Causes and examples of international differences in accounting

By Chan Hoi Leong, Researcher

Topic: Education
Area of discussion: International Accounting
Chapter/Keyword(s): Causes and examples of international differences

Question

“Accounting is affected by its environment, including the culture of the country in which it operates.” (Nobes and Parker (2012), Comparative International Accounting, 12^th ed., Pearson, page 28).

Identify these factors and evaluate their impact on different accounting systems.

Research Essay
Inti International College Subang

1.0 Introduction

        Iqbal (2002, p.2) defines international accounting as “accounting for international transactions, comparisons of accounting principles in different countries, and harmonisation of diverse accounting standards worldwide”. Apparently, accountants from different countries produce dissimilar financial statements due to the differences in inventory valuation, assets measurement, computation of income, disclosure practices, depreciation methods, and et cetera. Eventually, this creates many problems such as difficulties in preparing group accounts and financial statements become incomparable. Most importantly, an awareness and understanding of these differences have led to impressive attempts to reduce them and hasten the global harmonisation. In addition, it helps us to justify the reasons for these variations in financial reporting in the past, why they continue in the present, and will not disappear in the future. Below is a detailed discussion on the environmental factors and national culture, which affect a country’s accounting system and contributed to the worldwide accounting diversity.

2.1 Legal systems

            Basically, common law and codified Roman law are the two main types of legal systems used globally. Historically, common law system was originated from England and the countries which are utilising it usually rely on a limited number of statute law, which is then interpreted by the courts and formed case law to supplement the statutes. On the other hand, code law was derived from Roman jus civile; it was compiled by Justinian and developed further by European universities during the Middle Ages (Nobes & Parker 2012, p.31). Frankly, a country’s legal system has a direct impact on accounting; it determines the primary source of accounting rules which can be either developed by the government or a non-governmental organisation and also decides the extent to which company law governs the regulation of accounting (Radebaugh, Gray & Black 2006, p.17).

            In code law countries such as France, Italy and Germany, accounting is regulated largely via an accounting code which is typically prescriptive, detailed and procedural. The focus is placed upon the protection of companies’ creditors (Saudagaran 2009, p.5). In fact, accounting profession can hardly influence on the development of accounting standards. Thus, accounting law is usually general. It provides inadequate detail on specific accounting practices whilst certain areas might not have any guidance at all. For instance, the German accounting law which was passed in 1985, consists of only 47 pages in length and is silent with regard to issues such as leases, foreign currency translation and cash flow statements (Doupnik & Perera 2012, p.28).

            By contrast, in common law countries such as England, United States and Australia, specific accounting rules are established by the profession. In short, accounting standards are developed by a non-legislative organisation. Hence, much more detailed rules are developed (Doupnik & Perara 2012, pp.28-29). For example, in the United States, the Financial Accounting Standards Board (FASB) provides a huge amount of guidance in its accounting standards codification and updates until they became “overloaded”. Saudagaran (2009, p.5) highlights that in common law nations, the emphasis in financial reporting is to present a true and fair financial statements to shareholders. Interestingly, researchers reveal that due to the threat of shareholder litigation, companies in common law countries normally have higher levels of disclosures, greater incentives to report losses promptly, timelier financial information as well as being more transparent and efficient as compared to companies in code law countries (Rappeport 2008, pp.41-42).  

2.2 Providers of finance

            In countries where capital markets are strong such as United Kingdom and United States, the stock ownership is more widely dispersed; equity finance is raised from many shareholders who have restricted internal information, via stock exchanges (Radebaugh, Gray & Black 2006, p.16). So, there will be more pressure as greater demand exists for public accountability and information disclosures including unbiased estimate of future prospects as well as forward-looking information which is useful for investment decision making purposes. In term of financial statement orientation, greater emphasis is put on the income statement as shareholders are more interested in profit (Doupnik & Perera 2012, p.30). Consequently, the protection of private shareholders and the prevention of insider trading will also be the main concern. Thus, there will be a need for more auditors to enhance credibility.

            Conversely, in credit-based systems countries such as Germany, France and Japan, company financing is dominated by banks, governments or families. Clearly, such “lenders” have greater direct access to any information they need and can easily influence company management as well as affect company decisions. Hence, extensive public disclosures are limited (Dhaliwal, Khurana & Pereira 2011, p.293; Adhikari & Tondkar 1992, p.84). More emphasis is given on balance sheet as banks are more interested in solvency and liquidity (Doupnik & Perera 2012, p.30). Here, accounting focuses on creditor protection through conservative and prudent accounting measurements as they wanted to know the likelihood of getting their money back (Nobes & Parker 2012, p.35). A research conducted by Francis, Khurana and Pereira (2005, p.1159) suggests that a firm voluntary disclosures are higher when the need for external financing is greater and vice versa.

