Title: The Convergence of International Accounting Standards and Practices
1The Convergence of International Accounting
Standards and Practices
- Cynthia Jeffrey
- Iowa State University
2- How different is accounting internationally
(across countries)? - What historical factors have contributed to these
differences?
3- Each nation has its own accounting rules that
tend to mirror certain elements in that nation. - A country's economic, legal, and political
systems stages of technological development or
sophistication culture and tradition and
various other socioeconomic factors all influence
the development of accounting standards and the
accounting profession in that nation.
4- These differences have led to significant
diversity in accounting standards from one nation
to another. - Given the growth of international business
activity, and especially international
investment, comparability of accounting standards
has a high priority. - International diversity in national accounting
standards has the potential to diminish the
international flow of investment capital and
thereby hinder economic development and the
efficient international allocation of resources.
5What are the international responses to
across-country accounting differences?
- Reconciliations versus mutual acceptance versus
one set of global accounting standards and
practices.
6Convergence of Accounting Standards
- It is useful to think about a continuum ranging
from total flexibility and diversity to total
uniformity. - Convergence implies a more flexible approach
whereby a limited set of alternatives are
acceptable, compared to standardization, which
implies a state of uniformity.
7- What kinds of problems are allegedly caused by
international accounting differences? - Potential inefficient allocation of scare
resources.
8Convergence of Accounting Standards
- Arguments for convergence
- Not only can convergence help with resource
allocation, but a multinational accounting firm
and the preparers of financial information, can
make a strong argument for increased convergence.
- The burden of financial reporting would be
lessened with increased convergence, which would
simplify the process of preparing individual and
group financial statements.
9How Different is Different?
- Example The News Corporation (an Australian
firm) reported 1992 earnings of 502 million
(Australian dollars). Under US GAAP, earnings
would have been about 421 million (Australian
dollars). The difference is about 16 of income
under Australian GAAP.
10Potential Costs?
- As an example of the financial cost of complying
with the differing accounting rules in different
countries, an article in WSJ described the costs
incurred by an international firm which sought to
sell an offering of securities in the US, Canada,
and the UK. - The offering required three sets of financial
statements and finally cost 2.8 million to get
the 55.5 million offering registered.
11Difficulties
- In general, there are difficulties in comparing
income, net assets, and shareholders equity
across countries.
12International Barriers to Convergence
- 1. Accounting itself is a judgmental and social
discipline, reflecting the needs of its
particular business environment - 2. National traditions, educational
opportunities, and business and accounting
attitude differences among nations - 3. Legal and economic differences among the
nations - 4. State sovereignty
- 5. Economic gaps between developed and
developing nations.
13Recognition Criteria Differ
- What items are recorded in the financial
statements, at what times? - Intangible assets, certain leases, goodwill
14Measurement Criteria Differ
- Historical cost versus inflation adjustments
versus fair values
15Disclosure Rules Differ
- What should be reported in the notes and
supporting schedules? - Management compensation
16Broad Categorizations
- TYPE A
- True and fair view
- Shareholder orientation
- Disclosure emphasized
- Tax rules separate
- Professional Standards
- TYPE B
- Legal-oriented view
- Creditor orientation
- Secrecy is emphasized
- Linked to tax rules
- Government rules
17Example of Specific Policies
- Depreciation over useful lives
- Limited or no use of legal reserves
- Lease capitalization
- Cash flow or funds statement
- Depreciation by tax rules
- Extensive use of legal reserves
- No leases capitalized
- No cash flow or funds statement
18Examples of Countries
- United Kingdom
- United States
- Australia
- Canada
- France
- Germany
- Spain
- Italy
19Historical Reasons for Differences
- Predominant modes of financing and ownership.
- Banks, and small groups of owners
- Government
- Shareholders
- Each of these different types of financing
arrangements implies differences in what
accounting information is needed for decision
making.
20- Legal system
- English common law versus codified law systems
- Differences in approaches to securities
regulation - Use of financial reports for taxation
- Audited reports for capital markets versus for
tax calculations
21What kinds of issues are allegedly raised by
International Accounting Differences?
