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International accounting
- IASB and current international developments
Gunnar Rimmel Associate professor
Head of Financial Accounting and Reporting GroupSchool of Business, Economics and Law
University of Gothenburg
Fall 2009
Special lecture on International Financial Accounting at Karlstad [email protected]
Overview
Origins of international accounting differences
Harmonising or standardising?
From EU directives to IFRS 2005
IASB
IASB vs FASB = conergence?
Origin of international differences
Country A Country B
Cultural differences
Coincidence andexternal influences
Provision of finance
Existinglaw
Relationship between accounting and taxation
Accounting regulation /profession
4
Common law versus code law countries
Anglo-Saxon law traditionLaws are created and developed by ”case law” practice
Continental – Roman-German law traditionLaws are written and developed by the state
Anglo-Saxon law tradition(common/case law countries)
Continental – Roman-German law tradition(code law countries)
USAUnited KingdomAustraliaNew ZealandCanadaIreland
GermanyFranceBelgiumItalySpainPortugalJapan (trade law)
5
Provision of finance- shareholder-oriented vs credit-oriented countries
Shareholder oriented Credit/family/state oriented
USAUnited KingdomNetherlandsSwedenAustraliaCanada
GermanyFranceBelgiumItalySpainPortugal
A B
Strong capital marketMany ”outside” shareholdersStrong/large auditing professionSeparate accounting and taxation rules
Weak capital marketMain ”inside” shareholderWeak/small auditing professionTaxation rules dominate accounting rules
Initial classification
General relationship between accounting and taxation
DependenceFinancial reporting purpose –to protect creditors and the state
Reporting independent from taxationFinancial reporting purpose – to increase disclosure and more detailed information as well as increased ”fair” information
fair => large number of outside owners require unbiased information about the success of a business and its state of affair.
Independence Dependence
DenmarkIrelandUnited KingdomNetherlandsCzech RepublicPoland
GermanyFranceBelgiumItalySpainNorway
Cultural differences
Individualism versus collectivism
Large versus small power distance
Strong versus weak uncertainty avoidance
Masculinity versus femininity
Geert Hofstede: Organisations and culture
Dates of establishment of professional accounting bodies
9
Country classification 1980
Accounting Systems(corporate Financial accounting)
Macro-uniformGovernment-driven
Tax-dominated
Netherlands Australia NZ UK Canada Italy France Belgium GermanyUSAIreland Spain Japan Sweden
Business practiceProfessional rules
British originBusiness economicsExtreme judgmental
Micro-fair-judgmentalCommercially-driven
UK influenceProfessional
regulation
US influenceProfessional
regulation
Code-basedinternationalinfluences
Plan-based Statute-based Economiccontrol
Families
Sub-classes
Classes
Country classification 1998Christopher Nobes (1998)
Accounting Systems(corporate financial accounting)
StandardDutch
Equity,Class A
Classes
UK GAAP IAS GAAP US GAAP StandardBelgian
StandardFrench
StandardGermany
StandardItalian
StandardJapanese
2. Bayer(Germany)Nestlé(Switzerland)Nokia(Finland)
1 US SEC-registeredcompanyaccounts
2. SomeJapanesegroupaccounts
Dutchaccounts
UKaccounts
2. Irishaccounts
Singaporelistedcompanies
Belgianaccounts
1 Frenchindividualaccountsand someFrenchgroupaccounts
1. Germanindividual andgroup accounts,except for somegroup accountsof large listedcompanies
2 Austrianindividualaccounts
Italianindividualaccountsorunlistedgroupaccounts
Japaneseindividualaccountsand mostgroupaccounts
Exam
ples
System
Equity,Class B
Family
Accounting harmonisation- three strategies to harmonise on ”de jure”-level (VanHulle 1993)
Harmonisation
equal rules
1. Standardisation with uniform rules without possibilities to choose. This model is applied by the FASB
2. ”equal” rules with notes. This model has dominated the EU.3. Choice alternatives, but desired alternative has been indicated.
This model has dominated the IASB.
Choice alternatives standardisation
One should differentiate between harmonisation on the de jure-level (rules and regulation) and the de facto-level (how corporations use accounting in practice).
Three strategies:
Harmonisation problem a la Daimler-Benz
Historical development of IAS/IFRS and IASB
Year What happened?1972 Proposal to form International Accounting Standards Committee (IASC).
1973 inaugural meeting 29 June, London International Accounting Standards Committee (IASC).Members: Australia, Canada, France, Germany, Japan, Holland, UK, Ireland & USA
1975 First IAS published:IAS 1 Disclosure of Accounting PoliciesIAS 2 Valuation and Presentation of Inventories in the Context of the Historical Cost System.
