《比较会计欧洲》PPT课件.ppt

1,第三章 比较会计:欧洲,Comparative Accounting: Europe,2,会计准则与会计实务的关系,会计准则与会计实务经常发生背离现象。主要原因在于： 许多国家对违背会计准则行为的处罚很轻微； 公司可以自愿披露超过准则规范的信息； 一些国家许可公司在报告会计信息时悖离准则，如果这样做能够更好地反映公司的经营成果和财务状况。 一些国家仅仅要求个别公司运用会计准则而不要求合并报表遵循会计准则。,3,第二章分析了普通法和成文法国家中会计模式的差异。这种差异对会计准则制订的影响表现为： 在普通法国家中，会计准则多由民间机构制定，准则及其制订过程较多受到公允表达理念的影响； 在成文法体系国家中，其会计准则多是由立法机构或政府部门制订，准则制订过程首先关注会计信息对法律规定的执行和遵守。,4,会计准则是规范财务报表的法规或规则。会计准则的制定过程实质上是影响会计准则的各方面社会力量协调过程。 会计准则与会计实务的关系十分复杂，而且不是一成不变的。 在某些情况下，实务来源于准则的规范和指导，而在另外一些情况下，准则来源于对实务的总结和归纳。 一旦准则制定之后，实务与准则之间也会经常产生差异。影响差异产生的原因图示如下：,5,在财务报告中，最关键的区别是会计被定位于对财务状况和经营成果的“公允”反映还是对法律要求的遵循,资本主要来自于分散的股东,微观基础 公允反映 强调自律和职业判断,成文法体系,宏观统一 强调会计报表和财务报告的守法合规 服务于国家经济发展,普通法体系,资本主要来自于银行和政府,6,本章选取法国、德国、捷克、荷兰、英国5个欧洲国家，分析比较这些国家会计模式的差别。 5个国家中的法国、德国、荷兰是欧共体（欧盟前身）1957年建立时的成员国，英国于1973年加入欧共体；这4个国家的会计职业组织都是IASC的创建者。 捷克原先是前苏联会计模式的代表，体现了计划经济向市场经济转化的特征；捷克于2004年加入欧盟。,7,France,France is the worlds leading advocate of national uniform accounting. The mandatory use of the national uniform chart of accounts does not burden French businesses because the plan is widely accepted in practice. A feature of French accounting is the dichotomy between individual company financial statements and those for the consolidated group.,8,The Plan Comptable Gnral（national accounting code）provides: Objectives and principles of financial accounting and reporting； Definitions of assets，liabilities，shareholders equity，revenues，and expenses； Recognition and valuation rules； A standardized chart of accounts，requirements for its use，and other bookkeeping requirements。 Model financial statements and rules for their presentation。,9,Even though individual company accounts must follow statutory reporting requirements，the law allows French companies to follow IFRs. The main reason for this flexibility is that when the EU Seventh Directive was implemented in 1986.,10,Financial Reporting French companies must report the following: Balance sheet Income statement Notes to financial statements Directors report Auditors report,11,To give a true and fair view，financial statements must be prepared in compliance with legislation and in good faith. A significant feature of French reporting is the requirement for extensive and detailed footnote disclosures。 French law also contains provisions aimed at preventing bankruptcies. The idea is that companies with a good understanding of their internal financial affairs and that prepare sound projections can better avoid financial difficulties.,12,Accordingly，larger companies (those with net sales in excess of 18 million or more than 300 employees) prepare four documents: a statement of cash position，a statement of changes in financial position or cash flow statement，a forecast income statement，and a business plan. A social report also is required of all companies with 300 or more employees.,13,Accounting Measurements(p.59) French accounting is characterized by a duality: individual companies must follow fixed regulations while consolidated groups have more flexibility. Accounting for individual companies is the legal basis for distributing dividends and for calculating taxable income.,14,法国会计的特征,强调会计信息的处理过程与税法税则保持一致(形式重于实质） 实行统一的会计制度 积极推广社会责任会计 高度稳健 通过企业会计与合并会计的脱钩来解决国际惯例与国家特色的矛盾。,15,Germany,The German accounting environment has changed continuously and remarkably since the end of world War . At that time， business accounting emphasized national and sectional charts of account (as in France). In a major turn of events， the 1965 Corporation Law moved the German financial reporting system toward British-American ideas.,16,Two new laws were passed in 1998. The first added a new paragraph in the third book of the German Commercial Code allowing companies that issue equity or debt on organized capital markets to use internationally accepted accounting principles in their consolidated financial statement. The second allowed the establishment of a private-sector organization to set accounting standards for consolidated financial statements.,17,Three characteristic of German accounting Creditor protection is a fundamental concern of German accounting as embodied in the Commercial code. Conservative balance sheet valuations are central to creditor protection. This creates a tendency to undervalue assets and overvalue liabilities. Reserves are seen as protection against unforeseen risk and possible insolvency. German accounting is designed to compute a prudent income amount that leaves creditors unharmed after distributions are made to owners.,18,The second fundamental characteristic of German accounting is Tax law also largely determines commercial accounting. The