- The holding of shares across international
boundaries is becoming more common, so more users
are confronting noncomparabilty of financial
statements - It is sometimes alleged that international
capital flows are needlessly hampered by the need
for users (investors) to develop their own
comparability adjustments.
22- Multinational firms are expanding their
operations cross-nationally, so more preparers
are confronting noncomparable accounting
standards and rules
23- What is viewed as acceptable or even desirable
accounting practice in one country might be
viewed as unacceptable or even misleading in
another country. - Example LIFO inventory valuation in the United
States.
24- Internal performance evaluation in large
multinational firms might be affected by the use
of different accounting and measurement systems
25- Large CPA firms are expanding their wold-wide
operations and facing attestation engagements
under widely varying accounting and reporting
systems. What does an audit report mean if there
are divergent practices across countries?
26- The US accounting system (part of the overall US
securities regulation system) is allegedly
needlessly stringent and discouraging to
international capital flows - Worldwide equity capitalization (one measure of
the demand for capital) is current estimated at
about 17 trillion. (Privatizations in China,
Europe coming)
27- There is intense competition for non-domestic
listings, particularly among the NYSE, NASD, and
the LSE. This competition could increase to the
extent the European exchanges develop new
alliances (remember the proposed alliance between
the LSE and the Frankfurt exchange--derailed
because of an unfriendly takeover bid for the LSE)
28Convergence
- Convergence refers to the process of increasing
the consistency and comparability of accounting
across countries, with the goal of removing
(alleged) impediments to international capital
flows.
29Is it Possible? Or Desirable?
- To the extent that accounting differences result
from underlying differences in economic, legal,
social, and other environmental factors,
accounting convergence may simply not be
appropriate.
30- The differences in accounting are so deep and
numerous that they are structural in nature and
it would take extremely strong actions to remove
them. - Some countries do not have a long tradition of a
strong accounting profession while others do.
Government intervention would be necessary to
achieve convergence, and this raises problems of
nationalism.
31Two Approaches to Convergence
- 1. Evolution in the development of accounting
principles. - This approach recognizes the reasons for the
differences in accounting principles countries
with different economic and legal systems should
have different accounting principles. - Time and the natural development of the
countries' economies would be necessary to bring
accounting principles into closer harmony. - That is, the natural evolution of accounting
principles within each nation would tend to
narrow the alternatives, and this would reduce
the degree of diversity from country to country.
- Other forces, including international competition
for investment and loan, would also work to
reduce diversity.
32Two Approaches to Convergence
- 2. The more dominant view posits that formal
action should be taken to reduce diversity. - This view looks to organizations for standard
setting with multi-country authority. - This is the problem! Enforcement?
- For a country to voluntarily give up their own
accounting destinies and delegate to others the
power to set accounting standards represents a
reduction in the national sovereignty.
33- Some who interpret convergence as implying the
use of a single set of financial reporting
standards worldwide favor the use of
International Accounting Standards, as
promulgated by the International Accounting
Standards Board (IASB)
34IASC
- International Accounting Standards Committee
- The concept was introduced as early as 1904 with
the First International Congress of Accountants
in St. Louis. - But it wasn't until 1973 that the International
Accounting Standards Committee (IASC) was founded
by the leading professional accounting bodies in
9 nations - Australia, Canada, France, Germany, Japan,
Mexico, the Netherlands, the UK, and the US. - Members are not nations, but rather accounting
bodies within nations are members. - In the US, the AICPA is a member, not the FASB or
the SEC. - In this way, no nation completely surrenders its
accounting sovereignty to the IASC. - Now, accounting bodies from over 91 nations are
members.
35- Recently, the IASC was restructured. The IASC is
the foundation that oversees the International
Accounting Standards Board IASB.
36IASB
- 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.
