International Variations in
IFRS Adoption and Practice
Research report 124
International Variations in
IFRS Adoption and Practice
Professor Christopher Nobes
Royal Holloway, University of London
Certied Accountants Educational Trust (London), 2011
ISBN: 978-1-85908-473-1
© The Association of Chartered Certied Accountants, 2011
ACCA’s international research programme generates high-prole, high-quality, cutting-edge research. All research
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Chartered Certied Accountants, 29 Lincoln’s Inn Fields, London WC2A 3EE.
3
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
Contents
Abbreviations 4
Executive summary 5
1. Introduction 7
2. International differences before IFRS 9
3. Grouping countries and accounting systems 14
4. How countries react to IFRS 16
5. Different national patterns of IFRS practice 21
6. National patterns on transition to IFRS 25
7. Have national patterns persisted? 31
8. Country groups and national patterns of IFRS 33
9. Does size matter? 35
10. Conclusions 36
References 38
4
ACCA Association of Chartered Certied Accountants
AGL actuarial gains and losses
ASB Accounting Standards Board
ASX Australian Stock Exchange index
AVCO average cost
BRIC Brazil, Russia, India and China
CAC French Stock Exchange index
DAX German Stock Exchange index
DC dominated culture
EU European Union
FIFO rst in, rst out
FPI foreign private issuer
FRRP Financial Reporting Review Panel
FTSE Financial Times Stock Exchange index
GAAP generally accepted accounting principles
HGB Handelsgesetzbuch (German Commercial Code)
IAS International Accounting Standard
IASB International Accounting Standards Board
IASC International Accounting Standards Committee
IBEX Iberian Stock Exchange index
IFRIC International Financial Reporting Interpretations Committee
IFRS International Financial Reporting Standards
JV joint venture
LIFO last in, rst out
OCI other comprehensive income
PPE property, plant and equipment
SCE statement of changes in equity
SEC Securities and Exchange Commission
SMEs small and medium-sized entities (or enterprises)
SORIE statement of recognised income and expense
SSAP Statement of Standard Accounting Practice
SSC self-sucient nancial and legal culture
Abbreviations
5
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
EXECUTIVE SUMMARY
amendments and then insert the result into law. All these
methods (apart from simply imposing IFRS) need
continual attention from regulators. Divergences from IFRS
can emerge, not least in the timing of adoption of
amendments and new standards. Auditors do not always
report on compliance with ‘IFRS as issued by the IASB’
even when this is being achieved.
The two-type classication can be used to explain and
predict which countries will allow IFRS for unconsolidated
reports. In Europe, only those with a history of strong
equity markets allow IFRS for this purpose. This is because
such countries have tax accounting that is, for many
topics, separate from nancial reporting. Therefore, IFRS
can be used in such countries without upsetting tax
calculations.
Several major countries have not yet moved to IFRS even
for listed companies – Brazil and Canada are adopting
IFRS, at least for listed companies in 2010 and 2011
respectively. It seems unlikely that China or Russia will fully
adopt IFRS in the near future. The US might partially adopt
IFRS for 2014 or later; Japan possibly for 2016.
Some of the factors that led to pre-IFRS international
accounting dierences can still inuence IFRS practices.
For example, there is still scope for tax inuence to feed
through from non-IFRS unconsolidated statements to IFRS
group statements.
There are many opportunities for IFRS practices to dier
from company to company or from country to country. For
example, dierent versions of IFRS arise because most
countries introduce delays or changes when implementing
IFRS; in addition, there are options within IFRS. For several
reasons, it can be expected that a company will continue
with many of its previous accounting policy choices when
it rst adopts IFRS. This report lists 13 policy choices and
makes predictions about which choices would be made
under IFRS in ve countries: Australia, France, Germany,
Spain and the UK. The actual policy choices made by large
listed companies in these ve countries for 2005 are then
recorded. There is statistically strong evidence that pre-
IFRS national practices have continued. The national
patterns of IFRS practice are set out in order to help users,
preparers and auditors to appreciate the dierences and
to compare annual reports.
The policies for the same countries and companies are
examined again in 2008. The report shows that there had
been few policy changes since 2005 and, therefore, the
national patterns remain. One major change did occur
between 2005 and 2008: Continental companies moved
to the UK practice of charging actuarial losses to other
comprehensive income (and, incidentally, they therefore
had to present a statement of such income).