2.3 Taxation

            In countries like Germany, France and Japan which run on Massgeblichkeitsprinzip (“authoritative principle” or “congruency principle”), published financial statements are utilised as a ground for taxation. Their tax rules are the accounting rules. Accounting and taxation are dependent. At such, they no need to have two sets of rules (Cuzdriorean & Matis 2012, p.32). The problem of deferred tax is small and because of that, there are only a little deferred tax regulations and fiscal influences. Tax regulations set maximum depreciation rates to be applied for particular assets. In most cases, deductible expenses and allowances like accelerated depreciation must be charged in the financial statements, if they are to be claimed for tax purposes (Doupnik & Perera 2012, p.29). 

            On the other side, in countries such as United States and United Kingdom, published financial statements are designed chiefly as performance indicators for investment decisions, instead for taxation usage (Nobes & Parker 2012, p.37). Here, the tax and financial reporting rules are independent. In other words, they operate separately and set by different bodies. So, published financial statements need to be adjusted for taxation purposes and submitted to the government separately from the reports sent to shareholders (Radebaugh, Gray & Black, p.16). Consequently, deferred taxation arises and causes a lot of trouble due to the differences between tax and accounting treatments. These differences affect depreciation and created certain requirements. For example, the use of LIFO inventory valuation in United States and the requirements of FRS 15 in determining the depreciation charges in United Kingdom.

2.4 The accounting profession

            The accounting profession’s size, strength, role and competence in a country are affected by numerous factors outlined earlier; in turn, the profession influences a country’s institutions and its accounting system (See appendix below). The stature of the accounting profession affects accounting development as well as the quality of financial statements produced. Radebaugh, Gray and Black (2006, p.16) claim that more developed accounting profession will lead to more judgementally based public accounting systems rather than centralised and uniform systems. Saudagaran (2009, p.8) discovers that in common law countries like United States and Canada, the accounting profession is largely self-regulating, plays an essential role in setting accounting and auditing standards, gives trainings, arranges examinations as well as establishing licensing requirements for entering and staying in the profession. In contrast, in code law countries such as France, Germany and Italy, the accounting profession has less stature and power as the government carries out many of these roles instead of delegating them to an independent body. Where there is a strong accounting profession, audit reports appear to be more independent and reliable, whereas in countries with weak accounting profession, the financial statements’ quality and auditors’ independence are more likely subject to dispute.  

Source: Taken from http://staff.undip.ac.id/akuntansi/anis/files/2012/03/akuntansi-dan-lingkungan.pdf, p.160.

2.5 Religion

            Accounting concepts are influenced by religion too. For example, any kinds of interest such as simple interest, compound interest, periodic interest, commercial interest and so on, are strictly forbidden in Islam as it is considered as an exploitative practice to earn effortless profit which is free of exchange (Hossain 2009, pp.241-242). Thus, the principles of Islam are in conflict with the practices of interest-based modern banking system. This results in a great variation of accounting practices especially in term of measurement, disclosure and classification as Islamic financial institutions have to comply with Shari’ah precepts (Abdel-Karim 2011, p.240). As a result, Islamic banks cannot charge interest. Instead, they have established a number of methods to share risks and returns between the borrower and the lender. Similarly, Islamic banks cannot invest in or lend to organizations that disobey Quranic injunctions. For instance, companies which are involving in alcohol, gambling or rearing pigs. As time passes by, Islamic banking gains popularity and starts to proliferate in number. So, Accounting and Auditing Organization for Islamic Financial Institutions (AAOIFI) was setup in 1993 to deal with these problems by issuing standards based on Islamic law (See appendix below). Meanwhile, other religious requirements such as gender separation also influences the way of presenting and communicating accounting information.

 

Source: Extracted from Abdel-Karim (2011, p. 241)

2.6 Political and economic ties

            Accounting ideas, systems and technologies are transferred through conquest, commerce and other such forces. Fischer, Taylor and Cheng (2008, p.506) claim that nations that previously were colonised by other countries usually have principles similar to their ruling nation. However, it is noticeable that former colonies have either stay or replaced the system after independence. For instance, Singapore and Malaysia have chosen to stay with the British system, but Indonesia has discarded the Dutch’s accounting system and adopted U.S. model of accounting. Next, economic ties influence accounting development too. For example, United States’ accounting affects Canada’s accounting, partly due to geographic proximity. Besides, United States represents the largest export market for Canada, plus many Canadian firms are listed on U.S. stock exchanges. Moreover, the establishment of regional economic alliances like EU, NAFTA and ASEAN have speed up the harmonisation process by reducing the variation in accounting regulations to save costs (Saudagaran 2009, pp.7-8).

