Comparative international accounting

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Now in its tenth edition, Comparative International Accounting by Nobes and Parker is renowned for its depth of discussion and comprehensive coverage of the international dimensions of financial accounting and reporting. Comparative International Accounting has been extensively revised for the many changes in international accounting since the last edition. New to this edition are: An additional chapter on how the practice of IFRS • can vary within a country and between countries Updated case studies and an increased number of • real-world examples New information on pension accounting, auditing • standards and IFRS 8 Increased coverage of China and of small and • medium enterprises (SMEs) • Contributions from a diverse group of international practitioners and academics, which are updated every two years to incorporate the latest developments in the field Christopher Nobes is Professor of Accounting at Royal Holloway, University of London. From 1993 to 2001 he was a representative on the board of the International Accounting Standards Committee. Robert Parker is Emeritus Professor of Accounting at the University of Exeter, UK. He was formerly editor of the journal, Accounting and Business Research. Both authors have received the American Accounting Association’s award of ‘outstanding international accounting educator’. Revised resources for lecturers are available to download at www.pearsoned.co.uk/nobes. an imprint of CVR_NOBE4767_10_SE_CVR.indd 1 Front cover image: © Getty Images/Iconica Comparative International Accounting It uncovers the conceptual and contextual foundations of the increasingly used International Financial Reporting Standards (IFRS) and contrasts them with US generally accepted accounting principles (GAAP). Nobes and Parker examine the key issues inherent in the subject, such as transition, harmonization and political lobbying, and the international differences that remain. They also look at the special accounting problems of multinational companies. Tenth Edition Christopher Nobes and Robert Parker Comparative International Accounting Tenth Edition Nobes Parker www.pearson-books.com 25/3/08 14:50:00 CIA_A01.qxd 12/14/08 11:15 AM Page i COMPARATIVE INTERNATIONAL ACCOUNTING .. CIA_A01.qxd 12/14/08 11:15 AM Page ii We work with leading authors to develop the strongest educational materials in business and finance, bringing cutting-edge thinking and best learning practice to a global market Under a range of well-known imprints, including Financial Times Prentice Hall, we craft high quality print and electronic publications which help readers to understand and apply their content, whether studying or at work To find out more about the complete range of our publishing, please visit us on the World Wide Web at: www.pearsoned.co.uk .. CIA_A01.qxd 12/14/08 11:15 AM Page iii Tenth Edition COMPARATIVE INTERNATIONAL ACCOUNTING Christopher Nobes and Robert Parker .. CIA_A01.qxd 12/14/08 11:15 AM Page iv Pearson Education Limited Edinburgh Gate Harlow Essex CM20 2JE England and Associated Companies throughout the world Visit us on the World Wide Web at: www.pearsoned.co.uk First edition published in Great Britain under the Philip Allan imprint 1981 Second edition published 1985 Third edition published under the Prentice Hall imprint 1991 Fourth edition published 1995 Fifth edition published under the Prentice Hall imprint 1998 Sixth edition published 2000 Seventh edition published 2002 Eighth edition published 2004 Ninth edition published 2006 Tenth edition published 2008 © Prentice Hall Europe 1991, 1995, 1998 © Pearson Education Limited 2000, 2002, 2004, 2006, 2008 Chapter 18 © John Flower 2002, 2004, 2006, 2008 The rights of Christopher Nobes and Robert Parker to be identified as authors of this work have been asserted by them in accordance with the Copyright, Designs and Patents Act 1988. All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without either the prior written permission of the publisher or a licence permitting restricted copying in the United Kingdom issued by the Copyright Licensing Agency Ltd, 6–10 Kirby Street, London