Executive summary
This report is designed to investigate the degree to which
nancial reporting remains dierent, by country, even
within the area of the world that has apparently adopted
International Financial Reporting Standards (IFRS). The
dierences between countries can be divided into two
main types: (i) the degree to which IFRS has been
mandated or allowed for particular companies or types of
reporting, and (ii) the degree to which the practice of IFRS
diers along national lines. These two issues are closely
linked because of the underlying forces that have caused
the long-running accounting dierences between
countries.
International dierences in nancial reporting create
problems because many users (eg investment analysts
acting for investors in equity or debt) assess companies on
a comparative basis internationally. Reconciliations from
one set of generally accepted accounting principles (GAAP)
to another (especially to US GAAP) were common until
2007, and they revealed signicant dierences between
countries. A standard reporting system for listed
companies would address these problems. There would be
disadvantages if the whole world had to adopt US GAAP.
Therefore, IFRS have been developed instead.
A large number of explanations have been oered for
dierences in the accounting systems of dierent
countries. One model (suggested by the author) is that,
unless one country is dominated by another, a national
accounting system will be largely determined by the
predominant type of nancing and owners of companies
(and, therefore, by the predominant users of nancial
reporting). The model can be used to predict how a
country’s (or a company’s) reporting will change as its
corporate nancing changes. This is especially relevant for
countries in transition from Communism. In addition, it is
now clear that one country (and even one company) can
use more than one system simultaneously for dierent
purposes.
This report shows that each accounting system can be
classed as being one of two main types, on the basis of the
dierential strength of equity markets. For example, one
type of accounting (IFRS or US GAAP) is needed by large
listed groups for reporting to international investors; the
other type (eg French accounting) is relevant to small
private companies for reporting and tax accounting.
The International Accounting Standards Board (IASB) has
no authority to impose IFRS on companies, and the
reactions of dierent jurisdictions to IFRS dier greatly.
Some have ignored it, some have allowed it; some have
required IFRS for some purposes, whereas others have
abolished national GAAP in favour of IFRS. Very few
jurisdictions have simply imposed IFRS as issued by the
IASB, although some countries (eg Canada) do incorporate
IFRS into law without amendment. Others make
6
A classication of countries by their IFRS practices reveals
the same two-group model (‘Anglo’ versus Continental
European) as seen in earlier classications of national
practices. The number of IFRS policy changes, from 2005
to 2008, also diers between these two country groupings.
Continental companies changed their policies much more
extensively after the transition to IFRS than did Anglo ones.
No underlying economic justications could be discerned
for the continuing international dierences in IFRS policies.
Taking Germany as an example, this report shows that
small listed companies choose signicantly dierent IFRS
policies from the largest companies. The smaller
companies are more inclined to continue their traditional
practices.
This report recommends that jurisdictions should consider
adopting the IASB’s process rather than producing
national versions of IFRS. If the latter must be done, then
auditors should still be required to give an opinion on
‘IFRS as issued by the IASB’ where that is the intended
result in the jurisdiction. Developing countries with few or
no listed companies should consider carefully whether
IFRS is appropriate for them.
Analysts and others need to be alert to the opportunities
for dierent practices within IFRS. The report provides
analysts and others with a chart of typical IFRS practices
by country. The report recommends that the IASB should
eliminate most of the available options currently within
IFRS.
There are many opportunities for further research. The
report’s model of the reasons for the development of
dierent accounting methods in dierent countries could
be tested for a larger group of countries. Researchers
could also apply, to a wider group of countries, the report’s
method of classifying countries by methods of IFRS
implementation, and they could create a new classication
related to the IFRS for SMEs. There is also room for
investigation of the quality of translations of IFRS and of
the quality of enforcement.
On the matter of the choice of IFRS options by companies,
researchers could extend the study to more countries,
later years and smaller companies. There might also be
ways of studying less obvious variations in IFRS practice,
such as impairment calculations.
7
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
1. INTRODUCTION
1.1 THE DANGERS OF POOR COMMUNICATION
If most investors had stayed within national boundaries (as
was the case until the 1970s) the use of national
accounting practices would have remained unproblematic.
When stock markets became international, however,
communication went awry. One drastic solution would
have been to make all listed companies use US GAAP.
Reconciliations
That, indeed, was the solution for some purposes. Table
1.1 illustrates this. Until 2007, foreign companies listed on
US exchanges were required by the Securities and
Exchange Commission (SEC) either to present nancial
statements using US GAAP or to reconcile numerically
their specic national accounting to US GAAP.
Table 1.1 shows the summary reconciliations of Glaxo’s
shareholders’ equity (= net assets). This number is the
denominator of protability or gearing ratios. In the rst
row of the table, to take an extreme example, those ratios
were about 100 times larger under US GAAP compared
with UK GAAP.