37- IASC was be established as an independent
foundation. The foundation has two main bodies,
the Trustees and the Board, as well as a Standing
Interpretations Committee and Standards Advisory
Council. The Trustees would appoint the Board
members, exercise oversight and raise the funds
needed, whereas the Board would have sole
responsibility for setting accounting standards.
38IASC, IASB
- Objectives
- 1. To formulate and publish international
financial standards - 2. To promote worldwide acceptance and
observation - 3. To facilitate a "common international
approach" to the harmonization of accounting
principles
39-
- Develop and aid the implementation of
international accounting standards that satisfy
the needs of developing and newly industrialized
countries - Narrow the differences between international
accounting standards and the various national
accounting requirements with a goal of developing
greater compatibility and easier comparability of
financial reporting.
40- The IAS Standards tend to follow the principles
of true and fair value and full disclosure,
consistent with the Type A view above.
41IASC
- A conceptual framework (Framework for the
Preparation and Presentation of Financial
Statements) is being developed for guidance. - objectives of financial statements,
- qualitative factors of financial information,
- the elements and the recognition criteria of
financial statements. - By the beginning of 1993, IASC had produced 31
statements which are very similar in content and
format to FASB statements. - Member organizations have pledged to use their
best efforts to have the standards adopted by
their national authoritative standard setting
bodies.
42IOSCO Charge
- In July 1995, the IOSCO Technical Committee
stated its agreement with the work plan, as
follows - The IASC Board has developed a work plan that
the Technical Committee agrees will result, upon
successful completion, in IAS comprising a
comprehensive core set of standards.
43- Completion of the comprehensive core standards
that are acceptable to the IOSCO Technical
Committee to recommend endorsement of IAS for
cross-border capital raising an listing purposes
in all global markets. - The goal is for 40 core standards.
44- The project was completed late in 1998.
- IOSCO, the International Organization of
Securities Commissions, has agreed to consider
these standards for registering and listing
shares.Within IOSCO, the key commissions are
those in Canada, Japan, and the US. These
countries are the most restrictive with regard to
to the use of (or reconciliation to) domestic
GAAP.
45IOSCO
- May 30, 2002--IOSCO Annual Conference encourages
cooperation to achieve convergence - http//www.iasc.org.uk/cmt/0001.asp?s896113sc7
5E9A0E3-85F3-4F1C-B03E-5C65B88F506Dn4083
46Adopters of IASCs
- Some countries have adopted IASC standards with
few amendments (Nigeria, Malaysia, Russia). Such
adoptions can be advantageous to countries with
developing market economies. - Stock exchanges in more than 30 countires (but
not the US) allow international standards, at
least for foreign registrants.
47US POLICIES
- Under current US regulations, any issuer who
wishes to access the US equity market must
conform to SEC rules, including filing
reconciliations of income and shareholders equity
with US GAAP on Form 20-F. - IF the SEC were to accept IAS for cross-border
listings, these form 20-F reconciliations would
presumably disappear for IAS users.
48Why Would a Non-US Issuer Object to
Reconciliations?
- Out of pocket costs to prepare
- Disclosure of proprietary information, including
reserves, segment data, and Form 10-Q
49Why might the SEC insist?
- Possible belief that US GAAP is superior
- Investor protection under US securities laws,
accounting rules and enforcement mechanisms - Emphasis on individual investor. IS this
important any more? Funds, and the effects of
online brokerages. 65 of trades are individual
investors.
50SEC Decision
- The SEC is a voting member of the IOSCO Technical
Committee that endorsed the IASC core standard
project.
51SEC Decision
- The broad policy decision is whether to allow IAS
for cross-border capital raising. - Complete acceptance and complete rejection are
not the only options - Partial acceptance? (early vs. late?)
- Continue to require some reconciliations?
- What would acceptance of current standards imply
for subsequent standards?
