Comparative Accounting PERTEMUAN 5 EBA 604 AKUNTANSI INTERNASIONAL

Comparative Accounting PERTEMUAN #5 EBA 604 AKUNTANSI INTERNASIONAL PROGRAM STUDI AKUNTANSI FAKULTAS EKONOMI DAN BISNIS UNIVERSITAS ESA UNGGUL

Comparative Accounting Chapter Topics Accounting environment, profession, regulation, principles/practices, and differences to IFRSs in • China • Germany • Japan • Mexico • United Kingdom 5 -2

Comparative Accounting Learning Objectives 1. Describe some aspects of the environment in which accounting operates in five countries: China, Germany, Japan, Mexico, and the United Kingdom. 2. Explain the nature of the accounting profession in selected countries. 3. Discuss the mechanism in place for regulating accounting and financial reporting in selected countries. 5 -3

Comparative Accounting Learning Objectives 4. Examine some of the accounting principles and practices used by companies in these countries. 5. Identify the areas where national accounting practices in these countries differ from International Financial Reporting Standards (IFRSs). 5 -4

China Background • World’s largest country with population of over 1. 2 billion. • People’s Republic of China (PRC) established in 1949. • Politically: Communist, one-party state. • Economically: Until the 1980 s, all firms state-owned. • Currently in transformation to market economy. • World’s fourth largest economy and fastest growing among large economies, largest recipient of FDI. Learning 5 -5 Objective 1

China Background • First securities regulations adopted in 1984. • Two major stock exchanges, Shanghai and Shenzhen established in 1990 and 1991. • Government controls capital market via Chinese Security Regulatory Commission (CSRC) similar to SEC. • Domestic companies list four types of shares: A, B, C, H. • Market characterized by speculation, high share turnover. Learning 5 -6 Objective 1

China Accounting Profession • Profession less prestigious than in U. S. /UK. • Accounting and auditing have developed separately. • Chinese Institute of Certified Public Accountants (CICPA) and Chinese Association of Certified Practicing Auditors (CACPA) merged in 1998. • Economic reform and the large number of joint ventures with foreigners has led to emergence of audit profession. Learning 5 -7 Objective 2

China Accounting Regulation • Recent activity is focused on harmonizing variety of domestic systems which vary by industry. • Committed to converging with IFRS, spurred by desired membership in World Trade Organization (WTO). • Audits of financial statements widely required. • Death penalty in an accounting fraud case suggests that it is taken very seriously. • Ministry of Finance (Mo. F) in similar role as FASB. Learning 5 -8 Objective 3

China Accounting Principles and Practice • Computation of taxable income of primary importance. • Conservatism criticized as a method by which owners can understate income and justify low wages. • Lack of conservatism still a difference with IFRS. • Lack of accounting infrastructure contributes to gap between accounting principles and practice. • Accounting System for Business Enterprises (ASBE) followed by over 500, 000 firms, including all listed companies. Learning 5 -9 Objective 4

China Differences to IFRSs • Property, plant, and equipment -- historical cost, IAS 16 permits revaluations. • Borrowing costs for self-constructed assets – require capitalization, IAS 23 allows capitalization or expensing. • Asset impairments – Chinese standards are silent, IAS 36 requires impairment test and recognition of loss. • Preoperating expenses – deferred, then expensed when operations begin, under IAS 38, expense immediately. Learning 5 -10 Objective 5

Germany Background • European Union’s largest country, population 83 million. • West Germany and East Germany established in 1949, reunified in 1990. • Historically, banks have been primary source of finance via both loans and equity. • Since reunification, the economy has been affected by internationalization. Learning 5 -11 Objective 1

Germany Background • German companies increasingly listing on foreign exchanges, e. g. , New York Stock Exchange. • Most common business forms are Aktiengesellschaft (AG) and Gesellschaft mit beschrankter Haftung (GMBH). • AG are publicly traded/GMBH are non-publicly traded. • Historically had significant influence on accounting systems in a number of other countries. • Japan’s commercial code is modeled on Germany’s. Learning 5 -12 Objective 1