Table 1.1: GlaxoSmithKline reconciliations of shareholders’
equity to US GAAP
UK IFRS US Dierence
£m £m £m % change
1995 91 8,168 8,876
1996 1,225 8,153 566
1997 1,843 7, 8 82 328
1998 2,702 8,007 196
1999 3,142 7, 2 30 130
2000 7, 517 44,995 +499
2001 7, 3 9 0 40,107 443
2002 6,581 34,992 432
2003 5,059 34,116 574
2004 5,925 34,042 475
2005 7,570 34,282 353
2006 9,648 34,653 259
Source: compiled from the annual reports of GlaxoSmithKline.
The reconciliations enabled Glaxo to be compared with
large US pharmaceutical companies. This improved
decision making, lowered risk for investors and lowered
the cost of capital in the case of UK companies, as other
ACCA reports show (Lee at al. 2008).
In practice, only a very small number of non-US
companies were SEC-registered, and therefore few
provided these reconciliations. Further, for 2007 and after,
the SEC has removed the reconciliation requirement, partly
in order to make US exchanges more attractive to
foreigners. This saved a lot of work for companies such as
Glaxo, but hardly improved the quality of communication:
1
it is no longer known how big the dierences are.
Why not go the whole way and impose US GAAP?
As noted above, one drastic solution to the communication
problem would be for all listed companies around the
world to use US GAAP. Counter-arguments are:
US GAAP is too complex for most companies•
US GAAP relies too much on detailed rules rather than •
on principles
US GAAP is ‘wrong’ in some areas (for example, by •
allowing last in, rst out (LIFO), and by not dening
subsidiaries in terms of actual control)
US GAAP would be politically unacceptable in many •
countries.
International standards
From the 1970s onwards, international standards were
created to solve some of these problems. National habits
are tenacious, however, and it has taken decades for
international standards to become widely used. There are
three aspects of IFRS that remain national.
Dierent countries have taken markedly dierent •
approaches to implementing IFRS.
National versions of IFRS practice have grown up, so •
that there is still no internationally uniform practice,
even where IFRS is used without amendments.
Monitoring and enforcement of IFRS practice remain •
the responsibility of national regulators.
This report focuses on the rst two items above: dierent
national implementations of IFRS and dierent national
versions of IFRS practice.
1. For example, Ashbaugh and Olsson (2002) show that US GAAP and
IFRS numbers have statistically dierent properties.
1. Introduction
8
Evidence of national or regional quirks (in bold type below)
can be seen in some splendidly oxymoronic phrases in the
report of Glaxo’s auditors on the 2009 statements:
‘we conducted our audit in accordance with International
Standards on Auditing (UK and Ireland)…’
‘the group nancial statements give a true and fair view,
in accordance with IFRSs as adopted by the European
Union…’
‘the group nancial statements have been properly
prepared in accordance with the Companies Act 2006
and Article 4 of the IAS Regulation…’
So, the auditing standards are ‘international’ but also ‘UK
and Ireland’; the accounting standards are ‘international’
but also ‘EU’, and the law requires ‘international
accounting standards’ because of an EU ‘Regulation’ but it
is British as well.
1.2 AIMS OF THIS REPORT
In order to investigate the issues above, this report:
provides an overview of some of the literature on the •
reasons for the dierences in accounting practices
extends the application of that literature to Brazil, •
Russia, India and China (BRIC)
provides a theory to explain the dierent ways in which •
countries have implemented IFRS
investigates the motives for dierent national versions •
of IFRS practice
claries the scope for such dierent versions within •
IFRS rules
investigates whether major listed companies preserved •
a national pattern of accounting on transition to IFRS in
2005
investigates whether any national patterns still persist •
by examining 2008/9 nancial reports
applies these ndings to economically important •
countries that will adopt IFRS in the future.
9
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
2. INTERNATIONAL DIFFERENCES BEFORE IFRS
2. International differences before IFRS
2.2 A SIMPLE MODEL
The academic literature
3
oers a large number of possible
reasons for international dierences in accounting. The
explanation can be dramatically simplied by suggesting a
single main factor: how companies are nanced. This
factor has two dimensions, as shown in Table 2.1.
‘Insiders’ are investors (in equity or debt) who have
long-term relationships with the company. They can
appoint board members, or may have special access to
information. Examples are: family members (even in large
listed companies, eg Fiat); banks (as big lenders or as
major equity holders, eg Daimler); and governments (eg
Renault).
By contrast, ‘outsiders’ are the millions of shareholders
who have small percentages of shares or listed debt.
