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1、1,International Accounting,6/e,Frederick D.S.ChoiGary K.Meek,Chapter 3:Comparative Accounting:Europe,2,Learning Objectives,Understand how financial reporting is regulated and enforced in four European countries:France,Germany,the Netherlands,and the U.K.Describe the key similarities and differences
2、between the accounting systems of these five countries.Identify the use of International Financial Reporting Standards at the levels of the individual company and the consolidated financial statements in these five countries.Describe the audit-oversight mechanisms in these five countries.,3,The rela
3、tionship between accounting standard and practice,The definition of accounting standardDoes accounting practice always follow what accounting standard requires?(page 38)PenalityVoluntary supply more informationPermission to not comply with accounting standards ifQuestion:Does the relationship betwee
4、n accounting standard and practice always move in a one-way direction?Supply and demand of information(page 39),4,IFRS in the European Union(page 39),Starting in 2005,all EU-listed companies must follow IFRS in their consolidated financial statements.Generally,IFRS consolidated statements are permit
5、ted for non-listed companies.Requirements for individual company financial statements vary IFRS may be required,allowed,or prohibited.,5,6,IFRS(to be continued),IFRS are based on fair presentation principlesIFRS may be overridden in rare circumstances to achieve fair presentationAccounting measureme
6、nts(page 40-41)Goodwill-the difference between the fair value of the consideration given and the fair value of the subsidiarys assets,liabilities,and contigent liabilities.Goodwill-annual impairment testNegative goodwill being immediately recognized in income,7,IFRS(to be continued),Accounting measu
7、rementsTranslation of financial statements of foreign operations functional currency concept(p130)Assets valued at historical cost or fair valueResearch costs expensed;development costs capitalizedLIFO not allowedFinance leases capitalized;operating leases expensedProvisions recognized when probable
8、 and estimableDeferred taxes recognized in full,using the liability method,for temporary differences between the carrying amount and tax base,8,9,France,OverviewFocus on needs of creditors and tax authoritiesConsolidated groups can report in U.S.GAAP or IASCompany law and tax law are the predominant
9、 influencesFocus on national economic planningTax laws tend to override accounting rulesSmall accounting profession established by lawOECand CNCC for public accounting and auditingAccounting and auditing profession are separateSmall stock marketMost capital contributed by banks,government,or familyF
10、rench equivalent of the SEC Financial Markets Authority or AMF)IFRS required for listed companies in 2005,10,France,Overview(page 41)“The Plan”national uniform chart of accounts(national accounting code)Objectives and principles of financial reportingDefinitions of elementsRecognition and valuation
11、rulesStandardized chart of accountsModel financial statementsOther influences on French accounting rulesCommercial legislation(Code de Commerce)Tax laws,11,France(to be continued),Accounting regulation and enforcement(p43)CNC National Accounting BoardKeeps plan currentMakes rulings and recommendatio
12、ns on accounting issues CRC Accounting Regulation CommitteeConverts CNC rulings and recommendations into binding regulationsReal regulatory powerAMF Financial Markets Authority(French equivalent of the U.S.Security Exchange Committee)Supervises securities marketsTwo divisions,12,Accounting regulatio
13、n and enforcementOEC Institute of Public AccountantsRepresents the accounting professionMembers prepare financial statements,and provide tax,information systems,and management advisory servicesBe under the juridiciton of the Ministry of Economy and FianceCNCC National Institute of Statutory Auditors
14、Members audit and give an opinion on financial statementsMust report criminal acts to the High Council of External AuditorsSubstantial overlap in OEC and CNCC membershipStatutory auditors not allowed to provide accounting services to the same clientAMF oversees audits of listed companies,but relies
15、on a committee of the CNCC to conduct audit-quality reviews,13,France(to be continued),Unusual features of French financial reportingMust report results of environmental activitiesReports aimed at preventing bankruptciesSocial reportNo requirements for a statement of changes in financial position or
16、 a cash flowBeing prepared in compliance with legislation and in good faith,14,France(to be continued),Accounting measurement(p45-46)Tangible assetsDepreciation expense of fixed assetsInventory being measured at the lower of cost or realizable valueR&D expensed as incurred in generalR&D capitalized
17、in restricted circumstances with less than five year amortizationFinancial lease not capitalized Liabilities of post-employment benefits not recognized,15,Germany,OverviewFocus on needs of creditors and tax authoritiesMNEs are becoming more investor-orientedCompany law is predominant influenceAccoun
18、ting rules amend the Commercial CodeAnnual accounts are the basis for tax accountsTax rules dominate legal accounting issuesLimited impact of accounting professionGerman Accounting Standards BoardIFRS required for listed companies in 2005,16,Germany(to be continued),The development of Germany accoun
19、tingThe changing attitude of Corporation LawThe impact of Fourth,Seventh DirectivesTwo new laws passed in 1998Issue debt or equity on capital market based IAAP in consolidated fiancial statementsEstablish the private organization to set accounting standards,17,Germany(to be continued),Creditor prote
