-party transactions
should be disclosed. The Board plans to discuss the matter in September and may ask for more
comments after that.
“It is a big issue,” says Andrew Conway, deputy CEO of the
National Institute of Accountants in Australia.
“Related-party transactions are disclosed for a reason,
disclosed because the market needs to know that there are
Conway
potential conflicts. How this plays out will be interesting to
watch.”
According to Conway, the key to IFRS is its brand and credibility; the
standards will only be as good as the market perceives them to be. If IFRS
incorporates too many compromises for individual nations and those
compromises make it difficult to understand a company’s accounting or
to compare financial statements between nations, IFRS will lose its value.
China’s IFRS Challenges
China also faces some practical problems related to IFRS adoption. The
nation set a lightning-fast adoption schedule, formally announcing in
early 2006 that all listed Chinese companies had to comply with IFRS by
the start of 2007. By contrast, the United States is just now hoping to
adopt IFRS by 2016; most countries give themselves three or four years
to ease into the IFRS world. According to some Chinese accountants, China
got ahead of itself.
“After the publication of IFRS in China, it was implemented soon,” says
John Liu, a partner at Shanghai J&J Certified Public Accountants Firm.
“There was no time for the CPAs to master it. For the Big 4, it’s no
problem at all. But for the other CPA firms in China, I still think it
is a big problem.”
Liu says that good texts covering and analyzing China’s IFRS are rare,
and even the regulations themselves can be unclear; sometimes he has to
consult the original English version of the standard to figure out what
the Chinese version is trying to say. Liu notes, however, that nobody
really knows whether the first batch of companies reporting under IFRS
succeeded. Chinese regulators are currently going through the books of
these firms, and probably won’t finish their inspections for several
months
“China had less than one year to complete the harmonization procedures,
which is quite different from most Western countries,” says Zhang Ying,
a PhD candidate doing research on China and IFRS at the University of
Wollongong in Australia. “I think the accountants or the companies must
do what the government requires, but the reality is that they have no idea
what is in IFRS. When I read articles in the Chinese media and see how
people interpret the rules, I find some errors very obvious to me.”
The transition was certainly not as difficult as it could have been. China
has been trying to bring its accounting standards into line with
international norms for a decade, and some Chinese companies have long
had “H” or “B” shares that are listed in Hong Kong and priced in dollars.
Another helpful break: Most Chinese companies are exempt from filing in
IFRS because they are small or private companies (although official policy
is to encourage them to use IFRS anyway).
The government insists that everything is proceeding well. It
acknowledges that small companies and small accounting firms may find IFRS
challenging, and believes that fair value could be an issue in China due
to the lack of good data on some investments and the lack of trading in
others. Overall, however, Beijing is pleased.
“We have been implementing the standard for about one year, and the
results are quite satisfactory,” says Wang Jianxin, vice director of the
Accounting Research Office at the Ministry of Finance. “The transition
to IFRS has been very smooth.”
“Of course, in implementing such a standard in a very huge and broad
country, and with so many different levels of enterprises, there will be
some problems,” he says. “But I have to say that we have to believe in
our government and in the hard work and diligent spirit of out accountants.
They will master the standard.”
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