2.7 Inflation

            High inflation rates render historical cost accounting to become irrelevant and pointless. Furthermore, it affects the likelihood of a country to incorporate price changes into accounts. Some examples of countries which have severe inflation issues are Zimbabwe, Israel, Mexico, Chile and Brazil. Thus, they have to apply various forms of inflation accounting such as general price level accounting and current cost accounting. Doupnik and Perera (2012, p.30) state that adjusting accounting records for inflation results in a write-up of assets and expenses. Likewise, adjusting income for inflation is vital especially when financial statements serve as the basis for taxation, to avoid from paying taxes which are charged based on fictitious profits.  

3.0 Culture

Hofstede’s Cultural Dimensions

            Theoretically, culture is the values and attitudes commonly shared by a society. Hofstede (2001, p.9) defines culture as “the collective programming of the mind that distinguishes the members of one group or category of people from another”. Based on a survey conducted on IBM workers worldwide, Hofstede has discovered four cultural dimensions or societal values, which can be briefly described as follows:

            Firstly, individualism versus collectivism (also known as “I” versus “We” concept) is the degree to which individuals are integrated into groups. Individualism refers to the societies in which the ties between individuals are loose. Therefore, people are expected to take care and stand up for themselves and their immediate families only. In individualistic societies, the stress is put on personal achievements and individual rights. On the other hand, in collectivist societies, individuals are strongly integrated into cohesive groups, extended families or organisations which continue to protect them in exchange for undoubted faithfulness. In short, the extent of interdependence that a society keeps among individuals is the key issue addressed by this dimension.

            Secondly, large versus small power distance is the level to which hierarchy and unequal power distribution in institutions and organisations are accepted by the members of a society. People in large power distance societies accept a hierarchical order where everyone has a place which requires no further explanation, whereas people in small power distance societies look for power equalisation and demand reasons for power inequalities. The basic issue highlighted by this dimension is how societies cope with inequalities among people when they arise.   

            Thirdly, strong versus weak uncertainty avoidance; it deals with a society’s tolerance and comfortability towards uncertainty and ambiguity. Societies that are practising strong uncertainty avoidance culture try to minimise the likelihood of such situations by having strict laws and rules as well as maintaining rigid codes of belief and conduct; deviant people and ideas are intolerable. Conversely, weak uncertainty avoidance societies stay in a more relaxed atmosphere in which practice counts more than principles and deviance is easier to be tolerated. This dimension tries to investigate how societies handle unknown future as time flies, which can be either: attempt to control the future or let it occurs.

            Fourthly, masculinity versus femininity refers to the distribution of emotional roles between the genders. Examples of masculine cultures’ values are achievement, assertiveness, heroism and materialism, whereas feminine cultures’ values are modesty, caring for the weak and the quality of life. The way in which a society allocates social roles to the genders is the fundamental issue addressed by this dimension. Undoubtedly, Japan is one of the most masculine societies in the world, while feminine countries are best represented by Sweden and Norway.   

Gray’s Accounting Values

            In 1988, Gray developed four pairs of contrasting accounting values based on Hofstede’s cultural dimensions. Amazingly, Gray even proposed four hypotheses to link his four accounting values with Hofstede’s four societal values (See appendix below). The details of each accounting values and the relationships are discussed as follows:

Source: Extracted from Borker (2013, p.169)

            Firstly, professionalism versus statutory control; it is a preference to utilise individual professional judgement and professional self-regulation, instead of fulfilling prescriptive legal requirements. Undeniably, accountants adopt independent attitudes and use their own professional judgement to a certain extent (Chanchani & MacGregor 1999, p.6). For instance, in United Kingdom, a true and fair view of a company’s financial position depends largely on the accountant’s professional judgement, whereas in France and Germany, the professional accountant’s role is mainly concerned with the implementation of relatively prescriptive and detailed legal requirements (Radebaugh, Gray & Black 2006, p.46). Gray (1988, p.9) claims that professionalism is most closely linked with individualism and uncertainty avoidance. It is found that consistency exists between the preference for independent professional judgement and the preference for a loosely ties between individuals as there is greater emphasis on individual decisions and respect for individual endeavour. Gray also noticed the correlation between professionalism and power distance. He points out that small power distance society has a higher probability to accept professionalism due to higher concern for equal rights, where people at different power levels feel less threatened and more readily to trust people, and where there is a belief in the need to justify the imposition of laws and codes. Consequently, he came out with the following hypothesis: The higher a country ranks in terms of individualism and the lower it ranks in terms of uncertainty avoidance and power distance then the more likely it is to rank highly in terms of professionalism.

