1、1International Accounting,6/eFrederick D.S.ChoiGary K.MeekChapter 3:Comparative Accounting:Europe2Learning ObjectiveslUnderstand how financial reporting is regulated and enforced in four European countries:France,Germany,the Netherlands,and the U.K.lDescribe the key similarities and differences betw
2、een the accounting systems of these five countries.lIdentify the use of International Financial Reporting Standards at the levels of the individual company and the consolidated financial statements in these five countries.lDescribe the audit-oversight mechanisms in these five countries.3The relation
3、ship between accounting standard and practicelThe definition of accounting standardlDoes accounting practice always follow what accounting standard requires?(page 38)lPenalitylVoluntary supply more informationlPermission to not comply with accounting standards iflQuestion:Does the relationship betwe
4、en accounting standard and practice always move in a one-way direction?lSupply and demand of information(page 39)4IFRS in the European Union(page 39)lStarting in 2005,all EU-listed companies must follow IFRS in their consolidated financial statements.lGenerally,IFRS consolidated statements are permi
5、tted for non-listed companies.lRequirements for individual company financial statements vary IFRS may be required,allowed,or prohibited.56IFRS(to be continued)lIFRS are based on fair presentation principleslIFRS may be overridden in rare circumstances to achieve fair presentationlAccounting measurem
6、ents(page 40-41)lGoodwill-the difference between the fair value of the consideration given and the fair value of the subsidiarys assets,liabilities,and contigent liabilities.lGoodwill-annual impairment testlNegative goodwill being immediately recognized in income 7IFRS(to be continued)lAccounting me
7、asurementslTranslation of financial statements of foreign operations functional currency concept(p130)lAssets valued at historical cost or fair valuelResearch costs expensed;development costs capitalizedlLIFO not allowedlFinance leases capitalized;operating leases expensedlProvisions recognized when
8、 probable and estimablelDeferred taxes recognized in full,using the liability method,for temporary differences between the carrying amount and tax base89FrancelOverviewlFocus on needs of creditors and tax authoritieslConsolidated groups can report in U.S.GAAP or IASlCompany law and tax law are the p
9、redominant influenceslFocus on national economic planninglTax laws tend to override accounting ruleslSmall accounting profession established by lawlOECand CNCC for public accounting and auditinglAccounting and auditing profession are separatelSmall stock marketlMost capital contributed by banks,gove
10、rnment,or familylFrench equivalent of the SEC Financial Markets Authority or AMF)lIFRS required for listed companies in 200510France lOverview(page 41)l“The Plan”national uniform chart of accounts(national accounting code)lObjectives and principles of financial reportinglDefinitions of elementslReco
11、gnition and valuation ruleslStandardized chart of accountslModel financial statementslOther influences on French accounting ruleslCommercial legislation(Code de Commerce)lTax laws11France(to be continued)lAccounting regulation and enforcement(p43)lCNC National Accounting BoardlKeeps plan currentlMak
12、es rulings and recommendations on accounting issues lCRC Accounting Regulation CommitteelConverts CNC rulings and recommendations into binding regulationslReal regulatory powerlAMF Financial Markets Authority(French equivalent of the U.S.Security Exchange Committee)lSupervises securities marketslTwo
13、 divisions12lAccounting regulation and enforcementlOEC Institute of Public AccountantslRepresents the accounting professionlMembers prepare financial statements,and provide tax,information systems,and management advisory serviceslBe under the juridiciton of the Ministry of Economy and FiancelCNCC Na
14、tional Institute of Statutory AuditorslMembers audit and give an opinion on financial statementslMust report criminal acts to the High Council of External AuditorslSubstantial overlap in OEC and CNCC membershiplStatutory auditors not allowed to provide accounting services to the same clientlAMF over
15、sees audits of listed companies,but relies on a committee of the CNCC to conduct audit-quality reviews13France(to be continued)lUnusual features of French financial reportinglMust report results of environmental activitieslReports aimed at preventing bankruptcieslSocial reportlNo requirements for a
16、statement of changes in financial position or a cash flowlBeing prepared in compliance with legislation and in good faith14France(to be continued)lAccounting measurement(p45-46)lTangible assetslDepreciation expense of fixed assetslInventory being measured at the lower of cost or realizable valuelR&D
17、 expensed as incurred in generallR&D capitalized in restricted circumstances with less than five year amortizationlFinancial lease not capitalized lLiabilities of post-employment benefits not recognized15GermanylOverviewlFocus on needs of creditors and tax authoritieslMNEs are becoming more investor
18、-orientedlCompany law is predominant influencelAccounting rules amend the Commercial CodelAnnual accounts are the basis for tax accountslTax rules dominate legal accounting issueslLimited impact of accounting professionlGerman Accounting Standards BoardlIFRS required for listed companies in 200516Ge
19、rmany(to be continued)lThe development of Germany accountinglThe changing attitude of Corporation LawlThe impact of Fourth,Seventh DirectiveslTwo new laws passed in 1998lIssue debt or equity on capital market based IAAP in consolidated fiancial statementslEstablish the private organization to set ac