determination principle states that taxable income is determined by whatever is booked in a firms financial records. The dominance of tax accounting means that no distinction is made between financial statements prepared for tax purposes and those published in financial reports.,19,The third fundamental characteristic of German accounting is its reliance on statutes and court decisions. Nothing else has any binding or authoritative status. To understand German accounting， one must look to both HGB (German Commercial Code) and a considerable body of case law.,20,Accounting Regulation and Enforcement Before 1998 Germany had no financial accounting standard-setting function， as it is understood in English-speaking countries. The German Institute provided consultation in various processes of lawmaking that affected accounting and financial reporting. Similar consultation was given by the Frankfurt Stock Exchange，German trade unions，and accounting academics.,21,The 1998 law on control and transparency introduced the requirements for the Ministry of Justice to recognize a private national standard-setting body to serve the following objectives: Develop recommendations for the application of accounting standards for consolidated financial statements. Advise the Ministry of Justice on new accounting legislation. Represent Germany in international accounting organization such as the IASB,22,The German Accounting Standards Committee(GASC) was founded shortly thereafter，and duly recognized by the Ministry of Justice as the German standard-setting authority. The GASC oversees the German Accounting Standard Board， which does the technical work and issues the accounting standards. The GASB is made up of seven independent experts with a background in auditing，financial analysis，academia，and industry.,23,It is important to emphasize that GASB standards are authoritative recommendations that only apply to consolidated financial statements. The German auditing profession is small. Two classes of auditors are legally sanctioned to conduct independent audit examinations of companies.,24,Financial Reporting The 1985 accounting Act specifies different accounting，auditing，and financial reporting requirements according to company size，not according to the form of business organization. There are three size: classes-small，medium，and large- defined in terms of balance sheet totals，annual sales totals，and numbers of employees. Companies with publicly traded securities are always classified as large.,25,The 1985 Accounting Act specifies the content and format of financial statements， which include the following: Balance sheet Income statement Notes Management report Auditors report,26,Small companies are exempt from the audit requirement and may prepare an abbreviated balance sheet. Small and medium-sized companies may prepare abbreviated income statements， and fewer disclosure requirements for their notes as well.,27,A feature of the German financial reporting system is a private report by the auditors to a companys managing board of directors and supervisory board. This report comments on the companys future prospects and，especially，factors that may threaten its survival. This report can run several hundred pages for large German companies. But it is private information， not available to shareholders.,28,Accounting Measurements(p.64) Because of Conservative idea，provisions as estimates of future expenses or losses are used heavily. Provisions must be set up for deferred maintenance expenses，product guarantees，potential losses from pending transactions，and other uncertain liabilities.,29,Most companies make provisions as large as possible because legally booked expenses directly affect the determination of taxable income. Provisions give German companies many opportunities to smooth income.,30,德国会计的特征,经济政策法制化-通过政治法律制度制约和调节市场经济运行，影响会计选择。 税法和税则对企业会计有重要影响，各纳税主体必须符合税法的要求。 企业可以根据法律的许可提取大量的准备。 德国财务报表披露的会计信息非常稳健，能够在相当程度上抗衡和化解市场经济中的风险，从而有效地保护企业的经济实力。,31,Czech Republic (CR),自20世纪起，捷克的会计模式经历了多次导向性变革。二战之前，捷克会计原则深受欧洲德语系国家影响。在二战之后，捷克作为东欧社会主义阵营的成员，其会计规范转向苏联统一会计模式。而1989年以后，捷克开始由计划经济向市场经济转型，其会计规范也发生了重大转变。 1991年捷克议会通过了会计法，该法案在很大程度上遵循了欧盟第四号和第七号指令，并借鉴了国际会计准则的相关规定。