EC1N 8TS. ISBN: 978-0-273-71476-7 British Library Cataloguing-in-Publication Data A catalogue record for this book is available from the British Library Library of Congress Cataloging-in-Publication Data Comparative international accounting / [edited by] Christopher Nobes and Robert Parker. – 10th ed. p. cm. Includes bibliographical references and index. ISBN-13: 978-0-273-71476-7 (alk. paper) 1. Comparative accounting. I. Nobes, Christopher. II. Parker, R. H. (Robert Henry) HF5625.C74 2008 657— dc22 2008007524 10 9 8 7 6 5 12 11 10 09 4 3 2 Typeset in 9.5/12.5pt Stone Serif by 35 Printed by Ashford Colour Press Ltd., Gosport The publisher’s policy is to use paper manufactured from sustainable forests. .. CIA_A01.qxd 12/14/08 11:15 AM Page v Brief contents Contributors Preface xvi xviii Part I SETTING THE SCENE 1 2 3 4 Introduction Causes and examples of international differences International classification of financial reporting International harmonization 3 24 51 74 Part II FINANCIAL REPORTING BY LISTED GROUPS 5 6 7 8 9 10 The context of financial reporting by listed groups The requirements of International Financial Reporting Standards Different versions of IFRS practice Financial reporting in the United States Enforcement of Financial Reporting Standards Political lobbying on Accounting Standards – US, UK and international experience 101 117 145 157 189 206 Part III HARMONIZATION AND TRANSITION IN EUROPE AND EAST ASIA 11 12 Harmonization and transition in Europe Harmonization and transition in East Asia 237 257 Part IV FINANCIAL REPORTING BY INDIVIDUAL COMPANIES 13 14 15 The context of financial reporting by individual companies Making accounting rules for non-listed business enterprises in Europe Accounting rules and practices of individual companies in Europe 285 293 314 Part V MAJOR ISSUES IN FINANCIAL REPORTING BY MNEs 16 Key financial reporting topics 343 v .. CIA_A01.qxd 12/14/08 11:15 AM Page vi Brief contents 17 18 19 Consolidation Foreign currency translation Segment reporting 368 384 427 Part VI ANALYSIS AND MANAGEMENT ISSUES 20 21 22 23 International financial analysis International auditing International aspects of corporate income taxes Managerial accounting Glossary of abbreviations Suggested answers to some of the end-of-chapter questions Author index Subject index 457 481 510 531 558 563 583 587 Supporting resources Visit www.pearsoned.co.uk/nobes to find valuable online resources For instructors I Complete, downloadable Instructor’s Manual, Convenience. Simplicity. Success. including answers to the end of chapter questions in the text, additional questions for further study and multiple choice questions (with answers). I PowerPoint slides of the figures and tables in the book that can be downloaded and used as OHTs For more information please contact your local Pearson Education sales representative or visit www.pearsoned.co.uk/nobes. vi .. CIA_A01.qxd 12/14/08 11:15 AM Page vii Contents Contributors xvi xviii Preface Part I SETTING THE SCENE 1 Introduction Contents Objectives 1.1 1.2 1.3 1.4 1.5 Differences in financial reporting The global environment of accounting The nature and growth of MNEs Comparative and international aspects of accounting Structure of this book Summary References Useful websites Questions 2 Causes and examples of international differences 3 3 3 4 5 12 15 18 21 21 22 22 24 Contents Objectives 24 24 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 2.9 25 25 28 29 33 35 36 37 38 Introduction Culture Legal systems Providers of finance Taxation Other external influences The profession Conclusion on the causes of international differences Some examples of differences Summary References Questions 46 47 50 vii .. CIA_A01.qxd 12/14/08 11:15 AM Page viii Contents 3 International classification of financial reporting 51 Contents Objectives 51 52 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 52 53 53 55 56 60 66 67 69 69 Introduction The nature of classification Classifications by social scientists Classifications in accounting Extrinsic classifications Intrinsic classifications: 1970s and 1980s Developments related to the Nobes classification Further intrinsic classification Is there an