1989 European Accounting Federation (FEE) intend for international harmonisation and greater European involvement in IASC
1996 Development of main principles.EU:s Contact Committee makes a feasibility study.
1997 Standing Interpretations Committee (SIC) forms to check IAS before endorsement.
1999 International Organization of Securities Commissions (IOSCO) review of IASC core standards begins.
2000 IASC member bodies approve IASC's restructuring and the new IASC Constitution European Commission announces plans to require IASC standards for all EU listed companies from
no later than 2005
2001 IASC forms IASB Foundation. IASC gives IASB responsibility to develop new IAS/IFRS.European Commission presents legislation to require use of IASC Standards for all listed companies
no later than 2005
2002 European Commission approves legislation to require IAS/IFRS. SIC transforms into International Financial Reporting Interpretations Committee (IFRIC)
2003 European Commission approves legislation on IAS/IFRS.
Historical development of EU-directives
Directiveson company law
Draftdates
Draftadopted
Topic
First 1964 1968 Ultra vires rules
Second 1970, 1972 1976 Separation of public companies,minimum capital, distributions
Third 1970, 1973, 1975 1978 Mergers
Fourth 1971, 1974 1978 Formats and rules of accounting
Fifth 1972, 1983 - Structure, managementand audit of companies
Sixth 1978 1982 De-mergers
Seventh 1976, 1978 1983 Consolidated accounting
Eigth 1978 1984 Qualifications and work of auditors
Ninth - - Links between public company groups
Tenth 1985 - International mergers of public companies
Eleventh 1988 1989 Disclosures about branches
Twelfth 1988 1989 Single member company
Thirteenth 1989, 1996, 1997 - Takeovers
Implementation of EU-directives redovisningslagstiftning
Fourth SeventhDenmark 1981 1990
United Kingdom 1981 1989
France 1983 1985
Netherlands 1983 1988
Luxembourg 1984 1988
Belgium 1985 1990
Germany 1985 1985
Ireland 1986 1992
Greece 1986 1987
Spain 1989 1989
Portugal 1989 1991
Austria 1990 1990
Italy 1991 1991
Finland 1992 1992
Sweden 1995 1995
Norway 1998 1998
16
The IASB Foundation
International Accounting Standards Committee
Foundation(19 Trustees)
International Accounting
Standards Board (12+2 Board Members)
Standards Advisory Council
Advisory Groups
Director of Operations and non-Technical Staff
Director of Technical Activities and Technical staff
International Financial Reporting Interpretations
Committee (12)Appoints
Report to
Membership links
Advises
National Standard setters and other interested parties
IASB Board members Sir David Tweedie, chairman (ex chairman ASB,UK)
Thomas E.Jones (ex chairman IASC, CFO Citicorp)
Mary E.Barth (Stanford University, ex AA partner)
Steven Cooper (ex board member UBS Investment Bank)
Phillipe Danjou (ex director of French securities regulator - AMF)
Jan Engström (ex CFO Volvo Group)
Gilbert Gélard (ex partner KPMG, ex IASC Board)
Robert P.Garnett (ex CFO Anglo American plc, South Africa)
James J.Leisenring (ex FASB)
Warren McGregor (ex Australian Accounting Research Foundation)
John T. Smith (partner Deloitte)
Tatsumi Yamada (ex partner PwC Japan, ex IASC Board)
Zhang Wei-Guo (ex Chief Accountant and Director General of the Department of International Affairs at the China Securities RegulatoryCommission - CSRC)
International Financial Reporting Standards (IFRS)
ContentIASC Foundation ConstitutionIASB Framework for the Preparation and Presentation of Financial StatementsPreface to International Financial Reporting Standards,Due Process Handbook for the IASB, Glossary of TermsFrameworkIAS 1 – 41IFRS 1 - 8IFRIC 1 -17SIC 1 - 33
The main changes 2009 • one revised standard - IFRS 1 • amendments to IFRSs that were issued as separate documents • amendments to IFRSs issued in the first annual improvements project • amendments to other IFRSs resulting from those revised or amended
standards • three new Interpretations - IFRICs 15-17
19
Standards Advisory Council- around 40 members
Current composition of members
2 Africa 7 Asia / Oceania
(Australia, China, India, Japan, Korea, 2 South-East Asia)
13 Europe(10 EU + Russia + Switzerland + CESR-fin)
3 Latin America1 Middle East4 North America
7 International organisations• Basel Committee of Banking Supervisors• International Association of Insurance Supervisors• International Federation of Accountants• International Monetary Fund• International Organization of Securities
Commissions• United Nations Conference for Trade and
Development• World Bank
3 Official observers• European Commission • Financial Services Agency of Japan • US Securities and Exchange Commission
Objectives of IASB
MISSION STATEMENT“The International Accounting Standards Board is an independent, privately-funded accounting standard setter based in London, UK. Board Members come from nine countries and have a variety of functional backgrounds. The Board is committed to developing, in the public interest, a single set of high quality, understandable and enforceable global accounting standards that require transparent and comparable information in general purpose financial statements. In addition, the Board cooperates with national accounting standard setters to achieve convergence in accounting standards around the world.”
IAS fundamental rule
An enterprise whose financial statements comply with International Accounting Standards should disclose that fact. Financial statements should not be described as complying with International Accounting Standards unless they comply with all the requirements of each applicable Standardand each applicable interpretation of the Standing Interpretations Committee.