20、ctionConservative balance sheet valuationsReserves as protection against unforeseen risks and insolvencyAccounting is designed to compute a prudent income amount that leaves creditors unharmed after distributions are made to ownersInfluence of tax lawDetermination principle:taxable income is determi
21、ned by what is booked in a companys financial recordsReliance on statutes and court decisions,18,Germany(to be continued),Accounting regulation and enforcementGerman Commercial Code(HGB)Applies to all business entitiesGerman Accounting Standards Board(GASB)Develops recommendations for consolidated f
22、inancial statementsCan GASB alter or restrict HGB?Financial Accounting Control Act in 2004PurposeTwo-tiered enforcement systemFinancial Reporting Enforcement Panel(private)Federal Financial Supervisory Authority(public),19,Germany(to be continued),Accounting regulation and enforcement Financial Repo
23、rting Enforcement PanelEnforces compliance with German financial reporting requirements and IFRS by listed companiesAuditor Oversight CommissionChamber of Accountants Oversees WPs(“enterprise examiners”or CPA),20,Germany(to be continued),Unusual features of German financial reportingAuditors private
24、 report to board of directors and supervisory board on companys future prospectsFinancial reporting requirements depending on company sizeDualityConsolidated financial statement based on IFRS Individual company based on HGB requirements,21,Germany(to be continued),Accounting measurementsDifferent tr
25、eatment of goodwill under HGB and GASTangible assetsInventory at the lower of cost or marketDepreciation expense under tax codeR&D expensedFinance lease not capitalizeProvision as estimates of future expenses or losses,22,The Netherlands,OverviewBusiness economics approach to accountingTradition ofP
26、ublic ownership of shares International business outlook“Generally Acceptable Accounting Principles”Provided by Council for Annual ReportingMembers from the accounting profession(NIVRA)and others Not mandated by law,but followed by most companiesCompany law is supplemented by case lawIFRS required f
27、or listed companies in 2005,23,The Netherlands(to be continued),OverviewAccounting paradoxesPermissive requirements,but high professional practice standardsCode law country whose accounting is oriented toward fair presentationFair presentation orientation developed without a strong stock marketFinan
28、cial reporting and tax accounting are two separate activitiesPower of accounting profession,24,The Netherlands(to be continued),OverviewOther influences on Dutch accountingU.K.and U.S.as much as continental European countriesAccounting professionBusiness economics(microeconomics)IASB,25,The Netherla
29、nds(to be continued),Accounting regulation and enforcement(p55)Company law Act on Annual Financial StatementsIntroduction of mandatory auditOther changes of EU directivesDutch Accounting Standards Board Develops guidelines on generally acceptable accounting standardsNo force of law but followed by m
30、ost companies and auditorsEnterprise ChamberEnforces compliance with accounting requirements,26,The Netherlands(to be continued),Accounting regulation and enforcement(p56)The Netherlands Authority for the Financial Markets(NAFM)equivalent to the SEC in U.S.A.Oversight annual reporting and auditing o
31、f listed companiesFinacial Reporting Supervision Division examines the financial statements filed with the AMFAudit Firm Oversight Division ensures the compliance with auditing standardNIvRAOversees auditing profession,27,The Netherlands(to be continued),Unusual features of Dutch financial reporting
32、Financial statements may be in Dutch,French,German,or EnglishOther than consolidated financial statements of Dutch listed companies,financial statements may be based on Dutch guidelines,IFRS,or a combinationFlexible accounting measurementsCurrent values are permitted for tangible assets.Are current
33、values acceptable for tax purposes?Historical cost as an additional information providedRevaluation offset by a revaluation reserve in OEGoodwillcapitalized and amortized over 20 yearsInventory,intangibles,R&D,Finance leaseOpportunities for income smoothing,28,United Kingdom,OverviewFocus on investo
34、rsCompany law has a much wider remit Accounting requirements are for all LLCs and corporationsAccounts present a“true and fair view”of company resultsAccounting Standards Board(ASB)will incorporate International Financial Reporting Standards(IFRS)by 2005,29,United Kingdom(to be continued),OverviewLe
35、gacy of British accountingFirst country to develop an accountancy professionFair presentation(true and fair view)Exported British accounting around the world,30,United Kingdom(to be continued),Accounting regulation and enforcementCompanies ActBroad financial reporting frameworkFinancial Reporting Co
36、uncil oversees:Accounting Standards BoardIssues Financial Reporting Standards(FRSs)UITF clarifies FRSsAuditing Practices BoardIssues auditing standards,31,United Kingdom(to be continued),Accounting regulation and enforcementFinancial Reporting Council oversees:Financial Reporting Review PanelEnforce
37、s compliance with FRCsProfessional Oversight BoardOversees auditing professionAudit Inspection UnitMonitors the audit of listed companiesAccountancy Investigation and Discipline BoardInvestigates and disciplines accountants for professional misconduct,32,United Kingdom(to be continued),Unusual featu
38、res of British accountingTrue and fair overrideAccounting measurementGoodwillCapitalize and amortize for 20 yearsAnnual impairment test for no amortizationAssets measurement at HC,CC or bothRevaluation of land and buildingsResearch cost expensed and development cost deferredInventory LIFO not permittedFinance lease,33,34,Other Chapter Exhibits,35,Other Chapter Exhibits(to be continued),36,Other Chapter Exhibits(to be continued),
