IFRS in China, or China in IFRS?
I was brought up on western business practices and financial reporting standards. Now I work in China
and have begun to understand the differences between Chinese business and accounting culture and
that of Western countries. I suggest that international standards such as IFRS may need adaptation to
suit the Chinese environment, that China has a fresh perspective to bring to IFRS and that this wil be
not only for its own benefit but also for the benefit of al users of IFRS. Business practices are a function of the society in which they are based and as Chinese society differs
in several important ways from western society, so business practices also differ in some important
ways. However, IFRS were developed in the context of western business practices and so do not
always accommodate wel business practices rooted in a different culture. In general, Chinese people place more importance on personal relationships than on contract terms.
This has been pointed out in numerous articles alerting westerners to the importance of ensuring that
they have a real rapport and understanding with their business counterparts in China and of not
assuming that a contract wil always be fol owed to the letter. I do not contend that one way is better or
worse than the other, just that they are different and that assuming that the western, contract-based
model of doing business wil work equal y wel in China can lead to misunderstanding, frustration and
disappointment. It is common to find that what happens in practice is out of line with what the contract says. Chinese
management wil often say that what they have agreed informal y with their business partners is more
important than what the contract says. In the west, the relationship provides the context but the
contract determines what happens in practice. By contrast, in China, the contract provides the context
but what happens in practice is determined by the relationship. While IFRS contain the notion of
‘substance over form’ (i.e. one should try to portray the economic substance of transactions, not just
their legal form), in many details IFRS take a narrow view of legal and constructive obligations, and
often cannot reflect the depth and sophistication of Chinese personal and business relationships. A simple example would be the col ection of receivables. While the contract may say that payment is
due in 30 days, it is common to find amounts owing for a year or more. The debtor and creditor may
wel have a tacit understanding, not reflected in the contract, that payment wil be made when the
debtor has sufficient funds and that the creditor wil not press for payment before that. IFRS require
that receivables be recognised initial y at fair value, which would be the discounted present value of
the expected cash flows. Consequently, a debt that wil only be received in a year’s time is worth less
than face value. Sales revenue would be the lower amount and the remaining income would be
recognised as interest receivable during the fol owing year. However, it is not usual to discount the
receivable in a sales transaction, because the contract says that the debt is due in 30 days. Thus, the
total amount of cash that wil eventual y be received is often recognised at the time of sale. The
principles of IFRS (IAS 39 and IAS 18) in this case are appropriate but in practice IFRS are not easy
to apply when the expected settlement date is open-ended. Related parties are another area where IFRS do not recognise the sophistication of business
relationships in China. The stated objective of IAS 24 is to:
‘draw attention to the possibility that its financial position and profit or loss may have been
affected by the existence of related parties and by transactions and outstanding balances with
In China, you would hardly consider doing business with somebody without some kind of relationship.
However, these are personal relationships built on trust and a sense of honour, rather than on
prescribed connections between the parties, such as share ownership, family relationships, etc. Very
few of the many relationships that have a significant effect on the terms of business meet the
definitions in IAS 24, so financial reporting does not draw attention to the possibility described in the
objective, let alone tel you what the results might have been without that relationship. IFRS also assume that companies enter into transactions (or series of linked transactions) so as to
maximise their economic benefits from the transaction(s). The problem is that in China the advantage
to a company from entering into a transaction wil often come in an unspecified way at an unspecified
future date. It is therefore impossible to link the costs and the benefits when accounting for a (series
For example, it is not uncommon for Chinese companies to guarantee other, ‘unrelated’ companies’
bank borrowings, sometimes on a reciprocal basis, sometimes not. This results in the beneficiary of
the guarantee being able to obtain bank financing at a lower interest rate than it otherwise could or
even to obtain financing that it could not obtain without the guarantee. However, the giver of the
guarantee may not be paid or receive any immediate or identifiably related benefit. Perhaps, for
example, it is just that the other company wil put in a good word for it when, in future, it seeks to
obtain land use rights to build a new factory. IAS 39 treats this as a financial guarantee contract, requiring the giver of the guarantee to account for
the obligation at fair value. This can be a material figure and wil vary over time depending on the
credit-worthiness of the borrower, prevailing interest rates, etc. The giver of the guarantee wil
general y not be able to take account of the ‘favour’ it has built up for the future, because the nature of
the benefit is general y so undefined that it would not meet the recognition criteria for an asset. The
transaction thus has to be accounted for as a one-sided and disadvantageous one under IFRS, when
in reality the company may have done itself a net favour by giving the guarantee. IFRS are not good at
accounting for ‘gu nxì’ (which literal y translates as ‘connections’ or ‘relationship’ but commonly
indicates a debt of honour). This can represent a huge difference between two otherwise similar
companies. China’s new accounting standards, which are effective for years beginning on or after 1 January 2007,
are based closely on IFRS. There are some differences, both at the detailed level and at the
conceptual level. However, they import the fundamentals of IFRS largely intact. In the past, a lot of inward investment into China was through foreign parent companies, who told their
subsidiaries or joint ventures how to do financial reporting. Many Chinese companies just did what
their foreign parents told them to do in terms of reporting and thus were not too concerned about what
IFRS said. Now the trend is for Chinese companies to expand on their own, using foreign equity, so
they are having to make their own decisions about accounting policies and methods. This gives them
a much greater interest in financial reporting in general and IFRS in particular. Financial reporting
matters more to them now. Now that Chinese companies have a more direct interest in what IFRS say, I hope they wil speak out
when those standards make assumptions that do not hold in China or when IFRS fail to reflect the ful
sophistication of Chinese business practices. That way, IFRS wil be improved not only for the benefit
of Chinese preparers and users of financial statements but for other preparers and users worldwide.
By Tony Upson, PKF Beijing. This article first appeared in Practical China Tax and Finance Strategies, published by WorldTrade Executive. For more information go to http://www.wtexec.com/tax.html
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