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1、1,International Accounting, 6/e,Frederick D.S. Choi Gary 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 d
2、ifferences 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 countrie
3、s.,3,The relationship between accounting standard and practice,The definition of accounting standard Does accounting practice always follow what accounting standard requires? (page 38) Penality Voluntary supply more information Permission to not comply with accounting standards if Question: Does the
4、 relationship between 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 consolid
5、ated statements are permitted 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 principles IFRS may be overridden in rare circumstances to achieve fair p
6、resentation Accounting measurements (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 test Negative goodwill being immediately recognized in income,7
7、,IFRS (to be continued),Accounting measurements Translation of financial statements of foreign operations functional currency concept (p130) Assets valued at historical cost or fair value Research costs expensed; development costs capitalized LIFO not allowed Finance leases capitalized; operating le
8、ases expensed Provisions recognized when probable and estimable Deferred taxes recognized in full, using the liability method, for temporary differences between the carrying amount and tax base,8,9,France,Overview Focus on needs of creditors and tax authorities Consolidated groups can report in U.S.
9、 GAAP or IAS Company law and tax law are the predominant influences Focus on national economic planning Tax laws tend to override accounting rules Small accounting profession established by law OECand CNCC for public accounting and auditing Accounting and auditing profession are separate Small stock
10、 market Most capital contributed by banks, government, or family French 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
11、 of financial reporting Definitions of elements Recognition and valuation rules Standardized chart of accounts Model financial statements Other influences on French accounting rules Commercial legislation (Code de Commerce) Tax laws,11,France (to be continued),Accounting regulation and enforcement (
12、p43) CNC National Accounting Board Keeps plan current Makes rulings and recommendations on accounting issues CRC Accounting Regulation Committee Converts CNC rulings and recommendations into binding regulations Real regulatory power AMF Financial Markets Authority (French equivalent of the U.S. Secu
13、rity Exchange Committee) Supervises securities markets Two divisions,12,Accounting regulation and enforcement OEC Institute of Public Accountants Represents the accounting profession Members prepare financial statements, and provide tax, information systems, and management advisory services Be under
14、 the juridiciton of the Ministry of Economy and Fiance CNCC National Institute of Statutory Auditors Members audit and give an opinion on financial statements Must report criminal acts to the High Council of External Auditors Substantial overlap in OEC and CNCC membership Statutory auditors not allo
15、wed to provide accounting services to the same client AMF oversees audits of listed companies, but relies on a committee of the CNCC to conduct audit-quality reviews,13,France (to be continued),Unusual features of French financial reporting Must report results of environmental activities Reports aim
16、ed at preventing bankruptcies Social report No requirements for a statement of changes in financial position or a cash flow Being prepared in compliance with legislation and in good faith,14,France (to be continued),Accounting measurement (p45-46) Tangible assets Depreciation expense of fixed assets Inventory being measured at the lower of cost or realizable value R&D expensed as incurred in general R&D capitalized in restricted circumstances with less