52SEC Criteria
- Comprehensiveness
- High quality, including Transparency, Full
Disclosure, and Comparability - Rigorous interpretation and application
- These criteria (presumably) derive from the
investment framework of US standard setting, with
its focus on the role of accounting in capital
allocation decision
53IASC
- Consider the structure and decision process
- IASC standards have been criticized for imprecise
language, and PURPOSEFUL ambiguity - No mechanisms for ascertaining what constitutes
compliance. (Recent establishment of the
Standing Interpretatins Committee to assist in
application of IAS)
54- Under the old structure, More than 91 people
could attend (and could speak) at each meeting
meetings were held only about four times per year.
55IASC
- Some feel that the current IASC standards fall
short by allowing too many free choices of
accounting treatments and by lack of any comment
on some important aspects of financial reporting.
56Assessment
- The FASBs comparison project identified 225
instances of differences between US GAAP and IAS,
but there is no measure of materiality of the
differences. - How do we distinguish between uniformity and
equivalence?
57- Uniformity--Identical
- Equivalence--of equal usefulness in terms of
relevance and reliability - Example, are LIFO and FIFO, with note disclosure
of the LIFO reserve equivalent? - The user must make a conversion--does this affect
comparability?
58IFAC
- International Federation of Accountants
- 1977 - Two objectives
- 1. To arrange future international congresses
- 2. To achieve international technical, ethical,
and educational guidelines for the accounting
profession - that is, to promote a coordinated, worldwide
accounting profession with harmonized standards - Main work to date
- Issuing auditing and professional guidelines and
issues and the enhancement of the quality of the
accountancy profession. - Five standing committees
- Auditing, Education, Ethics, Public Sector,
Management, Financial.
59IFAC and IASC
- Interactions between IFAC and IASC
- IASC is sole source for issuing international
accounting standards - IFAC nominated all members on IASC board and
contribute 10 of IASC's budget. - IFAC is "spokesperson for the worldwide
accounting profession"
60European Community
- The roots of the European Community can be traced
back to 1948 and the establishment of the
Organization for European Economic Cooperation to
administer the Marshall Plan. - The Marshall Plan was an aid program designed to
rebuild Europe economically after WWII. - In 1952, the European Coal and Steel Community
was established among France, Germany, Italy,
Belgium, the Netherlands, and Luxembourg.
61European Community
- From this beginning, the Common Market evolved in
1957 with the signing of the Treaty of Rome. - The same 6 countries participated in the new
union, joined by Great Britain, Denmark, and
Ireland in 1973, Greece in 1981, and Spain and
Portugal in 1986. - The belief supporting the Common Market is that
cross-country economic integration is necessary
for Europe to compete with the US (and formerly
with the USSR).
62European Community
- The first step was Customs Union, which involved
the abolition of national import tariffs and
restrictions. - This union was achieved in the late 60s, and a
common external trade policy was implemented. - The remaining two steps are Economic Union, which
involves the harmonization of national social,
fiscal, and monetary polices. - This phase is in process.
- The third phase is political union which is
envisioned as a "United States of Europe."
63European Community
- The European Community has made convergence of
accounting standards a part of the second level
of integration. - Each nation in the EC has its own approach to
accounting, and these are often on opposite ends
of the accounting spectrum. - The convergence of accounting standards within
the EC is being carried out by means of EC
directives, which, when approved by the EC's
Council of Ministers, become binding on the
member nations.
64European Community
- The nations must change their own national
legislation, typically within 18-36 months, to
comply with the directive. - However, a great deal of time (up to 10 years)
can elapse from the initial conception of a
directive to its final approval! - The EC Commission consults with the EC Accounting
Study Group, which is composed of representatives
from the leading professional accounting
organizations of the EC countries.
65European Community
- The EC has also established an Accounting
Advisory Forum made up of users, preparers, and
standard setters as a consultative group. - This body is expected to work with the IASC.
- Historically the EC has tended to ignore the
IASC, but they are making efforts to bridge this
gap.
66European Community
- There have been directives that relate to
accounting and financial reporting - 4, 5 (withdrawn), 7, 8, and 11.
- The 4th is outlined in great detail in your book.