Included in this group are large shareholders (eg pension
funds in the US or UK) as long as they have no privileged
access to company information (because, for example, that
would break insider-dealing laws in the country
concerned).
Examples of the nancing systems are as follows.
System I• (credit/insiders) is associated with several
continental European countries in the 19
th
and 20
th
centuries.
System II• (credit/outsiders) might be rare, but there is
a vast amount of listed debt on the New York Stock
Exchange.
System III• (equity/insiders), elements of which are seen
in Japan.
System IV• (equity/outsiders) is the full-blown
capitalism of New York and London. China has moved
towards System IV but the State (an insider) still holds
much equity.
Table 2.1: Financing systems
Dominant investors Strong credit Strong equity
Insiders I III
Outsiders II IV
3. Choi and Mueller (1992) ch.2; Radebaugh et al. (2006) ch.3; Belkaoui
(1995) ch.2; Nobes and Parker (2010) ch.1.
2.1 DEFINING SOME TERMS
One of the problems in identifying reasons for accounting
dierences, and then classifying accounting systems into
groups, is a lack of clarity about what is being examined or
classied. This report discusses accounting practices,
using ‘accounting’ to mean published nancial reporting.
In some jurisdictions, the rules of nancial reporting may
be identical or very similar to the practices, but sometimes
a company may depart from rules or may have to make
choices in the absence of rules. So, it seems more
pertinent to discuss actual practices rather than formal
rules.
Another diculty concerns the word ‘system’. It sometimes
includes entities such as regulatory agencies, whereas
other uses of the term refer to a corpus of accounting rules
or practices. This report follows the latter usage; that is, an
‘accounting system’ is a set of practices used in a
published annual report. Although this is a narrow
denition, these practices will reect the wider context in
which that accounting system operates. Yet another issue
is whether to separate disclosure from measurement
practices. It seems appropriate to include the presence or
absence of certain key disclosures (eg earnings per share,
cash ow statements) as elements of an accounting
system.
A further issue is to determine whose accounting practices
are being examined. In general, this report will discuss
listed companies, because their accounting is easy to
inspect and can benet from international harmonisation.
A related point is that all the researchers
2
classify
countries. A country can have more than one system – one
for companies with publicly traded securities and another
for small private companies.
In addition, a country’s accounting system may change
dramatically; for example as a result of economic or
political revolutions (eg China, Russia, Poland). In addition,
accounting in a country can change quite signicantly as a
result of new laws (eg in Spain from the late 1980s, as a
consequence of EU Directives). Lastly, companies in two
countries (eg the UK and Ireland) can use extremely
similar accounting practices (ie perhaps the same
‘system’).
The detailed elements of accounting practice can dier so
much from one company to another that the number of
dierent sets of practices is eectively innite. A certain
degree of variation among company practices may be
allowed, however, without having to abandon the idea that
the companies are all using the same system.
2. Such as: Nair and Frank (1980); Nobes (1983); Doupnik and Salter
(1993).
10
There are two caveats to this.
Countries might have more than one of the four •
systems; for example, System IV (equity/outsiders) for
big companies and System I (credit/insiders) for small
ones. This report concentrates on the bulk of a
country’s economic activity; for the US and the UK, for
example, that means listed companies.
Countries change over time, but accounting might •
change more slowly and will be inuenced by the past.
Some simple measures of equity market size are given in
Table 2.2. Listed companies and equity markets are
obviously much less important in Italy and Germany than
they are in the UK and the US.
The starkest contrast is between System I and System IV.
Concentrating on these, the following are relevant points.
In a country (or in a sector of a country) dominated by •
equity/outsiders (System IV), there will be a demand
for detailed, audited, frequent, published accounting
information.
The conceptual frameworks of the IASB and of •
standard setters in Australia, Canada, the UK and the
US state that the purpose of nancial reporting is
primarily to enable investors to make economic
decisions. This is clearly a System IV orientation.
Table 2.2: The strength of equity markets, 2009
Domestic listed
companies per
million of
population
Equity market
capitalisation as %
of GDP
Italy 5.1 0.19
Germany 9.0 0.28
United States 18.0 0.81
United Kingdom 39.3 0.55
Source: Nobes and Parker (2010: 33)
In a country (or in a sector of a country) dominated by •
credit/insiders (System I), there will be no such
demand for investor-oriented reporting. For such
countries, in the absence of an outsider purpose,
accounting will serve its traditional purposes:
calculating prudently distributable prot and
calculating taxable income. System I purposes are legal
in nature and relate to single entities, therefore the
detail of accounting tends to be controlled by the State
and will concentrate on unconsolidated statements. By
contrast, in equity/outsider (System IV) countries, the
detail of accounting will be controlled by bodies
connected to accountants or stock markets.