(IAS1§11)
Research
9 – 15 months
IASB’s standard setting process
Discussionpaper
Exposuredraft IFRS
ProjectProposal
- IASB Board- SAC- National standard setters
Review ofcomments
Review ofcomments
9 – 15 months
EU-endorsement of IFRS
• Endorsed, no directive!• Endorsement 31 dec 2002 • Group accounting 2005 according to IFRS (and
EU-directive!)• Mandatory for listed corporations, member states
decide if unlisted corporations may report according to IFRS
• ARC - Accounting Regulatory Committee (politics)
• Technical level: EFRAG• Modernisation of the Directives
Committees and organizations involved for standards EU approval(European Financial Reporting Advisory Group)
Accounting RegulatoryCommittee
Technical Expert Group (TEG)
EU-Commission
Consultation forum with European norm setter
CESR (The Committee of European Securities
Regulators)
Supervisory Board
EFRAG
Observer status
Translation
IASB
approval
EFRAGadvice
EU bureaus
EU Comm + ARC
endorses EU review
EU-Parliament
+ C o Ministers
2 m + 1m2 m 1,5m
EU’s regulation process
Endorsed
Official translation
Timetable for Application of Standards- no new standards until 2009
2003 IAS 41
2004 IFRS 1 – First Time Adoption of IFRS
2005 (Mandatory) Improvements Project Share-based Payment (IFRS 2) Amendments to IAS 32/39 Convergence Phase 1 (ED 4) Business Combinations Phase 1 (ED 3) Insurance Contracts Phase 1 (ED 5)
2005 (Optional) Business Combinations – Phase II Consolidation, Including Special Purpose Entities Disclosure of Financial Risk and Other Disclosures about Financial Activities Comprehensive Income (Performance Reporting) Other Convergence Issues Revenue Recognition, Liabilities, and Equity
Improvements Project
Exposure draft Improvements to IFRS was issued May 2002 Comment deadline: 16 September 2002 Final Standards were issued in December 2003
Revised IAS Resulting from the Improvements Project
IAS 1 Presentation of Financial Statements IAS 2 Inventories IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors IAS 10 Events after the Balance Sheet Date IAS 15 Information Reflecting the Effects of Changing Prices (Withdrawn) IAS 16 Property, Plant and Equipment IAS 17 Leases IAS 21 The Effects of Changes in Foreign Exchange Rates IAS 24 Related Party Disclosures IAS 27 Consolidated and Separate Financial Statements IAS 28 Investments in Associates IAS 31 Interests in Joint Ventures IAS 33 Earnings per Share IAS 40 Investment Property
Effective dates: 2005 year ends
FASB vs. IASB
Remember the Titans ?
Sarbanes-Oxley Act (2002)Plenty of new rules and regulation on corporate governance and internal control
The Norwalk Agreement (2002)IASB & FASB convergence of their accounting rules
Convergence project
Objectiveidentify differences between IFRS and US GAAPfind the best global solutions to these differencesto eliminate a variety of differences between International Financial
Reporting Standards and US GAAPTo save money by working on rules together
PurposeTo increase transparency of reports
”Tell it like it is” …David Tweedie
To encourage investors to diversifyTo lower company’s costs
TimingPhase 1: ED 4 issued on 24 July 2003, final standard in Q1 2004 would
apply in 2005Phase 2: mandatory after 2005, optional in 2005
Convergence topics for Phase 2
Classification of liabilities* (IAS 1)Inventories – idle capacity and spoilage (IAS 2)Application of temporary difference approach (IAS
12)Asset exchanges* (IAS 16)Government grants (IAS 20)Joint ventures (IAS 31)Interim financial reporting (IAS 34)Research and development costs (IAS 38)
Convergence topics for Phase 2
Convergence Issues for Asset Disposals and Discontinued Operations:
— Project completed
Convergence Issues for IAS 12 Income Taxes:— Exposure draft expected 4th quarter 2005— Final standard timetable not yet announced
Convergence Issues for IAS 14 Segment Reporting:— Exposure draft expected 4th quarter 2005— Final standard timetable not yet announced
Convergence topics for Phase 2
Convergence Issues for IAS 19 Employee Benefits:
— Project completed (see Completed Projects below)
Convergence Issues for IAS 20 Government Grants:
— Exposure draft on replacement of IAS 20 expected 4th quarter 2005
— Final standard: timetable not yet announced
Convergence Issues for IAS 37 Provisions:— Exposure draft was issued 30 June 2005— Final standard expected 2nd half 2005
FRANCE
IASBUK
USA/FASBJAPAN
GERMANY
AUS
CANADA
Some years ago
SPAIN
FRANCEUK
GERMANY AUS
SPAIN
IASB
USA/FASBJAPAN
CANADA
A couple of month ago
USA/FASBJAPAN
CANADA
FRANCEUK
GERMANY AUS
SPAIN
Current state
IASB
US GAAP IAS/IFRS
GLOBAL GAAPGLOBAL GAAP
CONVERGENCE
JAPAN
GLOBAL GAAP on its way?