Valtech Valuation Assists Hong Kong Companies in Long Service Payments (LSP) Valuation under the Proposed New Legislations

HKICPA recently issued comprehensive guidance for the accounting for the impact arising from the abolition of the Mandatory Provident Fund (MPF)-Long Service Payment (LSP) offsetting mechanism (the “Abolition”) on entities in Hong Kong.

https://www.hkicpa.org.hk/-/media/HKICPA-Website/New-HKICPA/Standards-and-regulation/SSD/gMPFLSP.pdf

It should be noted that the Government Subsidy does not yet meet the recognition criteria of any element of the financial statements based on an assessment of relevant facts and circumstances at the time of writing of the above publication.

Past service cost should be recorded in the year of enactment of the Amendment Ordinance. Valtech’s LSP valuation model can incorporate acturaial assumptions and calculate the LSP including the anticipated effects of the Abolition. The calculation process can be adjusted no matter the Company chooses Approach 1 or Approach 2 in the guidance.

Methodology: Projected Unit Credit Method

Why are you encouraged to hire a valuation specialist to perform the calculation?

The calculation is not too complicated for one single employee. Following the practical example provided by HKICPA, you can calculate the result and project the impact for a single employee under simplified assumptions using a single worksheet of a spreadsheet program. However, when the number of employees increase from 1 to hundreds or even to thousands, the complexity will increase significantly. Programming technique will be required to handle massive data. On the other hand, according to HKAS 19, actuarial assumptions should be used. For example, staff turnover rate should be considered and turnover rate should be different for staff in different age groups. Combining the impact of actuarial assumptions and the large pool of employees, involvement of valuation specialist can support company in using a proper framework and perform a level review on the input data.

Valtech Valuation has been appointed by multinational corporations and prominent employers in Hong Kong. Currently Valtech Valuation is actively helping clients with several thousands of employees in quantifying their LSP obligation under the new legislation. It is far more complicated than one can expect in handling a lot of different possibilities in a sizable workforce. Appointment of specialist is highly recommended.

Hong Kong Accounting Standard 19 (HKAS 19) requires businesses to compute and report their defined benefit obligations (DBO) and related expenses. Thus, Hong Kong companies need to have fair value assessments on DBO. The most commonly adopted method in valuation of DBO is the projected unit credit method.

The projected unit credit method is a valuation method using actuarial assumptions that considers each period of service as generating an additional unit of benefit entitlement and measures each unit separately to build up the final obligation.

Under the new legislations, significant differences could be found in the calculations of MPF offsetting arrangement. Overall, the related obligations will increase. In the calculation process, the related issues rise from pre- and post-transition have to be solved.

The Hong Kong Government will put in place two supporting measures to assist businesses to adapt to the new policy. The first measure is a 25-year refined subsidy scheme. The Government will subsidize a certain proportion of the total amount of severance payments (SP) and LSP payable by employers under this scheme, in order to lower the burden of employers brought by rising obligations.

The second measure is the Designated Saving Accounts (DSA) Scheme. The DSA Scheme mandates employers to save up for their future SP/LSP liabilities. The monthly contribution to the DSA should equal to 1% of employees’ monthly relevant income. Employers may stop the contribution when the savings in the DSA reached 15% of total employee’s annual relevant income.

Valtech’s valuation team includes Master of Finance, Master of Statistics and valuation experts with background in quantitative finance and financial engineering. In addition, Valtech’s valuation services are ISO 9001 cert If companies’ auditors do not require an actuary to be responsible for the calculations, our valuation team are capable of providing opinion on DBO for financial reporting purposes.

The details of the abolition of MPF offsetting arrangement could be referred below:

Abolition of Offsetting Arrangement (to be implemented in 2025)

The Legislative Council passed the Employment and Retirement Schemes Legislation (Offsetting Arrangement) (Amendment) Bill 2022 on 9 June 2022 to abolish the use of the accrued benefits of employers’ mandatory contributions under the Mandatory Provident Fund (MPF) System to offset severance payment (SP) and long service payment (LSP) (the offsetting arrangement). The Government will implement the abolition of the offsetting arrangement in tandem with the full implementation of the eMPF Platform of the Mandatory Provident Fund Schemes Authority, which is expected to be in 2025.

Key points of the abolition of offsetting arrangement:

• After the abolition of the offsetting arrangement takes effect (the transition date), employers can no longer use the accrued benefits derived from their mandatory MPF contributions to offset employee’s SP/LSP;
• Accrued benefits derived from employers’ voluntary contributions as well as gratuities based on length of service can continue to be used to offset SP/LSP.
• To reduce the risk of large-scale dismissals before the transition date, the “grandfathering” arrangement will be put in place for the pre-transition portion of SP/LSP of employees who are already in employment before the transition date.

Key points of the “grandfathering” arrangement (only applicable to employees who are already in employment before the transition date):

• For employees already in employment before the transition date, their SP/LSP will be divided into pre-transition portion (i.e. for the employment period before the transition date) and post-transition portion (i.e. for the employment period starting from the transition date).
• The pre-transition portion will be calculated on the basis of the monthly wages immediately preceding the transition date and the years of service before the transition date, whereas the post-transition portion will be calculated on the basis of the last monthly wages before termination of employment and the years of service after the transition date.
• The maximum amount of SP/LSP (i.e. the sum of pre-transition and post-transition portions of SP/LSP) is still capped at $390,000. If an employee’s total SP/LSP exceeds $390,000, the amount in excess of the cap will be deducted from the post-transition portion.
• Employers can continue to use the accrued benefits derived from their MPF contributions (irrespective of whether the contributions are made before, on or after the transition date, and irrespective of whether the contributions are mandatory or voluntary) to offset the pre-transition portion (but not the post-transition portion) of SP/LSP.

After the abolition of the offsetting arrangement, calculation of SP/LSP payable to a monthly-rated employee is as follows:

(1) Employment period before transition date

• Employee’s last full month’s wages immediately preceding the transition date× 2/3 × years of service before transition date

(2) Employment period after transition date

• Employee’s last full month’s wages before termination of employment× 2/3 × years of service after transition date

(3) The ceiling on the monthly wages for calculating SP/LSP is $22,500 and the maximum SP/LSP amount is $390,000. These ceilings remain unchanged.