By Chan Hoi Leong,
Researcher
Topic: EducationArea 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, 12th
ed., Pearson, page 28).
Identify these
factors and evaluate their impact on different accounting systems.
Research Essay
Inti International College Subang
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.
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Source: Taken from http://staff.undip.ac.id/akuntansi/anis/files/2012/03/akuntansi-dan-lingkungan.pdf, p.160.
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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.
‘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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