            Secondly, he proposed uniformity versus flexibility: a preference for uniformity and consistency over flexibility in response to circumstances, since accounting principles’ basic features include uniformity, consistency and comparability internationally (Chanchani & MacGregor 1999, p.7). For example, in Spain and France, a uniform accounting plan along with the imposition of tax rules for measurement purposes have been operating for a long time to assist national planning and pursuit macroeconomic objectives (Radebaugh, Gray & Black 2006, p.46). On the other side, in United Kingdom and United States, more emphasize is put on inter-temporal consistency together with some degree of intercompany comparability subject to a perceived need for flexibility (Borker 2013, p.171). Gray (1988, p.9) argues that uniformity is most closely related to uncertainty avoidance and individualism. A preference for uniformity is consistent with a preference for strong uncertainty avoidance, which leads to: a concern for law, order and rigid codes of behaviour; a need for written rules and regulations; a respect for conformity; and the search for ultimate, absolute truths and values. Besides, this value dimension is also consistent with a preference for collectivism. He also noticed the connection between uniformity and power distance where uniformity is simpler to be facilitated in large power distance society where the impositions of laws and codes of a uniform character have a greater tendency to be accepted. At last, he formed the following hypothesis: The higher a country ranks in terms of uncertainty avoidance and power distance and the lower it ranks in terms of individualism then the more likely it is to rank highly in terms of uniformity.

            Thirdly, conservatism versus optimism: a preference for cautious approach to measurement rather than a more optimistic, risk-taking approach in dealing with future event’s uncertainty. In fact, conservatism or prudence is perceived to be part of accountants’ elementary attitude internationally; it is the oldest, most pervasive and widely used principle of accounting valuation in measuring assets and profits reporting. Conservatism can perhaps be linked most closely with uncertainty avoidance and the short-term versus long-term orientations. A preference for more conservative profits measurement is consistent with strong uncertainty avoidance due to a concern with security and a perceived need to adopt a cautious way to handle future event’s uncertainty (Gray 1988, p.10). Meanwhile, a less conservative approach to measurement is consistent with a short-term orientation where fast results are expected and hence a more optimistic approach is adopted relative to conserving resources and investing for long-term trends (Doupnik & Perera 2012, p.38). There also seems to be a link, if less strong, between high levels of individualism and masculinity, on the one hand, and weak uncertainty avoidance on the other, to the extent that the stress on individual achievement and performance is likely to foster a less conservative approach to measurement (Radebaugh, Gray & Black 2006, p.47). After all, Gray (1988, p.10) formulated the following hypothesis: The higher a country ranks in terms of uncertainty avoidance and the lower it ranks in terms of individualism and masculinity, the more likely it is to rank highly in terms of conservatism.

            Fourthly, secrecy versus transparency: a preference for confidentiality where business information disclosure is restricted to certain people only, instead of disclosing it openly to the public (Borker 2013, p.169). In reality, the quality and quantity of information disclosed to outsiders can be influenced by management. Moreover, secrecy (or confidentiality) in business relationships is a fundamental accounting attitude. It looks like secrecy is strongly connected to conservatism as both values imply a cautious approach in corporate financial reporting. Secrecy is related to the disclosure dimension, whereas conservatism is related to the measurement dimension. Such variations appear to be reinforced by the differential capital markets development and the public ownership of shares which give incentives for the voluntary disclosure of information (Chanchani & MacGregor 1999, pp.8-9). According to Gray (1988, p.11), secrecy can be linked most closely with uncertainty avoidance, power distance and individualism. For instance, a preference for secrecy is consistent with strong uncertainty avoidance due to the need to restrict information disclosures to preserve security, avoid conflict and competition. Not only that, high power distance societies normally prefer to restrict information to maintain power inequalities. Besides, secrecy is also consistent with a preference for collectivism because its concern is for those involved with the firm as compared to external parties (Radebaugh, Gray & Black 2006, p.48). Doupnik and Perera (2012, p.38) state that a long-term orientation suggests a preference for secrecy where there is a need to conserve resources and ensure that funds are sufficient for investment relative to the demands of shareholders and workers for higher payments. A significant but perhaps less crucial link with masculinity suggests that in societies where more emphasis is put on achievement and material success, there will be a greater tendency to publicise such achievements and material success as well as be more open to socially related information. Thus, Gray described the relationship as follows: The higher a country ranks in terms of uncertainty avoidance and power distance and the lower it ranks in terms of individualism and masculinity then the more likely it is to rank highly in terms of secrecy.