- The 7th Directive dealt with consolidation
concepts - instead of following the traditional legal basis
in defining a group, it concentrated on economic
factors, such as dominance and dependence among
entities. - For example, as US firm with EC operations would
have to prepare an EC consolidation for its EC
operations--a broader perspective than commonly
used in the US.
67European Community
- The 8th Directive is primarily concerned with the
qualification and training of auditors performing
statutory audits. - It initially dealt with auditor independence.
- This issue was eventually excluded because
agreement could not be reached. - The final version of the directive simply states
that an auditor should be a "person of good
repute," and should carry out audits with
"professional care," and should follow the
appropriate national standards for independence. - The 11th Directive concerns disclosure
requirements for a branch located in an EC
country with its parent company based in another
company.
68European Community
- Post 1992 Europe
- In 1985, leaders of the EC promised that by the
end of 1992 they would eliminate all of the
bothersome internal barriers. - Europe 1992 became a code word signifying the
coming birth of an economic superpower, perhaps
on its way to becoming one very powerful
federation of interdependent countries. - To a very large extent, this has occurred
although not to the extent envisioned.
69European Community
- New opportunities for businesses and consumers
opened up on January 1, 1993 with the official
launching of the Single European Market. - Many barriers were removed and much harmonization
of standards (including accounting standards) has
been established in a process of creating a
unified European economy.
70European Community
- Internal customs checks have been eliminated.
- Banks licensed in any EC country may now offer
their services anywhere within the EC - although special licensing procedures are faced
by banks from countries which have been slower in
incorporating EC banking rules into national
legislation. - Capital adequacy and solvency standards applying
to banks are the same throughout the EC. - Restrictions on intra-EC capital movements and
double taxation of affiliated companies have been
eliminated, and a set of EC-wide merger controls
have been established.
71European Community
- Similar efforts are underway on behalf of the
investment services and insurance industries. - Labor mobility is being improved by mutual
recognition of qualifications. - Some 30 additional European Countries are
knocking on the door to join the 12 countries now
in the EC. - A great many barriers still remain, and there are
problems and disagreements. - There is no easy way to enforce all aspects and
there is no clear cut method to mediate disputes.
72European Community
- The EC has also established an Accounting
Advisory Forum made up of users, preparers, and
standard setters as a consultative group. - This body is expected to work with the IASC.
- Historically the EC has tended to ignore the
IASC, but they are making efforts to bridge this
gap.
73Where Does the FASB Fit In?
- The attitude of the FASB toward the IASC has been
characterized as benign neglect, uncooperative,
uninterested, and less than enthusiastic. - It has also been said that the FASB's idea of
convergence has been to play the lead role. - The FASB does keep in close touch with
international accounting developments - In 1991 they indicated a plan for increased
involvement in international activities. - The FASB's objective is to "create a body of
superior international accounting standards
accepted in all countries as GAAP for general
purpose external financial statements.
74Where Does the FASB Fit In?
- The board intends to work in the international
arena through the following standard setting
efforts - 1. Intensify consideration of IASC and other
standards - 2. Engage in joint standard-setting activities
with foreign counterparts to produce results
consistent with IASC standards - 3. Consider adopting some superior foreign
standards in the US and to convince others to
consider adopting superior US standards. Make
joint choices where neither principles are
superior. - 4. Continue efforts to encourage equality of
financial statement requirements for US and
foreign issuers in their use of US markets.
75Two International Pressure Sources for
Accounting and Audit Harmonization
- 1. Global Capital Markets
- 2. Global Trade in Goods and Services
76Global Capital Markets
- More investors seek investment opportunities in
other countries - In 1975, 65 billion was the grand total for all
transactions involving foreigners buying US
securities and US citizens buying foreign
securities. - By 1989, that amount had grown 80 times to
5.4 trillion! - More securities are sold internationally.
- In 1990, more than 500 companies were listed on
at least one stock exchange outside their home
country, and there were more than 50 mutual funds
specializing in single country investments.