,32,As a centrally planned economy was being constructed， Czech accounting practice was based on the soviet model. The administrative needs of various central government institutions were satisfied through such features as a uniform chart of accounts，detailed accounting methods，and uniform financial statements，obligatory for all enterprises.,33,After 1989 Czech moved quickly toward a market-oriented economy， relatively accounting turned westward，reflecting the principles embodied in the European Union Directives.,34,Accounting regulation and enforcement The new Commercial Code was enacted by Parliament in 1991 and became effective on January 1，1992. This legislation includes requirements for annual financial statements，income taxes， audits，and shareholdersmeetings. The Accountancy Act that sets out the requirements for accounting was passed in 1991 and became effective on January 1，1993.,35,1991年会计法强调运用账户表（欧盟为了保持各国会计信息的可比性而制定）进行会计记录和编制报表，并引入了“真实与公允”和“实质重于形式”原则。但由于当时的捷克会计实务界习惯于计划经济体制下会计模式，财务信息需求主体也未真正形成，一系列会计改革措施在实务中并未得到很好的运用。 随着捷克加入欧盟的步伐加快及1991 年会计法日益显露出来的不足， 捷克共和国于2000 年起对会计法重新进行修订并于2002 年1 月1 日开始实行修订后的会计法。,36,The Accountancy Act was significantly amended with effect from January 1，2002， primarily to bring Czech accounting closer to IAS/IFRs. The Ministry of Finance is responsible for accounting principles. Ministry of Finance decrees set out acceptable measurement and disclosure practices that companies must follow. Thus，accounting in the CR is influenced by the Commercial Code，the Accountancy Act，and Ministry of Finance decrees.,37,Auditing is regulated by the Act on Auditors，passed in 1992. This act established the Chamber of Auditors，a self-regulated professional body that oversees the registration，education， examination，and disciplining of auditors，the setting of auditing standards，and the regulation of audit practice，such as the format of the audit report.,38,The audit is designed to ensure that the accounts have been kept according to applicable legislation and decrees and that the financial statements present a true and fair view of the companys financial position and results.,39,Financial Reporting Financial statements must be consisting of: Balance sheet Profit and loss account (income statement) Notes (include a cash flow statement) Czech companies have the option of using IAS/IFRS or Czech accounting standards in preparing the their consolidated financial statements. However，listed Czech companies are required to prepare audited financial statements according to IAS/IFRS.,40,Accounting Measurements(p.68) Goodwill arising from a business combination is written off in the first year of consolidation or capitalized and amortized over no more than 20 years. Leased assets are typically not capitalized-an example of form over substance. Legal reserves are required: Profits are appropriated annually until they reach 20% of equity for corporations and 10% for limited liability companies.,41,捷克的会计规范改革进程是不断向国际会计准则靠拢并以其为最终目标的过程， 该进程中较少保留捷克的本土特色。 这是由于捷克的筹资渠道、与欧洲大陆政治、经济的密切联系等因素不断作用的结果，同时也是由于捷克在历史传统上就没有太多自己的特色， 其大多数时间都是融于欧洲大陆模式，特别是德语国家模式之中。并且，捷克会计国际化也是由于欧盟会计国际化进程加快这一外在因素推动所致。,42,The Netherlands,Dutch accounting presents several interesting paradoxes as follow: The Dutch have relatively permissive statutory accounting and financial reporting requirements but very high professional practice standards. The Netherlands is a code law country， yet accounting is oriented toward fair presentation. Financial reporting and tax accounting are two separate activities. Furthermore， the fairness orientation developed without a strong stock market influence.,43,Accounting in the Netherlands is considered a branch of business economics. As a result，much economic thought has been devoted to accounting topics and especially to accounting measurements. Highly respected professional accountants are often part-time professors. Thus，academic thought has a major influence upon ongoing practice.,44,Dutch accountants are also will to consider foreign ideas. The Netherlands is also home to several of largest multinational enterprises in the world. These large multinationals have influenced financial reporting of other Dutch companies.,45,Accounting Regulation and Enforcement Accounting regulations in the Netherlands remained liberal until 1970，when the Act on Annual Financial Statements was enacted. Among the major provisions of the 1970 act on the P.55.,46,The council for Annual Reporting issues guidelines on generally acceptable accounting principles. The council is a private organization and is financed by grant from the business community and NIvRA. Even though the councils guidelines do not have the force of law， they are followed by most large companies and auditors.,47,荷兰年报条例（the Act on Annual Accounts Statements）对荷兰企业的财务报告制定了基本的法律要求，适用于荷兰的所有企业，包括上市公司和非上市公司。 条例主要包括三部分内容：一般要求、披露要求和关于“企业庭”（the Enterprise Chamber）的规则。 “企业庭”是阿姆特丹法院特高下设的一个法庭，专门负责解决公司和与其财务报告有利害关系的各方出现的争端。,48,根据年报条例，与某公司财务报告有直接利害关系的个人和组织，在该公司财务报告公布日或批准日之后两个月内可以就该公司财务报告的虚假和失误等问题向企业庭提出控告。 