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1、國際會計準(zhǔn)則與中國準(zhǔn)則差異(英文版)our mission: to help our clients and our people excel this guide is one of a series of publications intended to assist users in understanding international accounting standards. these include: international 3rd edition. written by deloitte & accounting standards: touche, un
2、ited kingdom. published a guide to preparing by abg professional information: accounts .abgweb4>>. international 2nd edition. model financial accounting standards - statements and presentation and a practical guide to disclosure checklists prepared under financial reporting ias. published by d
3、eloitte touche tohmatsu. ias in your pocket 2nd edition. an 80-page pocket-sized guide with summaries of all iasb standards and interpretations, updates on agenda projects, and other useful iasb-related information. ias plus newsletter a quarterly newsletter on recent developments in international a
4、ccounting standards and accounting updates for individual countries. to subscribe visit our ias plus website. .iasplus> our ias plus website provides up-to-date news on ias developments as well as summaries of ifrs and interpretations and reference materials for download. financial instruments re
5、lated summaries, guidance, applying ias 32 and examples, and us gaap ias 39 comparisons. published by deloitte touche tohmatsu. gaap differences in this 20-page booklet identifies and your pocket: ias and explains 81 differences between us gaap international financial reporting standards and us gaap
6、. ? 2002 deloitte touche tohmatsu. all rights reserved. printed in hong kong. hk052-02 the information in this publication is written in general terms. it is intended as a guide only and the application of its contents to specific situations will depend on the particular circumstances involved. it c
7、annot be applied to a specific situation without appropriate professional advice. accordingly, we recommend that readers seek such professional advice regarding their particular circumstances. this publication should not be relied on as a substitute for such professional advice. all offices of deloi
8、tte touche tohmatsu would be pleased to advise you. while all reasonable care has been taken in the preparation of this publication, neither deloitte touche tohmatsu, nor any of its offices, partners or employees, accept any responsibility for any errors it might contain, whether caused by negligenc
9、e or otherwise, or for any loss, howsoever caused, incurred by any person as a result of relying on it. foreword foreword what is prc gaap? separate document of supporting implementation generally accepted aguidance. ccounting principles (gaap) in the peoples republic of china (prc) come from a ? th
10、e mof has recently developed two comprehensive accounting systems, one that is now number of sources, most notably the law, the ministry of finance (mof), and, for listed company disclosures, applicable to foreign investment enterprises and joint stock limited enterprises (including listed the china
11、 securities regulatory commission (csrc). enterprises) and the other applicable to foreign the law investment financial institutions and listed financial institutions. the accounting law of the prc (last revised as of 1 july 2000) is the highest authority on accounting in ? the mof has developed fro
12、m 1993 various china. it sets out general principles of accounting for industry-specific accounting systems, such as those for agriculture, communication, and transportation, all enterprises, including a definition of the nature and role of accounting and basic principles. it empowers and systems th
13、at apply to different types of unlisted financial institutions. the prc ministry of finance to administer accounting affairs and to establish uniform accounting regulations ? from time to time, the mof also develops ad hoc and systems. such regulations and systems have the regulations. force of law.
14、 chinese accounting standards (cas). the mof has been working to develop a body of chinese accounting in 2000, the state council issued financial accounting and reporting rules for enterprises (farr). it focuses standards that are broadly in line with international on such financial accounting and r
15、eporting matters as accounting standards (ias). the mof issued its first bookkeeping, preparation of financial statements, and standard in 1997. to date, 16 standards have been adopted and others are under active development. reporting practices. it applies to all enterprises other than very small o
16、nes that do not raise funds externally. deloitte touche tohmatsu has served as the advisor to the mof in its project to develop cas. ministry of finance (mof) a complete list of cas is set out in the table on the pursuant to its mandate under the accounting law, the next page. the table identifies t
17、he category of mof has issued various accounting regulations that enterprises to which each standard applies. apply to different categories of enterprises in china: accounting system for business enterprises. in ? in 1993, the mof adopted the accounting january 2001, the mof adopted a comprehensive
18、standard for business enterprises (basic accounting system for business enterprises (the standard), which serves as the conceptual system). the system is based, in part, on the framework of accounting in china. however, experience of the mof in implementing the accounting many definitions and concep
19、ts included therein system for joint stock limited enterprises and, in part, have been revised or updated by subsequent on the existing individual cas issued in the past few pronouncements such as the farr. years. ? the mof has adopted a series of chinese accounting standards (cas), in each case wit
20、h a foreword foreword applicability to joint stock limited enterprises. starting accounting effective applicability standard date1 january 2001, all joint stock limited enterprises (jsles) were required to follow the system other than 1 disclosure of related 1 jan. 1997 listed enterprises party rela