77Global Capital Markets
- More capital crosses borders for investment in a
variety of industrial and other undertakings. - In 1989, foreigners spent 65 billion to buy or
establish 1,101 business in the US. - Many European corporations with global operations
wish to sell their securities in the countries
where they have a business presence. - On Monday, October 19, 1987, national stock
markets crashed simultaneously because they were
now part of a global market.
78Global Capital Markets
- CONCERNS
- 1. The investor in foreign markets is exposed
to greater risks since his/her funds are being
allocated on the basis of nonuniform accounting
information. - 2. Opportunity cost in lost transactions to the
local financial community of the country with
more rigorous requirements.
79Global Capital Markets
- SEC Commissioner Lochner took issue with US
listing rules for foreign securities that require
compliance with US GAAP - Some companies apparently do not list in this
country to avoid US GAAP compliance costs. - The Commissioner believes
- Harmonized GAAP would provide investors with
financial statements that are far more comparable
than those they may be currently using. - Harmonization would increase dramatically the
willingness of foreign issuers to participate in
US securities markets.
80Global Capital Markets
- For sophisticated GAAP countries, there are
serious economic consequences to a capital flight
to less sophisticated markets - 1.The protective mission of their securities
regulators is thwarted by their investors'
considerable flight to lower GAAP markets. - 2.Their investors' choices may be suboptimal
since they are based on financial statements
lacking uniformity. - 3.Their financial services industry loses
transaction revenues. - 4. Their cost of debt and equity capital
increases.
81Global Capital Markets
- According to the chair of the NYSE
- We've got to trade foreign securities here this
is one industry in which this country is the
leader of the world. And we're going to lose
that leadership. Unless we get started this
thing will pass us by. (WSJ, 1991)
82Global Capital Markets
- The NYSE already trades over 100 foreign
companies, but there are some 2,000 to 3,000 such
companies that could qualify for listing. - About 250 of these have stock market values about
20 times the size of the average NYSE listing. - Many of these firms don't meet NYSE listing
standards because of the GAAP they use. - The SEC is aware of this but is reluctant to ease
accounting requirements because they fear it may
introduce unwarranted greater risks in US
securities markets.
83Global Capital Markets
- Some foreign issuers see the tough US rules as
valuable for those who meet them. - 1990
- Compania de Telefonos de Chile listed on the NYSE
and raised 100 million, followed shortly by
another offering of 90 million. - The company's CFO stated
- When we prepared for the issue in 1990, we made
the decision to go for a public US offering. The
accounting rules were far stricter, but by
complying with them we gained credibility not
only in the US but also in Europe and Asia. We
wouldn't have been so successful in achieving
financing if investors hadn't already known that
we fully complied with the SEC and GAAP.
84Global Capital Markets
- Despite accounting diversity, the international
dimensions of capital markets have experienced
tremendous growth. - Diversity may not be insurmountable, but is it
still serious enough to create strong pressures
for its reduction or elimination?
85Global Capital Markets
- Choi and Levich surveyed investment-related
public. - Groups surveyed
- Institutional investors, Corporate issuers,
Rating agencies' representatives, Underwriters,
Market regulators, an international financial
data service, an organization working for
increased accounting harmony - FROM NY, Frankfurt, Tokyo, London, Zurich
86Global Capital Markets
- Main findings
- Approximately half of the respondents felt that
accounting diversity affects market decisions. - The remaining respondents either had developed
coping mechanisms which nullified the negative
effects of accounting diversity or felt that the
lack of accounting uniformity was not a
significant problem. - Choi and Levich concluded that accounting
differences are important and affect the
investment decisions of a significant number of
market participants regardless of nationality,
size, experience, scope of international
activity, and organization structure. - Restatement was not sufficient to remove the
problem of lack of uniformity.
87Global Trade in Goods and Services
- Growing willingness to try free market approaches
to the trade of goods and services. - This seems to be leading many nations to join in
free trade zones or common markets. - IT is somewhat of a halfway point between highly
protected national markets and a free trade based
global economy. - GATT--General Agreement on Tariffs and Trade
(1985) - Participants agreed to vigorously decrease a host
of protectionist practices - NAFTA