Chamber decisions may lead to modifications of financial statements or various penalties. Even thought the rulings apply only to defendant companies， they sometimes state general rule that may influence the reporting practices of other companies.,49,Auditing in the Netherlands is a self-regulated profession. Its governing body is the Netherlands Institute of Register-accountants (NIvRA)， which has approximately 13000 members. It is fully autonomous in setting auditing standards and its strong professional code of conduct has statutory status.,50,Financial Reporting The quality of Dutch financial reporting is uniformly high. Statutory financial statements should be filed in Dutch，but English，French，and German are also acceptable. The financial statements must include the following: Balance sheet Income statement Notes Directorsreport Other prescribed information,51,A cash flow statement is not required，but is recommended by a council guideline，and most Dutch companies provide one. Small companies are exempt from the requirements for an audit，and they may file an abbreviated income statement and balance sheet.,52,Medium-sized companies must be audited，but may publish a condensed income statement. Small，Medium-sized，and large companies are defined in the civil code. Dutch companies are permitted to prepare financial statements using IFRS or U.S. GAAP instead of Dutch accounting standards.,53,Accounting Measurements(p.72) The Dutch flexibility toward accounting measurements may be most evident in permitting the use of current values for tangible assets. Because Dutch companies have flexibility in applying measurement rules，one would suspect that there are opportunities for income smoothing. In addition，certain items can bypass the income statement through direct adjustment to reserves in shareholdersequity.,54,荷兰会计的特征,1.荷兰的财务会计与税务会计截然分开，税法对财务报告的影响不大。 2. 荷兰是唯一设置会计法庭的国家。隶属于会计法庭的商会可就报表争议对企业采取法律行为。 3荷兰会计的重要特征是极端的自由选择与高度的职业标准相结合。,55,United Kingdom,Accounting in the United Kingdom developed as an independent discipline， pragmatically responding to the needs and practices of business. Over time，successive companies laws added structure and other requirements，but still allowed accountants considerable flexibility in the application of professional judgment.,56,Since the 1970s the most important source of development in company law has been the EU Directives，most notably the 4th and 7th. At the same time，accounting standards and the standard-setting process have become more authoritative. The United Kingdom was the first country in the world to develop an accountancy profession. The concept of a fair presentation of financial results and position (the true and fair view) is also of British origin.,57,Accounting Regulation and Enforcement 英国会计准则的制定经历了三个阶段: 第一阶段是1970年之前，在公司法规定下，依靠不成文的惯例进行规范； 第二阶段是1970 -1990年，由六大会计团体组建了专门的准则制定机构ASC， 制定书面的、成文的会计准则；,58,第三阶段是1990 年至今。 1990 年8 月，一个独立的机构ASB取代ASC. ASB制订的会计准则称为财务报告准则( Financial Reporting Standards，简称FRS).,59,Financial Reporting British financial reporting is among the most comprehensive in the world. Financial statements generally include: 1. directors report 2. profit and loss account and balance sheet 3. cash flow statement 4. statement of total recognized gains and losses 5. statement of accounting policies 6. notes referenced in the financial statements 7. auditors report,60,Financial statements must present a true and fair view of a companys state of affairs and profits. To achieve this，additional information may be necessary，and in exceptional circumstances requirements may be overridden. The latter is known as the “true and fair override.”,61,Small and medium-sized companies are exempt from many financial reporting obligations. The companies Act sets out size criteria. In general， small and medium-sized companies are permitted to prepare abbreviated accounts with certain minimum prescribed information.,62,Accounting Measurements(p.77) Assets may be valued at historical cost，current cost，or (as most companies do) using a mixture of the two. All U.K. companies are permitted to use IFRS instead of U.K. GAAP. Thus the EU 2005 initiative for listed companies is extended to non-listed U.K. companies as well.,63,英国会计的特征,英国会计的一个最主要的特征是强调“真实和公允”，这一要求在1948年的公司法中最终确定之后一直沿用至今，并通过欧盟指令影响到欧洲大陆的其他国家。 但是英国的法律从未定义过“真实和公允”的概念，它的含义是由会计职业界判断的。这有利于应付错综复杂的实际情况，但难免带来不确定因素，造成实务处理中一些认识和判断上的分歧。,64,一般认为，“真实和公允”是指财务报告符合公认会计原则和公司法，以诚实的态度披露所有真实的、可信的重要信息，不抱偏见，不隐瞒或忽略重大事实；必要时可超出规定要求披露有关细节。 如果在某些情况下，按照公司法和会计准则的要求编制财务报表不能给予“真实和公允”的反映时，公司可以不按公司法和会计准则的要求去做，但必须在报表注释中说明原因和产生的影响。,65,Summary of significant accounting practices (P.78),