Chapter
2
Worldwide accounting diversity
Chapter Outline
I. Considerable differences exist across
countries in the accounting treatment of many items. These differences can result in significantly
different amounts being reported in the financial statements prepared by
companies using different GAAP.
II. A variety of factors influence a country’s
accounting system.
A. Legal system – in code law countries,
accounting rules tend to be legislated; common law countries tend to have a
non-legislative organization that develops accounting standards.
B. Taxation – financial statements serve as the
basis for taxation in many countries.
In those countries with a close linkage between accounting and taxation,
accounting practice tends to be more conservative so as to reduce the amount of
income subject to taxation.
C. Providers of financing – in those countries
in which family members, banks, and the government are the major providers of
business finance, there tends to be less demand for public accountability and
information disclosure. In countries
where shareholders are a major provider of financing, the demand for
information made available outside the company becomes greater.
D. Inflation – countries with chronic high
inflation adopt accounting principles in which traditional historical cost
accounting is abandoned in favor of inflation adjusted figures.
E. Political and economic ties – through
previous colonization, a British style of accounting is used throughout most of
the former British Empire. Ties between countries also help to explain
similarities between the U.S.
and Canada, and
increasingly, the U.S. and Mexico.
III. Differences in accounting across countries
cause several problems.
A. Consolidating foreign subsidiaries requires
that the financial statements prepared in accordance with foreign accounting
rules must be converted into parent company GAAP.
B. Companies interested in obtaining capital in
foreign countries may be required to provide financial statements prepared in
accordance with accounting rules in that country, which are likely to differ
from rules in the home country.
C. Investors interested in investing in foreign
companies may have a difficult time in making comparisons across potential
investments because of differences in accounting rules across countries.
D. There is a lack of quality accounting
standards in some parts of the world.
The 1997 East Asian financial crisis was at least partially attributable
to a lack of high quality accounting in the region.
IV. There are two major classes of accounting
systems, the micro-based class and the macro-uniform class.
A. The micro-based class of accounting is found
in common law countries, where there is a separation of accounting from
taxation, and shareholders are an important source of financing. Information is developed primarily for equity
investors, with adequate disclosure serving as a major objective.
B. The macro-uniform class exists in code law
countries, where accounting serves as the basis for taxation, and families, banks
and government are the major providers of capital. Income measurement is more conservative and
disclosure is lower than in the micro-based class of countries.
V. National culture is another factor long
thought to influence a country’s accounting system. Using Hofstede’s (1980) societal value dimensions, Gray
(1988) developed the following hypotheses:
A. Conservatism hypothesis – countries high on uncertainty avoidance and long-term orientation
and low on individualism and masculinity will foster a more conservative
approach to measurement.
B. Secrecy hypothesis – countries high in power
distance, uncertainty avoidance, and long-term orientation and low on
individualism and masculinity will exhibit more secrecy (less disclosures) in
accounting reports.
C. Research results provide some support for
these hypotheses, especially the hypothesis that culture affects the level of
disclosure in accounting reports.
VI. Nobes introduced a simplified model of the
reasons for international differences in financial reporting in 1998. In this model, the class (A or B) of
accounting used in a country is a function of the strength of the
equity-outsider financing system, which is a function of a nation’s culture,
including its institutional structures.
A. Class A accounting systems are oriented toward
providing information to outside shareholders (less conservative, more
disclosure). This is consistent with the
micro-based class of accounting.
B. Class B accounting systems are geared to
taxation and creditors (more conservative, less disclosure, accounting follows
tax rules).
C. Nobes suggests that countries in Class B
countries that are interested in competing for equity capital will adopt a
Class A accounting system if allowed to do so.
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