Anglo-Saxon group? A taxonomy of accounting classifications Summary References Questions 4 International harmonization 70 71 73 74 Contents Objectives 74 74 4.1 4.2 4.3 4.4 4.5 75 76 78 87 91 Introduction Reasons for, obstacles to and measurement of harmonization The International Accounting Standards Committee Other international bodies The International Accounting Standards Board Summary References Useful websites Questions 94 95 97 98 Part II FINANCIAL REPORTING BY LISTED GROUPS 5 The context of financial reporting by listed groups 101 Contents Objectives 101 101 5.1 5.2 5.3 5.4 5.5 5.6 101 102 105 106 108 110 Introduction IFRS in the EU Adoption of, and convergence with, IFRS Foreign listing and foreign investing Reconciliations from national rules to US GAAP and IFRS High-level IFRS/US differences viii .. CIA_A01.qxd 12/14/08 11:15 AM Page ix Contents 5.7 5.8 Reconciliations from IFRS to US GAAP Convergence of IFRS and US GAAP Summary References Useful websites Questions 6 The requirements of International Financial Reporting Standards 111 113 114 115 116 116 117 Contents Objectives 117 118 6.1 6.2 6.3 6.4 6.5 6.6 118 118 125 128 130 131 Introduction The conceptual framework and some basic standards Assets Liabilities Group accounting Disclosures Summary References Further reading Useful websites Questions Appendix 6.1 An outline of the content of International Financial Reporting Standards 7 Different versions of IFRS practice 132 132 133 133 133 134 145 Contents Objectives 145 145 7.1 7.2 7.3 7.4 145 146 148 154 Introduction Motivations for different IFRS practice Scope for different IFRS practice Conclusion Summary References Questions 8 Financial reporting in the United States 155 155 156 157 Contents Objectives 157 158 8.1 8.2 158 159 Introduction Regulatory framework ix .. CIA_A01.qxd 12/14/08 11:15 AM Page x Contents 8.3 8.4 8.5 8.6 8.7 8.8 8.9 Accounting standard-setters The conceptual framework Contents of annual reports Accounting principles Consolidation Audit Differences from IFRS Summary References Further reading Useful websites Questions 9 Enforcement of Financial Reporting Standards 163 166 169 174 181 183 184 186 186 187 188 188 189 Contents Objectives 189 189 9.1 9.2 9.3 9.4 9.5 189 190 194 195 201 Introduction Modes and models of enforcement United States European Union Australia Summary References Useful websites Questions 10 Political lobbying on Accounting Standards – US, UK and international experience 202 202 204 205 206 Contents Objectives 206 206 10.1 10.2 10.3 10.4 10.5 10.6 10.7 10.8 207 208 210 220 224 228 229 231 Introduction Motivations for political lobbying Political lobbying up to 1990 US political lobbying from 1990 Political lobbying of the IASC/IASB Preparer attempts to control the accounting standard-setter Political lobbying of the FASB’s convergence with the IASB Some concluding remarks Summary References Useful websites Questions 231 232 234 234 x .. CIA_A01.qxd 12/14/08 11:15 AM Page xi Contents Part III HARMONIZATION AND TRANSITION IN EUROPE AND EAST ASIA 11 Harmonization and transition in Europe 237 Contents Objectives 237 237 11.1 Introduction 11.2 Harmonization within the European Union 11.3 Transition in Central and Eastern Europe 238 238 244 Summary References Useful websites Questions 253 253 256 256 12 Harmonization and transition in East Asia 257 Contents Objectives 257 257 12.1 Introduction 12.2 Japan 12.3 China 258 258 272 Summary References Further reading Useful websites Questions Appendix 12.1 ASBE Standards 277 278 280 280 280 282 Part IV FINANCIAL REPORTING BY INDIVIDUAL COMPANIES 13 The context of financial reporting by individual companies 285 Contents Objectives 285 285 13.1 Introduction 13.2 Outline of differences between national rules and IFRS or US GAAP 13.3 The survival of national rules 13.4 Financial reporting, tax and distribution 13.5 Special rules for small or unlisted companies 285 Summary References 292 292 286 286 289 290 xi .. CIA_A01.qxd 12/14/08 11:15 AM Page xii Contents Useful websites Questions 14 Making accounting rules for non-listed business enterprises in Europe 292 292 293 Contents Objectives 293 293 14.1 Introduction 14.2 Who makes accounting rules? 