Our Ref.: C/FRSC30 May 2019Sue LloydIFRS Interpretations CommitteeColumbus Building7 Westferry CircusCanary WharfLondon E14 4HDUnited KingdomDear Sue,Tentative agenda decision – Holdings of CryptocurrenciesThe Hong Kong Institute of Certified Public Accountants (HKICPA) is the only bodyauthorised by law to set and promulgate standards relating to financial reporting,auditing and ethics for professional accountants, in Hong Kong. We are grateful for theopportunity to provide you with our views on this tentative agenda decision (TAD).In response to this TAD, the HKICPA:
(a) considered input from our technical and industry experts in accounting firms('practitioners') who provide accounting advice to entities holding cryptocurrenices;
and(b) developed its views through its Financial Reporting Standards Committee. TheCommittee comprises academics, preparer representatives from various industrysectors, regulators, and technical and industry experts from small, medium andlarge accounting firms.The HKICPA observes some diversity in how entities account for holdings ofcryptocurrencies. For the purpose of eliminating the existing diversity in practice, theHKICPA supports finalising the TAD as interim guidance to clarify how existing IFRSStandards apply to holdings of cryptocurrencies.Nevertheless, the HKICPA acknowledges the following concerns on the TADexpressed by some of our stakeholders:
IFRS Interpretations Committee Tentative Agenda Decision: Holdings of Cryptocurrencies
下载原件Our Ref.: C/FRSC30 May 2019Sue LloydIFRS Interpretations CommitteeColumbus Building7 Westferry CircusCanary WharfLondon E14 4HDUnited KingdomDear Sue,Tentative agenda decision – Holdings of CryptocurrenciesThe Hong Kong Institute of Certified Public Accountants (HKICPA) is the only bodyauthorised by law to set and promulgate standards relating to financial reporting,auditing and ethics for professional accountants, in Hong Kong. We are grateful for theopportunity to provide you with our views on this tentative agenda decision (TAD).In response to this TAD, the HKICPA:
(a) considered input from our technical and industry experts in accounting firms('practitioners') who provide accounting advice to entities holding cryptocurrenices;
and(b) developed its views through its Financial Reporting Standards Committee. TheCommittee comprises academics, preparer representatives from various industrysectors, regulators, and technical and industry experts from small, medium andlarge accounting firms.The HKICPA observes some diversity in how entities account for holdings ofcryptocurrencies. For the purpose of eliminating the existing diversity in practice, theHKICPA supports finalising the TAD as interim guidance to clarify how existing IFRSStandards apply to holdings of cryptocurrencies.Nevertheless, the HKICPA acknowledges the following concerns on the TADexpressed by some of our stakeholders:
(a) IAS 38 Intangible Assets was developed long before cryptocurrencies and was notdesigned with transactions that involve cryptocurrencies in mind. Applying IAS 38to holdings of cryptocurrencies (when holdings of cryptocurrencies do not meet thebroker-trader exception in paragraph 3(b) of IAS 2 Inventories) may not alwaysprovide the most useful information to users of financial statements. Thesestakeholders consider that given the nature and volatility of cryptocurrencies,measuring cryptocurrency holdings at fair value through profit or loss would betterreflect the underlying economics of these assets and provide users of financialstatements with relevant and useful information. They consider that the accountingfor cryptocurrencies should be dealt with by standard setting instead of issuing anagenda decision.(b) The TAD only covers the accounting for holdings of cryptocurrencies. In HongKong, an increasing number of entities undertook initial coin offerings and / orlaunched businesses around cryptoassets during the last two years. We alsoexpect that the level of interest in cryptoasset transactions will increase followingthe announcements 1 by the Hong Kong Securities and Futures Commissionregarding upcoming regulatory framework/standards on funds investing incryptocurrencies and exchanges/trading platforms for such assets. Consideringthat cryptocurrencies, or more broadly cryptoassets and related transactions, areevolving, we expect questions about the accounting for cryptoasset transactionswill continue to arise. We think the IASB should be responsive to thesedevelopments by commencing a standard setting project.The HKICPA understands that standard-setting activity would take time. Therefore, theHKICPA supports finalising the agenda decision as interim guidance to clarify howexisting IFRS Standards apply to holdings of cryptocurrencies. However, the HKICPAstrongly recommends that the IASB commences a standard-setting project forcryptocurrencies or work with interested national standard-setters to develop a morerobust accounting suitable for cryptocurrencies.If you have any questions regarding the matters raised in this letter, please contact meor Eky Liu (eky@hkicpa.org.hk), Associate Director of the Standard SettingDepartment.Sincerely,Christina NgDirector, Standard Setting Department1 The Hong Kong Securities and Futures Commission (SFC) plans to issue guidance on theregulatory standards expected of virtual asset portfolio managers and fund distributors. TheSFC is also exploring a conceptual framework for the potential regulation of virtual assettrading platform operators.․https://www.sfc.hk/web/EN/files/ER/PDF/App%201%20-%20Reg%20standards%20for%20VA%20portfolio%20mgrs_eng.pdf․https://www.sfc.hk/web/EN/files/ER/PDF/App%202_%20Conceptual%20framework%20for%20VA%20trading%20platform_eng.pdf