Comparative international accounting systems and practices

Exposé Comptabilité & finances Comptabilité

Date de publication :

28/09/2006

Langue :

Anglais

Format :

.doc

Nombre de pages :

26 pages

Niveau :

grand public

Consulté :

3 fois

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Sommaire :

Sommaire

Anglo-saxon accounting
1. United states
2. United kingdom
Nordic accounting
1. The netherlands
2. Sweden
Germanic accounting
1. Germany
2. Switzerland
Latin accounting
1. France
2. Italy
Asian accounting
1. Japan

Résumé :

There is no doubt that Anglo-Saxon accounting can be distinguished from accounting in continental Europe, Asia, Latin American, and many other parts of the world. It is practiced not only in the United States and United Kingdom, but also to an important extent in countries where, for example, the United Kingdom has had a major colonial influence, such as in Australia, Canada, Hong Kong, India, Ireland, Kenya, Malaysia, New Zealand, Nigeria, Singapore, and South Africa. Anglo-Saxon accounting tends to be relatively optimistic and transparent compared to the Germanic and Latin countries, as well as Japan.
In many Ways, accounting in the United Kingdom is very similar as might be expected given the importance or the historical and investment connections between the two countries. Just as the language and legal system were exported from the United Kingdom to the United States, so were the founding fathers of U.S accounting, including pioneers such as Arthur Young (a Glasgow University graduate of the 1880s). Nevertheless, the United States has adapted rather than adopted the United Kingdom accounting tradition. Indeed, the more recent historical and environmental circumstances of the United States have given rise to some significant distinguishing features.
The securities markets are the dominant influence on accounting regulation in the United States. Dealings in securities and investor protection are regulated and enforced at the federal government level under the Securities Act of 1933 and the Securities Exchange Act of 1934, which were passed in response to the stock market crash of 1929 and subsequent financial crises.
The Securities and Exchange Commission (SEC) was established with the legal authority to enforce the securities laws and also to formulate as well as enforce accounting standards. However, the SEC recognizes as authoritative the "Generally Accepted accounting Principles" (GAAP) embodied in standards issued by an independent Financial accounting Standards Board (FASB), witch was established in 1973 following criticism of the standard setting procedures of the American Institute of Certified Public Accountants, thus the standard setting role has been delegated to the FASB with the SEC acting in only a supervisory capacity unless it deems it necessary to intervene, which it has done on only rare occasions (e.g. With respect to oil and gas accounting). Corporations are required to follow EASB standards; otherwise the SEC will refuse registration and hence trading in their securities. It should be noted that only listed corporations (a minority of U.S. corporations) are required to comply with the very detailed regulations imposed by the SEC for investor protection purposes.
The FASB has a very open approach to standard setting known as operating in the "sunshine". All meetings are open to the public and a variety of opinions sought in an elaborate "due-process" in an effort to ensure that the public interest is properly served. In order to help formulate new standards and improve existing ones; the FASB has developed an explicit conceptual framework of objectives and qualitative characteristics of financial reporting in its series of statements of financial accounting concepts.
The Fast's pronouncements on accounting practice are issued as "Statements of Financial accounting Standards" (SFAS). More Than 100 of these had been issued by 1991. Taken overall, the FASB Standards are quite detailed and voluminous compared to U.K standards, for example, this suggest that while the United Stats is similar in many ways to the United Kingdom and Other Anglo-Saxon countries, it is unique in having perhaps the most comprehensive system of accounting regulations in the world, at least so far as securities markets are concerned.