國際會計學第六版chapter3課件

1、International Accounting, 6/eFrederick D.S. ChoiGary K. MeekChapter 3: Comparative Accounting: Europe1Learning ObjectivesUnderstand how financial reporting is regulated and enforced in five European countries: France, Germany, the Czech Republic, the Netherlands, and the U.K.Describe the key similar

2、ities and differences between the accounting systems of these five countries.2Identify 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 fiv

3、e countries.3IFRS in the European Union Starting in 2005, all EU-listed companies must follow IFRS in their consolidated financial statements.Generally, IFRS consolidated statements are permitted for non-listed companies.Requirements for individual company financial statements vary IFRS may be requi

4、red, allowed, or prohibited.4IFRS (contin)IFRS are based on fair presentation principlesIFRS may be overridden in rare circumstances to achieve fair presentationAccounting measurementsBusiness combinations purchase accountingGoodwill annual impairments testInvestments in associates equity methodTran

5、slation of financial statements of foreign operations functional currency concept6Assets valued at historical cost or fair valueResearch costs expensed; development costs capitalizedLIFO （Last in, First out ）not allowedFinance leases capitalized; operating leases expensedProvisions recognized when p

6、robable and estimableDeferred taxes recognized in full, using the liability method, for temporary differences between the carrying amount and tax base7France Overview“The Plan” national uniform chart of accounts (national accounting code)Objectives and principles of financial reportingDefinitions of

7、 elementsRecognition and valuation rulesStandardized chart of accountsModel financial statementsOther influences on French accounting rulesCommercial legislation (Code de Commerce)Tax laws9France (contin)Accounting regulation and enforcementCNC National Accounting BoardKeeps plan currentMakes ruling

8、s and recommendations on accounting issuesCRC Accounting Regulation CommitteeConverts CNC rulings and recommendations into binding regulations10AMF Financial Markets AuthoritySupervises securities marketsOEC Institute of Public AccountantsRepresents the accounting professionMembers prepare financial

9、 statements, and provide tax, information systems, and management advisory services11CNCC National Institute of Statutory AuditorsMembers audit and give an opinion on financial statementsMust report criminal acts to the High Council of External AuditorsSubstantial overlap in OEC and CNCC membershipS

10、tatutory auditors not allowed to provide accounting services to the same clientAMF oversees audits of listed companies, but relies on a committee of the CNCC to conduct audit-quality reviews12France (contin)Unusual features of French financial reportingMust report results of environmental activities

11、Reports aimed at preventing bankruptciesSocial report13GermanyOverviewCreditor protectionConservative 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

12、 made to owners14Germany (contin)Accounting regulation and enforcementGerman Commercial Code (HGB) Applies to all business entitiesGerman Accounting Standards Board Develops recommendations for consolidated financial statements16Financial Reporting Enforcement Panel Enforces compliance with German f

13、inancial reporting requirements and IFRS by listed companiesChamber of Accountants Oversees WPs (“enterprise examiners”)Unusual features of German financial reportingAuditors private report to board of directors and supervisory board on companys future prospects17Accounting regulation and enforcemen

14、tMinistry of FinanceOversees Commercial Code (modeled on German commercial law)Oversees Accountancy Act (based on EU directives)Chamber of AuditorsOversees auditorsUnusual features of Czech financial reportingForm over substance still applies in some casesStill implementing accounting practices cons

15、istent with EU directives and IFRS19The NetherlandsOverviewAccounting paradoxesPermissive requirements, but high professional practice standardsCode law country whose accounting is oriented toward fair presentationFair presentation orientation developed without a strong stock marketOther influences

16、on Dutch accountingU.K. and U.S. as much as continental European countriesAccounting professionBusiness economics (microeconomics)IASB20The Netherlands (contin)Accounting regulation and enforcementCompany law Act on Annual Financial StatementsDutch Accounting Standards BoardDevelops guidelines on ge

17、nerally acceptable accounting standardsEnterprise ChamberEnforces compliance with accounting requirementsNIvRAOversees auditing professionUnusual features of Dutch financial reportingFinancial statements may be in Dutch, French, German, or EnglishOther than consolidated financial statements of Dutch

18、 listed companies, financial statements may be based on Dutch guidelines, IFRS, or a combinationFlexible accounting measurementsCurrent values are permitted for tangible assetsOpportunities for income smoothing21United KingdomOverviewLegacy of British accountingFirst country to develop an accountancy professionFair presentation (true and fair view)Exported British accounting around the world22United Kingdom (contin)Accounting regulation and enforcementCompanies ActBroad finan