21、tionships and enterprises in banking, insurance, and other specialised transactions financial industries (for which a separate accounting 2system has been adopted see below). cash flow statements 1 jan. 2001 all enterprises (minor revision in 2001) when the system became effective on 1 january 2001,
22、 3 events occurring after the 1 jan. 1998 listed enterprises balance sheet datethe old accounting system for jsles was abolished. starting in 2001, also, enterprises other than jsles 4 debt restructuring 1 jan. 2001 all enterprises (revised significantly in have been encouraged to follow the system
23、as well, 2001) with the proviso that state-owned enterprises require 5prior approval from the relevant government authority. revenue 1 jan. 1999 listed enterprises 6 investments (minor in addition, if a parent company adopts the system, the 1 jan. 2001 joint stock limited revision in 2001) enterpris
24、es (prior to parent should require its subsidiaries to adopt the 1 january 2001 it system as well. was listed enterprises only) applicability to foreign investment enterprises. as of 1 7 construction contracts 1 jan. 1999 listed enterprises january 2002, the mof extended the applicability of the sys
25、tem to all foreign investment enterprises again 8 changes in accounting 1 jan. 2001 all enterprises (prior policies and estimates and to 1 january 2001 it other than banks, insurance companies, and other corrections of accounting was listed errors (minor revision in financial enterprises. enterprise
26、s only) 2001) applicability to financial institutions. early in 2002, 9 non-monetary 1 jan. 2001 all enterprises the mof issued a new separate though similar transactions (revised significantly in 2001)accounting system for financial institutions. it must be applied, starting 1 january 2002, by all
27、listed and 10 contingencies 1 july 2000 all enterprises foreign investment banks, insurance companies, 11 intangible assets 1 jan. 2001 joint stock limited brokerages, leasing companies, and finance companies. enterprises unlisted financial institutions that are joint stock limited 12 borrowing cost
28、s 1 jan. 2001 all enterprises enterprises are encouraged to follow the new system. 13 leases 1 jan. 2001 all enterprises other unlisted financial institutions should continue to 14use the old accounting systems for financial interim financial reporting 1 jan. 2002 listed enterprises institutions. 15
29、 inventories 1 jan. 2002 joint stock limited enterprises the accounting system for financial institutions is 16 fixed assets 1 jan. 2002 joint stock limited similar to the one for general business enterprises but, enterprises in addition, includes principles specific to financial institutions, such
30、as how to recognise interest; repurchase agreements; securities transactions; foreword foreword insurance reserves; accounting by trusts; and accounting be stated at cost or at revalued amounts under ifrs by investment funds. whereas cas generally require cost basis. china securities regulatory comm
31、ission? areas such as hyperinflation where the mof has not developed a cas because of limited the csrc has adopted various regulations for application in china. presentation and disclosure of information by listed ? areas where the mof is currently developing new enterprises. these generally do not
32、address matters of standards. the mof has an ongoing programme to accounting recognition and measurement. issue standards that deal with areas specifically convergenceaddressed by ifrs. ? in the light of chinas evolving market economy the primary focus of the iasb is convergence of and developing ac
33、counting profession and the accounting standards worldwide. to facilitate practical circumstances of chinese enterprises, the convergence of accounting standards, the iasb has mof has not adopted certain accounting seven members who serve as official liaisons to national conventions applied in the i
34、frs, notably the standard-setters. countries with formal liaisons are pervasive use of fair value. the mofs approach australia (including new zealand), canada, france, is to establish a set of cas suitable to chinas germany, japan, the united kingdom, and the united circumstances, while striving tow
35、ard convergence states. with ifrs in an orderly manner. in addition, iasb maintains liaison with other key this publication countries through the international accounting standards advisory council (sac). madam feng this publication summarises some of the differences shuping, assistant minister, prc
36、 ministry of finance, between ifrs and prc gaap. for this purpose, we include in prc gaap mainly the requirements of the is a member of the sac. law, cas, the accounting systems for business given the circumstances of individual countries, enterprises and for financial institutions developed by diff
37、erences currently exist between national standards the mof, and the regulations of the csrc. and ifrs. for instance, our firms recently-published comparison of ias and us gaap identified over 80 therefore, the focus of this booklet is on gaap differences. the mof supports international applicable to
38、 listed enterprises, other joint stock limited enterprises, and foreign investment enterprises. accounting harmonisation and is working to achieve convergence of cas with ifrs by giving due deloitte touche tohmatsu consideration of ifrs in the process of drafting each cas.ken wild, global leader int
39、ernational accounting standards circumstances where differences arise between cas and ifrs include:stephen taylor, leader ias centre of excellence hong kong ? areas where ifrs allow choices but cas do not. for instance, property, plant, and equipment may september 2002 comparison of ifrs and prc gaa
40、p comparison of ifrs and prc gaap ias topic ifrs prc gaap 1 classifications of assets either are assets must be the following table sets out some of the differences between assets in the not classified or are classified into international financial reporting standards (ifrs) and gaap balance sheet c
