Công văn xin chuyển hạch toán theo thông tư 200 năm 2024
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Nhằm giải đáp một số nội dung của Thông tư 200/2014/TT-BTC hướng dẫn chế độ kế toán doanh nghiệp (DN), ngày 09/9/2015, Bộ Tài chính ban hành Công văn 12568/BTC-CĐKT. Theo đó, khi thực hiện chế độ kế toán doanh nghiệp theo Thông tư 200 cần phải lưu ý các nội dung sau: - Các DN có hoạt động bán hàng và mua hàng chủ yếu bằng ngoại tệ và thỏa mãn điều kiện sử dụng đồng ngoại tệ làm đồng tiền ghi sổ kế toán thì vẫn có thể được lựa chọn VNĐ làm đồng tiền ghi sổ kế toán mà không bắt buộc phải lựa chọn đồng ngoại tệ. - DN được áp dụng tỷ giá giao dịch thực tế tại ngày 01/01/2015 để chuyển đổi lợi nhuận sau thuế chưa phân phối tại ngày 01/01/2015 trong phần thuyết minh BCTC do năm 2015 là năm đầu tiên áp dụng Thông tư 200 và không có yêu cầu hồi tố về vấn đề này. Ngoài ra, Công văn này cũng giải thích thêm các nội dung về việc ghi nhận doanh thu, giá vốn của các giao dịch mua, bán, điều chỉnh sản phẩm, hàng hóa, dịch vụ nội bộ; thuyết minh giá trị hợp lý và suy giảm giá trị; trích trước khoản giảm trừ doanh thu… Xem chi tiết tại Công văn 12568/BTC-CĐKT ngày 09/9/2015. THE MINISTRY OF FINANCE --- SOCIALIST REPUBLIC OF VIETNAM Independence - Freedom – Happiness --- No. 12568/BTC-CĐKT Re: Clarification of Circular No. 200/2014/TT-BTC Hanoi, September 9, 2015 To: - Deloitte Vietnam Co., Ltd - Ernst & Young Vietnam Co., Ltd - KPMG Vietnam Co., Ltd - PwC Vietnam Co., Ltd The Ministry of Finance hereby responds to the official dispatch from Deloitte, E&Y, KPMG, and PwC dated June 26, 2015. The dispatch requested clarification regarding certain contents specified in Circular No. 200/2014/TT-BTC dated December 22, 2014, which provides guidelines for accounting policies for enterprises. In light of this, the Ministry of Finance provides the following comments: 1. Enterprises that mainly conduct sales and purchases in foreign currencies, and meet the requirements for using foreign currency as the accounting currency, still have the option to choose VND as the accounting currency, without the obligation of selecting a foreign currency. 2. Enterprises are allowed to apply the actual exchange rate on January 1, 2015 to convert undistributed after-tax profits on January 1, 2015 in the notes to the financial statement because 2015 is the first year of implementation of Circular No. 200 and there is no retroactive request on this matter. The conversion of financial statements prepared in foreign currencies into VND is done in the same method as VAS 10 and Circular 161/2007/TT-BTC when converting financial statements of overseas subsidiaries. Attributing conversion difficulties to the accounting software's inability to meet requirements is not valid, as software is merely a supporting tool. When accounting policies change, supporting tools must change with them to ensure proper adherence to the updated policies. It is noted that the above provisions of Circular No. 200 are completely consistent with IAS 21, so enterprises need to convert financial statements according to international practices. 3. Recognition of revenue and cost of intra-company transactions in purchase, sale and transfer of goods and services In addition to Clause 2, Article 8 of Circular No. 200, this matter is also specified at Point e, Clause 3.2, Article 20 as follows: “e) When selling goods or providing services for affiliated units in the enterprise, according to operation and level in every unit, the revenue may be recognized either at the time in which the goods or services are transferred to dependent accounting units or at the time in which the dependent accounting units sell goods or services.” ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. 4. Notes regarding fair value and value decline - Fair value of financial investments When determining the fair value of trading securities for presentation in the notes to the financial statement, the enterprise may use the market value of securities it holds, as outlined in Point c, Clause 1, Article 15 and Point a, Clause 1.2, Article 45 of Circular No. 200. As for equity investments in unlisted entities, their fair values are determined based on valuation techniques. If the fair value of the investments contributed as capital to another entity cannot be reliably determined, the enterprise shall provide an explanation in Section 2c, Part VI, pertaining to additional information to the financial investment item on the notes to the financial statement. - Decline in the value of investment real estate Clause 1.6, Article 39 of Circular No. 200 on investment property stipulates “1.6. Enterprises do not depreciate investment property held for capital appreciation. In case it is evident that the investment property falls against market fair value and the decrease is determined reliably, the decline in cost of the investment property and the loss shall be recorded to costs of goods sold (similarly to provision for properties held for sale)”. Thus, the assessment of value decline must only be made when there are solid signs and evidence. If the decline in value of the investment property cannot be reliably determined, the enterprise will not record the loss due to such reason, but provide an explanation in Section 2c, Part VI, pertaining to additional information to the financial investment item on the notes to the financial statement. 5. Recording the environmental restoration cost Circular No. 200 only stipulates the advance deduction of the environmental restoration cost and the use of account 3524 for accounting. The amount of deduction, the time of starting and ending the deduction... must comply with the mechanism and policy applicable to each industry and each unit. For example, the advance deduction for oilfield cleanup cost of PetroVietnam or the advance deduction for environmental restoration cost of Vinacomin must comply with the specific provisions of the law applicable to each individual industry. ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. According to Circular No. 200, when calculating EPS, adjustments must be made to the amount already or to be deducted from the Commendation and Welfare Fund. The amount deducted from the Commendation and Welfare Fund in the previous period is not used to determine EPS in this period. The difference (if any) between the expected deduction of the previous period and the actual deduction (possibly in the next period) is adjusted to the EPS of the previous period (re-reported) and disclosed in the financial statement. 7. Exchange rate issues
