Understanding China’s Accounting Practice: Chinese GAAP vs. China’s Tax System

By HeTing Gan
Financial Specialist, Dezan Shira & Associates

One of the most challenging tasks for foreign investors in China is to fully understand the financial statements prepared for their entities. Multinational corporate groups would normally carry out reconciliations between Chinese GAAP and International Financial Reporting Standards (IFRS) or U.S. GAAP for the purpose of consolidation of financial statements on a group level. While it is important to make sure that the accounting practice in China follows China’s GAAP, investors also need to note that discrepancies may surface as a result of the tensions between Chinese GAAP standards and  the practical realities of dealing with China’s tax system, especially when it comes to accounting practice. In this article, we walk investors through the accounting practice in China, as well as explain the differences between China’s tax system and Chinese GAAP.

When performing accounting bookkeeping and reporting functions, a commonly observed accounting practice adopted by many China’s accounting professionals is to prioritize the management of China’s value-added tax (VAT) and fapiao system. A special VAT “fapiao” is physical tax receipt that can be used as a credit against outstanding VAT liabilities. Since these fapiaos effectively serve as a form of cash, routine accounting practices are heavily inclined towards prioritizing the issuing and receiving of special VAT fapiao and, in general to administering the VAT and fapiao system instead of the theoretical accounting standards. However, as result, given that all the companies in China are required to prepare financial reports at the end of each year based on Chinese GAAP, accounting professionals may need to make accounting adjusting entries during the annual audit for annual compliance purpose. 

So what leads to the discrepancy that may require adjusting? While Chinese GAAP prescribes that the appropriate time to recognize sales revenue and cost of sales is when sufficiently all the risks and rewards associated with the product (inventory) have been transferred to the buyer, from a practical perspective, however, it is much easier for an accountant to confirm whether a special VAT fapiao has been issued or received, because the transfer from one party to another of the near cash value of a special VAT fapiao is usually a much stronger indicator to Chinese business persons that a transaction has truly been finalized. In this case, there’s no need for accountants to make professional judgment in deciding whether the risks and rewards of goods have been transferred to the buyer. This often leads to accountants to focus on the issuing or receiving of special VAT fapiao in deciding whether a transaction should be recorded in the books, with little or minimum reference to the more theoretically revenue recognition criteria prescribed in Chinese GAAP.

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To illustrate these, we have designed the following case study.

Scenario: 

B is a trading company registered in China who has sold a batch of products at the end of June and has delivered the products to the buyers. The buyers required the goods to be delivered to the designated locations without the necessary document to prove that they have received the goods (e.g. fapiao, delivery notice and receiving notes). Thus, B’s accountant looks to the actual issuance of the special VAT fapiao as the most obvious moment for the recognition of sales revenue and cost of sales to July (the following month), which effectively defers the profit and tax payable to the following month.

The above practice has its advantages and disadvantages. On the one hand, such practice could easily be regarded as inconsistent with Chinese GAAP standards and could lead to distorting of the reported profit and tax payable in a given month by failing to reflect the underlying economic transaction in a timely manner. On the other hand, from a practical perspective, the qualitative characteristics of financial statements such as “reliability” and “verifiability” of the occurrence of a transaction could be relatively easily confirmed by checking whether the corresponding special VAT fapiao has been issued or received. Lastly from a tax obligation and cash flow perspective, deferring the issuance of fapiao will allow companies to pay VAT and other relevant tax in the next month, which is attractive when considering the impact on cash flow.

Therefore in order for foreign investors to better understand how accounting bookkeeping and reporting is practiced in China, one should take a more holistic view of the accounting environment, which includes considering Chinese GAAP standards as well as how the VAT and fapiao systems affect accounting practices.

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