20、counting standards17Germany(to be continued)lCreditor protectionlConservative balance sheet valuationslReserves as protection against unforeseen risks and insolvencylAccounting is designed to compute a prudent income amount that leaves creditors unharmed after distributions are made to ownerslInflue
21、nce of tax lawlDetermination principle:taxable income is determined by what is booked in a companys financial recordslReliance on statutes and court decisions18Germany(to be continued)lAccounting regulation and enforcementlGerman Commercial Code(HGB)lApplies to all business entitieslGerman Accountin
22、g Standards Board(GASB)lDevelops recommendations for consolidated financial statementslCan GASB alter or restrict HGB?lFinancial Accounting Control Act in 2004lPurposelTwo-tiered enforcement systemFinancial Reporting Enforcement Panel(private)Federal Financial Supervisory Authority(public)19Germany(
23、to be continued)lAccounting regulation and enforcement lFinancial Reporting Enforcement PanellEnforces compliance with German financial reporting requirements and IFRS by listed companieslAuditor Oversight CommissionlChamber of Accountants Oversees WPs(“enterprise examiners”or CPA)20Germany(to be co
24、ntinued)lUnusual features of German financial reportinglAuditors private report to board of directors and supervisory board on companys future prospectslFinancial reporting requirements depending on company sizelDualitylConsolidated financial statement based on IFRS lIndividual company based on HGB
25、requirements21Germany(to be continued)lAccounting measurementslDifferent treatment of goodwill under HGB and GASlTangible assetslInventory at the lower of cost or marketlDepreciation expense under tax codelR&D expensedlFinance lease not capitalizelProvision as estimates of future expenses or losses2
26、2The NetherlandsOverviewlBusiness economics approach to accountinglTradition oflPublic ownership of shares lInternational business outlookl“Generally Acceptable Accounting Principles”lProvided by Council for Annual ReportinglMembers from the accounting profession(NIVRA)and others lNot mandated by la
27、w,but followed by most companieslCompany law is supplemented by case lawlIFRS required for listed companies in 200523The Netherlands(to be continued)lOverviewlAccounting paradoxeslPermissive requirements,but high professional practice standardslCode law country whose accounting is oriented toward fa
28、ir presentationlFair presentation orientation developed without a strong stock marketlFinancial reporting and tax accounting are two separate activitieslPower of accounting profession 24The Netherlands(to be continued)OverviewlOther influences on Dutch accountinglU.K.and U.S.as much as continental E
29、uropean countrieslAccounting professionlBusiness economics(microeconomics)lIASB25The Netherlands(to be continued)lAccounting regulation and enforcement(p55)lCompany law Act on Annual Financial StatementslIntroduction of mandatory auditlOther changes of EU directiveslDutch Accounting Standards Board
30、lDevelops guidelines on generally acceptable accounting standardslNo force of law but followed by most companies and auditorslEnterprise ChamberlEnforces compliance with accounting requirements26The Netherlands(to be continued)lAccounting regulation and enforcement(p56)lThe Netherlands Authority for
31、 the Financial Markets(NAFM)equivalent to the SEC in U.S.A.lOversight annual reporting and auditing of listed companieslFinacial Reporting Supervision Division examines the financial statements filed with the AMFlAudit Firm Oversight Division ensures the compliance with auditing standardlNIvRAOverse
32、es auditing profession27The Netherlands(to be continued)lUnusual features of Dutch financial reportinglFinancial statements may be in Dutch,French,German,or EnglishlOther than consolidated financial statements of Dutch listed companies,financial statements may be based on Dutch guidelines,IFRS,or a
33、combinationlFlexible accounting measurementslCurrent values are permitted for tangible assets.lAre current values acceptable for tax purposes?lHistorical cost as an additional information providedlRevaluation offset by a revaluation reserve in OElGoodwillcapitalized and amortized over 20 yearslInven
34、tory,intangibles,R&D,Finance leaselOpportunities for income smoothing28United KingdomlOverviewlFocus on investorslCompany law has a much wider remit lAccounting requirements are for all LLCs and corporationslAccounts present a“true and fair view”of company resultslAccounting Standards Board(ASB)will
35、 incorporate International Financial Reporting Standards(IFRS)by 2005 29United Kingdom(to be continued)lOverviewlLegacy of British accountinglFirst country to develop an accountancy professionlFair presentation(true and fair view)lExported British accounting around the world30United Kingdom(to be co
36、ntinued)lAccounting regulation and enforcementlCompanies ActlBroad financial reporting frameworklFinancial Reporting Council oversees:lAccounting Standards BoardIssues Financial Reporting Standards(FRSs)UITF clarifies FRSslAuditing Practices BoardIssues auditing standards31United Kingdom(to be conti
37、nued)lAccounting regulation and enforcementlFinancial Reporting Council oversees:lFinancial Reporting Review PanelEnforces compliance with FRCslProfessional Oversight BoardOversees auditing professionAudit Inspection UnitMonitors the audit of listed companiesAccountancy Investigation and Discipline
38、BoardInvestigates and disciplines accountants for professional misconduct32United Kingdom(to be continued)lUnusual features of British accountinglTrue and fair overridelAccounting measurementlGoodwilllCapitalize and amortize for 20 yearslAnnual impairment test for no amortizationlAssets measurement at HC,CC or bothlRevaluation of land and buildingslResearch cost expensed and development cost deferredlInventory LIFO not permittedlFinance lease3334Other Chapter Exhibits35Other Chapter Exhibits(to be continued)36Other Chapter Exhibits(to be continued)