14.3 Which business enterprises are subject to accounting rules? 293 294 303 Summary References Further reading Useful websites Questions Appendix 14.1 Contents of the Plan comptable général Appendix 14.2 Financial accounting chart of accounts 307 308 309 310 311 312 313 15 Accounting rules and practices of individual companies in Europe 314 Contents Objectives 314 314 15.1 15.2 15.3 15.4 314 315 319 324 Introduction France Germany United Kingdom Summary References Further reading Useful websites Questions Appendix 15.1 Formats for French financial statements Appendix 15.2 Formats for German financial statements Appendix 15.3 Formats for British financial statements 326 326 327 327 327 328 333 336 Part V MAJOR ISSUES IN FINANCIAL REPORTING BY MNEs 16 Key financial reporting topics 343 Contents Objectives 343 343 16.1 Introduction 344 xii .. CIA_A01.qxd 12/14/08 11:15 AM Page xiii Contents 16.2 16.3 16.4 16.5 16.6 16.7 16.8 16.9 Recognition of intangible assets Asset measurement Financial instruments Provisions Employee benefits Deferred tax Revenue recognition Comprehensive income Summary References Questions 17 Consolidation 344 345 347 350 354 358 362 364 365 366 366 368 Contents Objectives 368 368 17.1 17.2 17.3 17.4 17.5 17.6 17.7 369 369 370 371 375 376 377 Introduction Rate of adoption The concept of a ‘group’ Harmonization from the 1970s onwards Definitions of group companies Publication requirements and practices Techniques of consolidation Summary References Further reading Questions 18 Foreign currency translation 381 382 382 382 384 Contents Objectives 384 385 18.1 18.2 18.3 18.4 18.5 18.6 18.7 18.8 18.9 18.10 18.11 385 389 395 398 401 406 409 411 413 419 423 Introduction Translation of transactions Introduction to the translation of financial statements The US initiative The temporal method versus the closing rate method FAS 52 IAS 21 Translation of comprehensive income Accounting for translation gains and losses Research findings An alternative to exchange rates? Summary References 423 424 xiii .. CIA_A01.qxd 12/14/08 11:15 AM Page xiv Contents Further reading Questions 19 Segment reporting 425 425 427 Contents Objectives 427 427 19.1 19.2 19.3 19.4 427 432 433 443 What is segment reporting? The need for segment information Disclosure regulations Evidence on the benefits of segment reporting Summary References Questions 450 451 453 Part VI ANALYSIS AND MANAGEMENT ISSUES 20 International financial analysis 457 Contents Objectives 457 457 20.1 20.2 20.3 20.4 20.5 458 458 463 470 474 Introduction Understanding differences in accounting Disclosure practices in international financial reporting Interpreting financial statements Financial analysis and the capital market Summary References Useful websites Questions 21 International auditing 477 478 480 480 481 Contents Objectives 481 481 21.1 21.2 21.3 21.4 482 484 489 495 Introduction Reasons for the internationalization of auditing Promulgating international standards The international audit process Summary References Further reading Useful websites Questions 507 508 508 508 509 xiv .. CIA_A01.qxd 12/14/08 11:15 AM Page xv Contents 22 International aspects of corporate income taxes 510 Contents Objectives 510 510 22.1 22.2 22.3 22.4 22.5 22.6 511 513 517 518 519 525 Introduction Tax bases International tax planning Transfer pricing Tax systems Harmonization Summary References Further reading Useful websites Questions 23 Managerial accounting 527 527 529 529 529 531 Contents Objectives 531 531 23.1 23.2 23.3 23.4 23.5 23.6 23.7 532 533 535 539 540 549 551 Introduction The balanced scorecard as an overview tool Currency and control Variances and foreign exchange Culture and management accounting Control and performance Looking forward Summary References Questions 553 554 557 Glossary of abbreviations 558 Suggested answers to some of the end-of-chapter questions 563 Author index 583 Subject index 587 xv .. CIA_A01.qxd 12/14/08 11:15 AM Page xvi Contributors Co-editor, author of Chapters 2, 3, 4, 5, 6, 7, 8, 12, 13, 16 and 22, and co-author of Chapter 17 Christopher Nobes Professor of Accounting at Royal Holloway College, University of London. He has also taught in Australia, Italy, the