- Accounting software must meet the standard set forth in Circular No. 103/2005/TT-BTC by allowing for upgrades, modifications, and supplements that comply with changes in accounting regulations and financial policies, without disrupting existing databases. In fact, implementing regulations on exchange rates in Circular No. 200 does not pose a problem for most enterprises, including 100% foreign-invested ones. However, a few enterprises are facing challenges due to their accounting software not meeting the prescribed standards. - The proposal to apply a single exchange rate to all types of intraday transactions will face the following problems: + The use of a single exchange rate from a commercial bank or reliable issuing organization for accounting purposes may not always provide an accurate depiction of the actual transaction. It is inappropriate for an enterprise to transact with one bank, yet use the exchange rate of another bank where the transaction did not take place. + When following the interbank average exchange rate as per Decision No. 15/2006/QD-BTC, only the exchange rate of Vietnamese dong and the US dollar is used. However, determining exchange rates of other currencies can be challenging due to cross-exchange, which may affect data’s reasonableness. + If only the buying rate or selling rate of a commercial bank is applied to various transactions, it would create inconsistency with reality. For example, for a purchase on credit for goods or services, an enterprise must record a liability corresponding to related items. When repaying the debt to a supplier, the enterprise must purchase foreign currency from the bank at the selling rate, so the transaction will be recorded at the bank's of foreign currency selling rate. When an enterprise receives foreign currency from sales, it must record the corresponding sales revenue. Regulations on foreign exchange management require the enterprise to sell the foreign currency to a bank and receive Vietnamese Dong at the buying rate. + In the current complicated exchange rate situation, a single buying or selling rate, or even the average of both, may not provide an accurate reflection of the financial state and exchange rate discrepancies faced by enterprises, especially those whose transactions involve large foreign currencies. ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. - When foreign currency monetary items are revaluated to recognize exchange rate differences at the time of preparation of the financial statement, the profit or loss resulting from exchange rate differences due to revaluation will be carried forward and reflected in the financial statements at the time of preparation, rather than solely at the end of the financial year due to typos in Circular No. 200. - The subsidiary company's use of the exchange rate set by the parent company to re-evaluate foreign currency monetary items only applies to the subsidiary having a parent company in Vietnam. As for subsidiaries with overseas parent companies, this provision applies only to consolidated financial statements, not to financial statements published in Vietnam. 8. Convertible bond issues Circular No. 200 guides 02 methods of recording and allocating bond issuance costs: + In case bond issuance costs are allocated using the straight-line method, the determination of the present value of future cash flows must exclude bond issuance costs (should be a minus). + In case bond issuance costs are allocated using the actual interest method, the determination of the present value of future cash flows includes bond issuance costs (should be a plus). However, due to negligence, Circular No. 200 has not clearly stated the difference between these two situations. The audit firms are recommended to guide enterprises to clearly distinguish between the two cases. - Because issued bonds are always determined into 2 components: principal and options. The principal is always the present value of the future payment (in which the cash flow is discounted), so there is no longer any concept of discount or premium. Discount or premium solely applies to ordinary bonds. - Bonds, as financial instruments traded on the market and typically involving multilateral transactions, are generally relevant only to public interest entities Therefore, the accounting for bond issuance costs should immediately comply with international accounting standards. ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. 9. Issues of liabilities and provisions - According to International Accounting Standard No. 37 which Circular No. 200 has approached, the provision is a liability that: + Buyer has not received the service provided (work has not been performed); + The liability amount can be reliably measured but is not completely certain; + The time for payment of the liability is uncertain. Therefore, in light of IAS 37, Circular No. 200 stipulates that the advance for major repair of fixed assets according to the technical requirements of fixed assets as a current obligation to ensure that the assets can operate normally as design standards is the provision. Because it meets all 3 requirements of IAS. It also does not contradict VAS 18 because VAS 18 has not mentioned this issue. - The deduction from the Science and Technology Development Fund is made (although enterprises can choose) in accordance with the law (i.e., has legal obligations) and has been done since 2009 in accordance with the Law on Science and Technology. The recent Circular No. 200 simply inherits and upholds this regulation, rather than introducing anything new. Thus, the Circular does not go against VAS. 10. Guidelines for preparation of cash flow statements According to regulations, Account 242 includes a lump sum payment of land rent that cannot be recognized as an intangible fixed asset. In essence, the cash flow of lump sum payment of land rent or the cash flow arising from the purchase of land use rights for a definite term are categorized as cash flows from investment activities. However, if the payment is made in installments, it is classified as operating cash flow. Therefore, the item "increase and decrease in prepaid expenses" does not include the difference between the closing balance and the opening balance of the lump-sum payment of land rent which is not eligible for recognition as intangible fixed assets (Circular No. 200 has a misspelling of the word “khong” (no)). ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. - Circular No. 200 has a spelling error that is the redundant word "BDSDT” (investment property). Only the difference between revenue and expenditure on liquidation and sale of fixed assets is presented as the above net amount in “other income” item, while revenue from investment property is presented in the “revenue” item, not in the “other income” item. 12. Prepaid expenses Prepaid expenses are classified as short-term or long-term based on their original term, not their remaining term. It is important to note that long-term prepaid expenses should not be reclassified as short-term.. 13. Notes to the financial statements The notes to the financial statements can also apply the concept of materiality. The Ministry of Finance cannot respond to an unclear question. It should be noted that when applying the concept of materiality, it must be disclosed in the “Other information” section of Section IX.7 of the Notes to Financial Statements. 14. Revenue recognition In light of the principle, revenue must be recognized in proportion to the incurred liability. Therefore, the enterprise cannot recognize revenue from gifts and promotions until they have been delivered as it does not meet the requirement for revenue recognition. Accordingly, the enterprise may not record a deduction from cost of goods sold for gifts and promotions. 15. Deduction in advance for sales deductions - According to the principle of prudence, only expenses can be deducted in advance, not the sales deductions because if the number of sales to be deducted has been determined, the sales must be recognized at the net amount immediately. ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. 16. Account 413 - As for purchases of assets or expenses paid immediately in a foreign currency (not through the accounts payable), the bank’s buying rate shall apply (Because the enterprise does not have to spend VND to purchase foreign currency, as it can utilize the foreign currency fund or the foreign currency deposited for payments). This provision is intended to ensure that assets are not recognized above their recoverable value. - As for asset purchase or incurred expenses whose payment has not yet been made, the enterprise shall record the liability at the bank's selling rate to ensure the principle that liabilities are not recognized lower than payable obligations. 17. Investment property Circular No. 200 does not require retroactive application, so the accumulated depreciation of investment property held for capital appreciation is still presented in the entry “Accumulated depreciation” and disclosed in a separate line in the notes to financial statement (it is consistent with paragraph 25 of VAS No. 5 and Clause 1.8 Article 39 that the conversion of the use purpose of the investment property does not change the cost of the investment property in determining the value or preparing the financial statement). 18. Circular No. 200 stipulates that enterprises must record losses due to decline in value of investment property in line with international practices and when the investment property increases again, the enterprise is entitled to a maximum refund of the amount recorded in the previous decrease. 19. Compliance with the Vietnamese Accounting System Circular No. 200 states that enterprises are not obliged to include a column of corresponding accounts in their accounting books. This is because the Circular grants flexibility to enterprises to choose the format of their accounting books, as long as they give a true and fair view of their financial position. 20. Comparison in financial statements ... ... ... Please sign up or sign in to your TVPL Pro Membership to see English documents. - The accounting for convertible bonds in accordance with Circular No. 200 shall be carried out from 2015 onwards. Convertible bonds issued in previous years are not required to apply retroactive regulations to recalculate the balance. 21. Capitalization of interest cost - Pursuant to point g, Clause 1, Article 54 of Circular No. 200, "The determination of capitalized interest cost must comply with the VAS "Borrowing costs". The capitalization of loan interest in some specific cases is as follows: As for a loan dedicated to the construction of fixed assets and investment property, the loan interest is capitalized even if the construction period is less than 12 months”. International practice does not specify that the time for the construction of unfinished assets is over or under 12 months, so to ensure that it reflects the true nature and is consistent with international practices, fixed assets and investment property are usually not must be mass-produced assets such as inventories. Therefore, Circular No. 200 stipulates capitalization even if the construction period of the property is less than 12 months. Accounting standards and corporate accounting regulations are both promulgated by the Ministry of Finance, so according to the Law on Promulgation of Legislative Documents, if there is any discrepancy between documents issued by the same agency regulating the same issue, the subsequent document will supersede the earlier document. |
