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KembaraXtra – Islamic Finance – Sukuk: Comparison between Ṣukūk, Bonds and Shares
Introduction
Ṣukūk were initially developed to provide a Sharīʿah-compliant alternative to conventional bonds, especially to meet the large-scale financing needs of governments and corporations. As a result, Ṣukūk share some similarities with bonds in practice, while at the same time retaining important conceptual similarities with shares (equity). However, there are also clear and fundamental differences among Ṣukūk, bonds, and shares in terms of nature, risk, returns, ownership, and Sharīʿah compliance.
Similarities between Ṣukūk and Bonds
Ṣukūk and bonds share several practical and market-related features:
- Capital market instruments
Both are used to raise funds for major financing needs of:- Governments (sovereigns),
- Corporations,
- Parastatal bodies,
- Financial institutions.
- Various tenures
Both can be structured as:- Short-term,
- Medium-term,
- Long-term,
- Even perpetual instruments.
- Regular returns and principal repayment
Both can be designed to:- Provide periodic payments during the life of the instrument, and
- Repay the principal amount at maturity.
- Secondary market tradability
In general, both instruments:- Can be traded in secondary markets,
- Are transferable among investors (subject to Sharīʿah rules in the case of Ṣukūk).
- Market infrastructure
Both can be:- Rated by credit rating agencies,
- Listed on exchanges,
- Issued in multiple currencies,
- Offered in domestic and international markets.
Conceptual Similarity between Ṣukūk and Shares
From a theoretical perspective:
- Ṣukūk resemble equity, because they represent:
- Proportionate ownership in assets, projects, or ventures.
- Shares represent:
- Ownership in a corporation as a whole,
- Often accompanied by voting rights.
Key Differences between Bonds, Ṣukūk and Shares
1. Nature of the Instrument
- Bonds
Represent an IOU or interest-bearing debt obligation of the issuer. - Ṣukūk
Represent proportionate ownership in Sharīʿah-compliant:- Assets,
- Usufructs,
- Services,
- Commodities,
- Business ventures,
- Or a combination of these.
- Shares
Represent ownership in the corporation as a whole.
2. Issuer
- Bonds
Issuers are not restricted in their business activities. - Ṣukūk
Issuers must be engaged in Sharīʿah-compliant activities only. - Shares
Can be issued by any company, although Sharīʿah screening applies for Islamic equity investment.
3. Investors
- Bonds
Traditionally targeted at non-Islamic investors. - Ṣukūk
Open to both Islamic and non-Islamic investors. - Shares
Also open to both Islamic and non-Islamic investors.
4. Relationship between Issuer and Investor
- Bonds
Create a lender–borrower relationship; investors are creditors. - Ṣukūk
Relationship depends on the Sharīʿah contract used (sale, lease, partnership, agency, etc.). - Shares
Investors become owners (shareholders) with ownership rights in the company.
5. Underlying Assets
- Bonds
- Unsecured bonds: no assets required.
- Secured bonds: may be backed by assets (even non-Sharīʿah-compliant).
- Ṣukūk
Must be backed by Sharīʿah-compliant underlying assets, which may include:- Tangible assets,
- Usufructs,
- Services,
- Receivables (subject to jurisdictional rules).
- Shares
Do not require specific underlying assets.
6. Asset-Related Expenses
- Bonds
Bondholders do not bear asset-related expenses. - Ṣukūk
Ṣukūk holders may bear asset-related expenses, reflecting ownership. - Shares
Shareholders do not directly bear specific asset expenses.
7. Status and Ranking
- Bonds
Bondholders are generally unsecured creditors, unless secured. - Ṣukūk
- Asset-backed Ṣukūk: investors have recourse to assets and rank above unsecured creditors.
- Asset-based Ṣukūk: investors rank pari passu with unsecured creditors.
- Shares
Shareholders are residual claimants and rank lowest in liquidation.
8. Returns to Investors
- Bonds
Returns are interest-based coupon payments, representing a percentage of capital. - Ṣukūk
Returns are Sharīʿah-compliant, derived from:- Profits (sale or partnership),
- Rentals (lease).
- Shares
Returns come in the form of dividends, which are not guaranteed.
9. Principal Repayment
- Bonds
Principal repayment at maturity is guaranteed, regardless of performance. - Ṣukūk
- Partnership-based Ṣukūk: no ex-ante guarantee of capital.
- Sale- and lease-based Ṣukūk: principal is generally repaid.
- Shares
No principal repayment, as shares are perpetual instruments.
10. Utilisation of Proceeds
- Bonds
Proceeds can be used for any legal purpose. - Ṣukūk
Proceeds must be used for Sharīʿah-compliant activities only. - Shares
Equity can be issued to meet any corporate financing needs.
11. Tradability in the Secondary Market
- Bonds
Trading represents sale of debt. - Ṣukūk
Trading represents sale of ownership in assets or projects:- Globally (e.g. AAOIFI): trading allowed mainly for asset-based Ṣukūk.
- Malaysia: trading of debt-based Ṣukūk is permitted.
- Shares
Trading represents sale of ownership in the company.
12. Pricing
- Bonds
Pricing is based on:- Credit rating,
- Terms and conditions,
- Spread over a reference interest rate.
- Ṣukūk
Pricing depends on:- Structure of the Ṣukūk,
- Asset backing (for asset-backed Ṣukūk),
- Market liquidity and complexity.
- Shares
Pricing is tied directly to corporate performance and market perception.
Simple Exam-Friendly Summary
- Bonds = debt + interest.
- Ṣukūk = ownership + Sharīʿah-compliant returns.
- Shares = ownership in a company with residual risk.
- Ṣukūk sit between bonds and shares, combining asset ownership with capital market features.
Key Takeaway
Ṣukūk are neither conventional bonds nor ordinary shares. They are a distinct Sharīʿah-compliant capital market instrument that blends ownership, ethical investment, and structured finance—offering a unique balance between risk, return, and compliance within the Islamic financial system.
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