Netherlands, New Zealand, Scotland, Spain and the United States. He is currently a visiting professor at the Norwegian School of Management. He was the 2002 ‘Outstanding International Accounting Educator’ of the American Accounting Association. He was a member of the Accounting Standards Committee of the United Kingdom and Ireland from 1986 to 1990, and a UK representative on the Board of the International Accounting Standards Committee from 1993 to 2001. He is vice-chairman of the accounting committee of the Fédération des Experts Comptables Européens. Co-editor, author of Chapters 1, 9, 11, 14 and 15, and co-author of Chapter 17 Robert Parker Emeritus Professor of Accounting at the University of Exeter and former professorial fellow of the Institute of Chartered Accountants of Scotland. He has also practised or taught in Nigeria, Australia, France and Scotland and was editor or joint editor of Accounting and Business Research from 1975 to 1993. He was the British Accounting Association’s ‘Distinguished Academic of the Year’ in 1997, and the 2003 ‘Outstanding International Accounting Educator’ of the American Accounting Association. Authors of other chapters Jan Buisman IFRS Senior Technical Partner for PricewaterhouseCoopers in Sweden and partner in the firm’s Global Corporate Reporting Group. He was formerly the Netherlands representative on the International Auditing Practices Committee, and chairman of Royal NIVRA’s Auditing Standards Board. He is now chairman of the Accounting Practices Committee of FAR in Sweden. (Co-author of Chapter 21) John Flower Formerly, Director of the Centre for Research in European Accounting (Brussels), and earlier with the Commission of the European Communities and Professor of Accounting at the University of Bristol. He now lives in Germany. (Chapter 18) Graham Gilmour Senior Manager in the Global Corporate Reporting Group of PricewaterhouseCoopers. (Co-author of Chapter 21) Stuart McLeay Professor of Treasury at the University of Wales, Bangor. Formerly, he worked as a chartered accountant in Germany, France and Italy, and was a financial analyst at the European Investment Bank. Co-editor of the ICAEW European Financial Reporting series. (Chapter 20) xvi .. CIA_A01.qxd 12/14/08 11:15 AM Page xvii Contributors Clare B. Roberts Professor of Accounting at the University of Aberdeen Business School. (Chapter 19) Stephen Salter Associate Professor and Director of the Center for Global Competitiveness at the University of Cincinnati. Formerly, he was a partner at Ernst & Young Management Consultants. (Chapter 23) Stephen A. Zeff Herbert S. Autrey Professor of Accounting at Rice University. (Chapter 10) xvii .. CIA_A01.qxd 12/14/08 11:15 AM Page xviii Preface Purpose Comparative International Accounting is intended to be a comprehensive and coherent text on international financial reporting. It is primarily designed for undergraduate and postgraduate courses in comparative and international aspects of accounting. We believe that a proper understanding requires broad overviews (as in Part I), but that these must be supported by detailed information on real countries and companies (as in Parts II to IV) and across-the-board comparisons of major topics (as in Parts V and VI). This book was first published in 1981. This present edition (the tenth) is a complete updating of the ninth edition which constituted the most extensive revision that we had ever made. One chapter (7) has been added: an examination of the possible motivations and opportunities for different national versions of IFRS practice. A revised manual for teachers and lecturers is available from http://www. pearsoned.co.uk/nobes. It contains several numerical questions and a selection of multiple-choice questions. Suggested answers are provided for all of these and for the questions in the text. In addition, there is now an extensive set of PowerPoint slides. Authors In writing and editing this book, we have tried to gain from the experience of those with local knowledge. This is reflected in the nature of those we thank below for advice and in our list of contributors. For example, the original chapter on North America was co-authored by a Briton