Germany Accounting Profession • Profession has traditionally been less influential than in U. S. /UK. • Auditing is dominant part of profession, certified auditors title of Wirtschaftprufer (WP) was created in 1931. • Institut der Wirtschaftprufer similar to the AICPA. • Obtaining WP title is extremely rigorous. • Wirtschaftpruferkammer (WPK) is state sponsored group that oversees auditing profession. Learning 5 -13 Objective 2

Germany Accounting Regulation • Commercial code and tax laws are main sources of accounting rules. • Stock exchange rules have less influence than in U. S. • Prudence is fundamental, recognition of revenues only when realized, losses when they appear possible. • Began change away from creditor orientation in 1960 s. • Starting in the 1980 s, EU directives began having major influence. Learning 5 -14 Objective 3

Germany Accounting Principles and Practices • Historical cost attribute for measuring tangible assets is adhered to. • Traditional focus on creditor protection is at odds with the true and fair view concept. • Importance of tax laws led to the reverse authoritative principle which requires expenses to be deducted from accounting income if they are to be tax deductible. Learning 5 -15 Objective 4

Germany Accounting Principles and Practices • In contrast to China, conservatism has been used to resist labor’s wage demands. • Standards allow for income smoothing, frequently accomplished via early recognition of losses. • EU fourth directive requires true and fair view, but Germans have a unique interpretation of the concept. • Commitment to globalization reflected in rule that allows public companies to use IFRS for consolidated statements. Learning 5 -16 Objective 4

Germany Differences to IFRSs • Goodwill – deducted immediately against equity, under IFRS 3, accounted for as an indefinite life intangible asset. • Internally generated intangibles – not recognized, under IAS 38, recognized as an asset under some conditions. • Leases – accounting uses tax rules with capitalization rare, IAS 17 criteria result in more frequent capitalization. • Accounting for subsidiaries – allow exclusion of dissimilar subsidiaries, which are consolidated under IAS 27. Learning 5 -17 Objective 5

Japan Background • Population 127 million, world’s third largest economy. • Banks are primary source of finance via both loans and equity, cross-corporate equity ownership also common. • Keiretsu (and predecessor Zaibatsu) emphasize close business ties and reflect cultural value of collectivism. • 1990 s recession led to and increase in Japanese firms attempts to obtain capital internationally. Learning 5 -18 Objective 1

Japan Accounting Profession • Certified Public Accountants Law (1948) established the profession. • Profession is significantly less influential than in U. S. /UK and is also much smaller in numbers than U. S. • Obtaining CPA title extremely rigorous, like in Germany. • Collectivism leads to lack of trust of auditors. • Tax advising is a much larger, separate, profession. Learning 5 -19 Objective 2

Japan Accounting Regulation • Government influences accounting via Commercial Code, Corporate Income Tax Law and Stock Exchange Law. • Similar to Germany, strong creditor orientation and accounting rules closely tied to tax rules. • Big Bang financial reforms are leading to harmonization with international standards. • These reforms included requirements for consolidation and fair value accounting for tradable securities. Learning 5 -20 Objective 3

Japan Accounting Principles and Practices • In contrast to U. S. , net income is less a measure of performance and seen more as funds available for dividends. • Since providers of financing tend to be close to the firm, there has historically been little pressure for disclosure. • Lack of disclosure is apparent in segment reporting. • In 2005, IASB and Accounting Standards Board of Japan agreed to work toward reducing differences. Learning 5 -21 Objective 4

Japan Differences to IFRSs • Revaluation of Land – allowed but updating not required, under IFRS 16, revaluations require regular updating. • Preoperating costs – capitalization is allowed, under IAS 38, expensed immediately. • Construction contracts – completed contract method is allowed, IAS 11 essentially requires percentage-of-completion. • Provisions – allow for provisions, prior to actual obligation, IAS 37 only allows for present obligations. Learning 5 -22 Objective 5

