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Financial Accounting TheoryCraig Deegan
Chapter 4
International Accounting (Part-2)
Dewan Mahboob Hossain;
Department of Accounting & Information
Systems
University of Dhaka
Dhaka
Bangladesh
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Main issues for difference
Differences in taxation system Differences in economic and political influences on
financial reporting
Modifications made to IFRS at national level
Differences in implementation, monitoring andenforcement
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Differences in taxation systems: evidence
Nobes (2006) uses a comparison of differences intaxation systems between Germany and the UK to
identify why financial accounting practices in the two
countries might be systematically different despite
both countries adopting IFRS.
In Germany, companies are required to continue to
prepare unconsolidated statements under
conventional rules for calculation of taxable income
and distributable income.
In the UK, IFRS is allowed for individual company
financial statements and therefore as a starting point
for calculation of taxable income.
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Economic and political influences
Powerful local economic and political forcesdetermine how managers, auditors, courts,
regulators and other parties influence the
implementation of rules.
Those forces have exerted a substantial influence onfinancial reporting practice historically, and are
unlikely to suddenly cease doing so, IFRS or no
IFRS.
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Modifications made to IFRS at a national level
IASB has no ability to enforce the application of itsaccounting standards in countries that have made
the decision to adopt IFRS.
If modifications to IFRS are made at a national level,
the result will be international inconsistencies inaccounting practices.
Regulatory bodies in particular countries may make
a decision to modify a particular IFRS before it is
released.
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Implementation, monitoring and
enforcement
Inconsistencies internationally in how the adoption of accounting standards isimplemented, monitored and enforced will lead to inconsistencies in how
standards are applied, which will in turn diminish the international comparability
of financial reports.
In some cases, the massive underdevelopment of the accounting profession,
implementation may be different.
In China, there are hardly 70000 practicing accountants and most of them arepoorly trained. So, implementation may be hampered.
The list of IFRS adopting countries ranges from countries with developed
accounting and auditing professions and developed capital markets to
countries without a similarly developed institutional background.
The free rider problem associated with IFRS: If a symbol of legitimacy suchas IFRS- can be acquired at a low cost, some countries with low accounting
proficiency will make the choice to adopt IFRS because of the reputation
benefits such a choice may generate.
However, such a choice will have costly implications for countries with a higher
level of accounting proficiency and who put in place appropriate
implementation, monitoring and enforcement.
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Explanations of differences in
accounting
1. Nature of business ownership and financing system
2. Colonial inheritance
3. Invasions
4. Taxation
5. Inflation
6. Level of education
7. Age and size of the accounting profession
8. Stage of economic development
9. Legal systems
10. Culture
11. History
12. Geography13. Language
14. Influence of theory
15. Political systems, local climate
16. Religion.
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Culture
The collective programming of the mind whichdistinguishes the members of one human group from
another.
Accounting is a socio-technical activity that involves
interaction between both human and non-humanresources.
Accounting cannot be culture-free.
Culture is typically reserved for societies as a whole, or
nations, whereas subcultures is used for the level of anorganization, profession or a family.
It is quite possible that had accounting systems evolved
independently in developing countries they would have
rather different from any now we witness in present day
Europe.
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Hofstede (1984)
Indiv id ual ism v s. Col lect iv ism:
A preference for loosely knit social framework
A tightly knit social framework
Large Vs. Smal l pow er distance
To which the members of a society accept that power in institutions and organizations
is distributed unequally .
Large power distance society: Hierarchical.
Small power distance society: strive for power equalities and demand for
justifications for power inequalities.
Strong Vs. weak uncerta inty avoidance
The degree to which the members of the society feel uncomfortable with ambiguity or
uncertainty.
Strong uncertainty avoidance: Rigid codes of beliefs and behavior. Weak uncertainty avoidance: maintain more relaxed atmosphere.
Mascul in i ty vs . feminin i ty
Masculinity: Achievement, heroism, assertiveness, and material success.
Femininity: relationships, modesty, caring for weak and the quality of life.
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Gray (1988): directly linked to Hofstede
Professional vs. statutory control:
Self-regulation or prescription requirements and statutory
control.
Uniformity vs. flexibility:
Uniform accounting practices between companies and the consistency
over time or flexibility in accordance with perceived
circumstances of individual companies.
Conservatism vs. optimism:
Cautious approach to measurement so as to cope with the uncertainty of
future events or optimistic, laissez-faire, risk takingapproach.
Secrecy Vs. transparency:
Confidentiality: restriction of disclosure of information or transparent,
open and publicly accountable approach.
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Hypothesized relationships between Grays accounting
values and Hofstedes cultural values
Culturalvalues
(Hofstede)
Accounting values (Gray)+ : positive relationship - : negative ?: unclear relationship
Professionalis
m
Uniformity Conservatism Secrecy
PowerDistance
_ + ? +
Uncertainty
avoidance
_ + + +
Individualism
+ _ _ _
Masculinity ? ? _ _
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Religion
Islamic culture typically fails to embrace western accountingpractices.
The Islamic tradition does have notions of stewardshipbut to
God rather than to suppliers of equity and debt capital.
Muslims believe that they hold assets not for themselves but in
trust for God. Islam prevents debt financing and prohibits the payment of
interest. This prohibition has significant implications for
processes aimed at the international harmonization of
accounting standards.
Many past and present western standards entail discountingprocedures involving a time value of money concept which is
not admitted by Islam.
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Legal Systems
Two kinds of legal systems: common law andRoman law systems.
Common law:
1. few prescriptive statutory laws.
2. Judges apply both limited amount of statutory lawand the outcomes of previous judicial decisions to
the facts of a specific case.
3. Each judgment becomes a legal precedent for
future cases.4. Originated in England and spread to its former
colonies: the US, Canada, Australia and NZ.
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Legal Systems (contd..)
Roman Law Systems:Statutory law tends to be very detailed and covers most
aspects of daily life.
Accounting implications:
Common law cou nt r ies :few detailed accounting laws guiding practices.Accounting practices: judgments of accountants.
Roman law countr ies :a body of codified accounting laws prescribing in detailshow each type of transaction or event should be treated in the accounts.
In the EU, we would expect England, Wales, Ireland and Scotland historically tohave had relatively few codified accounting laws.
In the reminder of the EU we could expect accounting practice to havehistorically been developed through detailed codified accounting laws.
The adoption of IFRSs (principles based) would have represented a significantchange in practice for countries with Roman law systems relative tocountries with common law systems.