4.0 Classification

            Classification groups countries according to the common elements and distinctive characteristics of their financial accounting systems. This provides some practical benefits. For instance, it enables countries that face accounting problems to get some ideas and solutions by looking at the experiences of other countries in the same group. Basically, there are two types of classifications in accounting, namely extrinsic and intrinsic.  

            Under extrinsic classifications, Muller (1967) identified four patterns to accounting development in Western market-oriented economies: macroeconomic pattern, microeconomic pattern, independent discipline approach and uniform accounting approach. Briefly, under macroeconomic pattern, business accounting is derived and designed to support national economic policies. In the microeconomic pattern, accounting is viewed as a branch of business economics. Meanwhile, in the independent discipline approach, which can be seen in the United States and the United Kingdom, accounting is viewed as a service function and is derived from business practices, whereas under the uniform accounting approach, accounting is standardised and utilised for administrative control by central government. Saudagaran (2009, p.20) stresses that Netherlands seems to be the only county where accounting developed along microeconomic lines. He also discovered that Mueller’s macroeconomic and uniform approaches have been overlapped. For example, France, Germany and Sweden have both features. Unlike Gray (1988), Mueller gave no explicit recognition on cultural factors.  

            Conversely, under intrinsic classifications, accounting patterns are identified by analysing data that are related to accounting rules and practices. Here, Nair and Frank (1980) have given a significant contribution by carried out a statistical analysis of international accounting practices using the 1973 and 1975’s Price Waterhouse surveys where financial reporting characteristics are divided into measurement and disclosure practices. They identified four measurement groupings: British Commonwealth, Latin American, continental European and U.S. models (See appendix below).

Source: R. D. Nair and W. G. Frank, “The Impact of Disclosure and Measurement Practices on International Accounting Classifications,” Accounting Review (July 1980): 433.

5.0 Harmonisation and enforcement effort

            Harmonisation means minimising the variations among national accounting standards. Obviously, it offers several benefits to users and preparers of accounts. For example, it allows investors to compare different companies’ financial statements internationally; governments of developing countries can save time and money by adopting international standards as well as controlling the activities of MNCs; it makes the computation of tax liability easier for the tax authorities; regional economic grouping’s trade recordings and transactions would be smoother; MNCs may have better access to foreign investor funds and consolidation of foreign subsidiaries and associates would be simpler. However, harmonisation processes face a lot of challenges such as different purposes of financial reporting, different legal systems, cultural differences, diverse user group, nationalism, political lobbying and lack of strong accounting bodies (Nobes & Parker 2012, pp.83-84).

            Chronologically, the IASC was formed in 1973 to publish and promote the worldwide acceptance of IASs. The IASC has made notable achievements by issuing forty-one standards, along with a conceptual framework and other publications. During the 1990s, many countries like Nigeria, Malaysia and Singapore adopted the IASs with few or no amendments as their national standards. In 2000, stock market regulators (IOSCO) endorsed the IASC’s standards. In 2001, the IASC was restructured into the IASB; this board develops and issues IFRSs. The IASB has revised a number of the IASs; some of them were superseded. Anyway, compliance with IASB standards is voluntary and IASB has no power to enforce them. Regional harmonisation could be achieved through the establishment of trading blocks around the world. For instance, the Fourth, Seventh and Eighth Directives have played a major role in harmonising financial reporting in EU countries (Dogariu, Urimumbeshi & Bonaventure 2008, p.126). Since many countries are adopting IFRSs or converging their national standards with it, the IASB is en route to become the world’s prime standard-setter.

6.0 Conclusion

            All in all, harmonisation process seems to be fruitful. Clearly, globalisation of capital markets, proliferation of MNCs worldwide, establishment of free trade zones as well as having strong support from the World Bank, IOSCO and other international bodies have eventually accelerated the harmonisation rate. Undeniably, harmonisation provides more benefits than drawbacks. At such, it slowly gains global acceptance where IFRSs and IASs have been adopted by many countries around the world. Ideally, a single set of global standards remains the IASB’s goal. In other words: “One world, one accounting”. Some of the notable events are the 2002’s Norwalk Agreement which aimed to remove differences in US GAAP and IFRS and coordinate their future work programmes as well as the duo efforts of the IASB and US FASB in running a joint project since 2005, with the objective to adopt one global conceptual framework (Pacter, 2013). Nevertheless, Tysiac (2013) suggests that a more practical goal for the future is to achieve global comparability, but not necessarily resulting in having identical reporting standards.

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‘Intertemporal consistency’ means that the activities an individual plans now to carry out in the future are the activities that he or she actually carries out when the future arrives.


7.0 References

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