41、lassified into current assets, in the peoples republic of china. the significance of these current and long-term differences and others not included in this list will vary with noncurrent.1 investments, fixed respect to individual companies depending on such factors as assets, intangible the nature
42、of the companys operations, the industry in which it assets, and other operates, and the accounting policy choices it has made. assets. reference to the underlying accounting standards and any relevant national regulations is essential in understanding the 1 classifications of liabilities either are
43、 liabilities must be liabilities in the not classified or are classified into specific differences. balance sheet classified into current and current and noncurrent. noncurrent.1 ias topic ifrs prc gaap 1 classification of classification by classification by expenses in the nature or by function. _
44、general principle-based principle-based approach standards with income function. standards limited application statement accompanied by guidance. detailed application 1 specific line some. many. guidance. items required on the face of _ ability to make some accounting few choices. financial choices
45、choices allowed. statements financial year-not specified. required to be 31 end date december.1 one year required both in required in comparative financial financial 1 complete set of balance sheet, same, plus prior year statements and in statements but not financial income statement, statement of f
46、inancial the notes. in the notes. statements equity statement, allowance for information csrc rules require cash flow impairment, profit listed companies to statement, plus appropriation include certain notes. statement, comparative statement of information in the segmental notes. information. 1 rep
47、orting a permitted, but not prohibited. 1 management encouraged required as part of separate line required.1 discussion and “outside the an enterprises item for “total analysis. financial financial and comprehensive statements”. accounting report, income” but not part of the combining net financial
48、profit or loss and statements. gains or losses charged directly to equity deloitte touche tohmatsu 9 10 deloitte touche tohmatsu comparison of ifrs and prc gaap comparison of ifrs and prc gaap ias topic ifrs prc gaap ias topic ifrs prc gaap 1 departure from permitted in not addressed. 8 non-mandated
49、 may either restate must restate prior a standard “extremely rare” changes in prior financial financial when circumstances “to accounting statements or statements unless compliance achieve a fair policy include as a impracticable. would be presentation”. cumulative effect in misleading net profit an
50、d loss in the current 2 producers may be measured excluded from the financial inventories of at net realisable scope of the cas. statements.1 livestock, value if there is a agricultural and well-established 8 change in change in estimate change in forest products, practice in that depreciation (pros
51、pective). accounting policy and mineral ores industry. method for (restate prior period existing assets financial 7 presenting cash may use either must present both flows from statements). direct method or direct method and operating indirect method. indirect method. 10 dividends non-adjusting adjus
52、ting event. activities declared after event. the end of a 7 classification of may be classified interest paid must financial year interest received as an operating, be classified as a and before the and paid in the investing, or financing activity. financial cash flow financing activity. classificat
53、ion of statements are statement interest received authorised for depends on its issue nature. 11 inclusion of included if the never included. 7 cash flows operating unless always operating. borrowing costs companys policy is relating to they relate to income taxesas costs of to capitalise investing
54、or construction borrowing costs. financing activities. contracts 8 extraordinary rare, generally “abnormal” items items presented limited to are presented separately in the expropriations, separately in the income natural disasters, cash flow statement and acts of war.1 statement. in addition, certa
55、in types of gains and losses must be disclosed as supplementary information. deloitte touche tohmatsu 11 12 deloitte touche tohmatsu comparison of ifrs and prc gaap comparison of ifrs and prc gaap ias topic ifrs prc gaap ias topic ifrs prc gaap 12 method of tax effect may use either (a) 16 property,
56、 plant, measured at fair measured at an accounting for accounting using a tax payable method and equipment value. amount agreed by income taxes balance sheet (deferred taxes not received as a all investing parties. approach recognised) or (b) capital deferred tax assets tax effect contribution from
57、and liabilities accounting using owners recognised for an income differences in the statement 16 exchanges of measured at fair measured at the book and tax bases approach dissimilar fixed value. gain or loss carrying amount of of assets and deferred tax assets assets. is recognised. the asset surren
58、dered. no liabilities. in and liabilities are measuring deferred gain or loss is recognised for taxes, the tax rate differences in recognised. expected at amounts 16 profit or loss on included in presented as a reversal must be recognised in the disposal of fixed operating profit or non-operating ga
59、in used. income statement assets loss. or loss. and on the tax return. in 17 lessee lower of fair value lower of lessors measuring deferred measurement of and present value carrying amount assets acquired of minimum lease and present value taxes, either the current tax rate or by a finance payments. of minimum lease lease and payments. if the expect
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