Mexico Background • History of significant inflation, government control of business is partially blamed for this. • Significant changes in 1990 s, including privatization of state-owned firms and NAFTA. • Historically, most businesses family-owned, even the very large. • Mexico’s one stock exchange, the Bolsa Mexicana de Valores, is privately-owned. Learning 5 -23 Objective 1

Mexico Accounting Profession • The Associacion de Contadores Publicos, first professional accountant organization, established in 1917. • This group was succeeded by the Mexican Institute of Public Accountants (MIPA) in 1964. • MIPA establishes accounting and auditing principles and was an original founding member of the IASC in 1973. • In order to practice public accounting in Mexico, one needs a “professional diploma. ” Learning 5 -24 Objective 2

Mexico Accounting Regulation • The Mexican Securities Law (1975), was amended in 1993 to comply with NAFTA issues. • Accounting standards, grounded in a conceptual framework, have four classes of Bulletins, A, B, C, and D. • Corporate tax rules require a report in accordance with Mexican GAAP audited in accordance with Mexican GAAS. Learning 5 -25 Objective 3

Mexico Accounting Principles and Practices • Mexican GAAP heavily influenced by U. S. GAAP due to NAFTA, geographical proximity, and comprehensiveness of U. S. GAAP. • Despite international influences, Mexico’s Bulletin B-10, on inflation accounting, shows how harmonized accounting may not be appropriate for all circumstances. Learning 5 -26 Objective 4

Mexico Accounting Principles and Practices • Bulletin B-10, Recognition of the Effects of Inflation, reflects a major difference to U. S. GAAP. • Nonmonetary assets and liabilities to be restated for purchasing power changes of the peso. • Inventory can be restated using current replacement costs. • Recognition in income (generally) of the gain or loss from the net monetary position, asset or liability. Learning 5 -27 Objective 4

Mexico Differences to IFRSs • Statement of cash flows – statement of changes in financial position required, IAS 7 requires a statement of cash flows. • Inflation Accounting – requires inflation adjustments regardless of inflation rate, IAS 29 requires only for hyperinflationary countries. • Negative Goodwill – recorded as a deferred credit and amortized over five years, IAS 3 requires immediate recognition of gain. Learning 5 -28 Objective 5

United Kingdom Background • Population of about 60 million, comprised of England, Northern Ireland, Scotland, and Wales. • Among five countries in this chapter, its financial structure is closest to the U. S. • 15, 000 Private Limited Companies (PLCs) with about 2, 500 of these listed on the London Stock Exchange. Learning 5 -29 Objective 1

United Kingdom Accounting Profession • World’s first association of professional accountants, The Society of Accountants in Edinburgh established in 1853. • The profession developed in response to the needs of industry and has influenced the development of professions in a number of other countries. • Compared to the U. S. the certification requirements focus more on work experience and less on university education. Learning 5 -30 Objective 2

United Kingdom Accounting Regulation • The Companies Act, accounting pronouncements, and stock exchange rules comprise accounting regulation. • Similar to the U. S. , and unlike Germany and Japan, tax rules do not significantly influence financial reporting. • Standard-setters have historically taken a principlesbased approach using a statement of principles as a conceptual framework. • Has not historically had a strong, SEC type agency, but recent scandals have led to increased regulation. Learning 5 -31 Objective 3

United Kingdom Accounting Principles and Practices • A primary objective of accounting is to support an effective capital market. • The true and fair view principle is paramount. • True and fair view override requires that companies not comply with standards that would result in misleading financial statements. Learning 5 -32 Objective 4

United Kingdom Differences to IFRSs • Goodwill – amortization allowed, IFRS 3 prohibits amortization and requires an annual impairment test. • Related party disclosures – requires disclosure of related party names, IAS 24 requires disclosure by type, not name, of related party. • Revaluation gains/losses – generally not taken to income statement, IAS 40 requires gains and losses to affect net income. Learning 5 -33 Objective 5

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