who had been assistant research director of the US Financial Accounting Standards Board; his knowledge of US accounting was thus interpreted through and for non-US readers. The amended version is by one of the editors, who has taught in several US universities. This seems the most likely way to highlight differences and to avoid missing important points through overfamiliarity. The chapter on political lobbying has been written by Stephen Zeff, an American who is widely acknowledged as having the best overview of historical and international accounting developments. Other contributors presently live or work in Germany, in Sweden and in the United States. Structure Part I sets the scene for a study of comparative international financial reporting. Many countries are considered simultaneously in the introductory chapter and when examining the causes of the major areas of difference (Chapter 2). It is then xviii .. CIA_A01.qxd 12/14/08 11:15 AM Page xix Preface possible to try to put accounting systems into groups (Chapter 3) and to take the obvious next step by discussing the purposes and progress of international harmonization of accounting (Chapter 4). All this material in Part I can act as preparation for the other parts of the book. Part I can, however, be fully understood only by those who become well-informed about the contents of the rest of the book, and readers should go back later to Part I as a summary of the whole. Part II examines financial reporting by listed groups. In much of the world this means, at least for consolidated statements, using the rules of either the International Accounting Standards Board or the United States. In addition to an overview and chapters on these two ‘systems’ of accounting, Part II also contains a chapter on whether national versions of IFRS exist, one on enforcement of accounting regulations, and one on political lobbying. Part III contains two chapters that examine the processes of harmonization and transition as applied in the EU and East Asia. Part IV concerns the financial reporting of individual companies, where large international differences remain. There are three chapters: context, regulatory styles, and accounting differences. Part V examines, broadly and comparatively, particular major financial reporting topics: key non-consolidation issues, consolidation, foreign currency translation and segment reporting. Part VI considers four issues of international analysis and management: international financial analysis, international auditing, international aspects of corporate income taxes, and managerial accounting. At the end of the book, there is a glossary of abbreviations relevant to international accounting, suggested answers to some chapter questions, and two indexes (by author and by subject). Publisher’s acknowledgements We are grateful to the following for permission to reproduce copyright material: Table 1.4: United Nations Conference on Trade and Development (UNCTAD) (2007) World Investment Report 2007: Transnational Companies, Exractive Industries and Development. Geneva, UNCTAD. Copyright © United Nations 2007; Table 1.8: United Nations Conference on Trade and Development (UNCTAD) (2007) World Investment Report 2007: Transnational Companies, Exractive Industries and Development. Geneva, UNCTAD. Copyright © United Nations 2007; Table 2.3: Source of data: Datastream. Reproduced by kind permission of Jon Tucker and David Bence of Bristol Business School; Figure 3.1: American Accounting Association (1977) Accounting Review, Supplement to Vol. 52, 1977, p. 99. Copyright © 1977 American Accounting Association. Reproduced with permission; Figure 3.2: Puxty, A.G., Willmott, H.C., Cooper, D.J. and Lowe, A.E. (1987) ‘Modes of regulation in advanced capitalism: locating accountancy in four countries’, Accounting, Organizations and Society, Vol. 12, No. 3, p. 283. Reproduced with permission of Elsevier; Table 3.1: Nair, R.D. and Frank, W.G. (1980) ‘The impact of disclosure and measurement practices on international accounting classifications’, Accounting Review, Vol. 55, No. 3, p. 429. Reproduced with permission of the American xix ..
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