The two classes of accounting that result have the features
listed in Table 2.3. These features are found in the
following cases. All the features of Class A in Table 2.3
were found in the national practices of Australia, the UK
and the US. All the features of Class B are found in the
unconsolidated statements of companies (even large ones)
prepared under the national accounting rules of France,
Germany or Italy.
Table 2.3: Examples of features of the two accounting
classes
Feature Class A Class B
Depreciation and
pension expenses
Accounting practice
diers from tax rules
Accounting practice
follows tax rules
Long-term
contracts
Percentage of
completion method
Completed contract
method
Unsettled currency
gains
Taken to income Deferred or not
recognised
Legal reserves Not found Required
Income statement
format
Expenses recorded
by function (eg cost
of sales)
Expenses recorded
by nature (eg total
wages)
Cash ow
statements
Required Not required, found
only sporadically
Earnings per share
disclosure
Required by listed
companies
Not required, found
only sporadically
11
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
2. INTERNATIONAL DIFFERENCES BEFORE IFRS
2.3 WHY OTHER FACTORS ARE LESS USEFUL
There are various explanations as to why other important
factors are less useful in explaining the main A/B split
between the classes of accounting.
International dierences in tax are of limited relevance in
causing the A/B split of Table 2.3 because Class A is
supposed to be unaected by tax issues. There are some
exceptions, such as the use of LIFO in the US for reporting
purposes, in order to be allowed to use LIFO for tax.
System IV nancing causes Class A accounting, which is
not designed to serve tax purposes. So, tax itself does not
explain why a country is in Class A or Class B. Of course,
within a set of countries that use Class B accounting,
dierences in tax are likely to be a major cause of
dierences in accounting.
International dierences in legal systems are also of only
limited relevance in causing the A/B split. Class A seems
to be associated with common law countries, and Class B
with Roman (codied) law countries, but there is not a
perfect correlation. In addition, IFRS was adopted in some
Roman law countries in the 1990s for the consolidated
statements of listed companies. The EU (a very Roman law
organisation) has adopted IFRS for this purpose.
Nonetheless, the national legal system still aects
monitoring and enforcement of accounting.
2.4 COLONIAL INFLUENCE
Colonial inheritance is probably the major explanatory
factor for the general system of nancial reporting in many
countries outside Europe. For example, it is easy to predict
how accounting will work in Gambia (a former British
colony) compared with neighbouring Senegal (a former
French colony). The same general point applies to
predicting how accounting will work in Singapore or New
Zealand, both of which must be expected to have British-
inuenced accounting. Colonial inheritance extends to
legal systems and to other background and cultural factors,
and not just to direct imports of accounting. Substantial
capital investment from another country may also lead to
accountants and accounting migrating with the capital.
Another related inuence on accounting is invasions, which
may have major eects, as is the case with Japanese,
4
French,
5
and German
6
accounting. When the invader
departs, however, any foreign accounting measures can be
gradually removed if they do not suit the country: Japan
closed down its Securities and Exchange Commission
4. Japan’s SEC, its structure of Securities Laws and its stock market owed
much to US inuence during the occupation following the Second World War.
5. The distinguishing feature of French accounting, the plan comptable,
was rst adopted when France was under German occupation.
6. The German accounting plan, though copied in France, was abolished
by the occupying Western powers after the Second World War. A version
survived in communist East Germany until reunication.
when the Americans left, whereas France retained its
German-inspired accounting plan in order to aid
reconstruction after the Second World War.
2.5 EMPIRICAL EVIDENCE
The two-class model outlined in section 2.2 has been
supported in the literature when researchers have
examined accounting practices.
7
It can also be seen in
measures of the dierences between various national
GAAPs and IFRS.
8
For example, in 2001, there were far
fewer dierences between UK GAAP and IFRS than there
were between French or German GAAP and IFRS.
Other empirical studies look at the eects of moving from
national GAAP to IFRS. Some of these look at ‘value
relevance’, ie whether IFRS accounting numbers are more
closely related than national GAAP to share price
movements. The evidence
9
suggests that there is not much
dierence between US GAAP and IFRS for this purpose, but
that IFRS is more value relevant than, for example, German
GAAP. This is consistent with the model proposed here.
2.6 THE MODEL DEVELOPED
Section 2.2’s simple model of the development of
accounting based on corporate nancing can now be
elaborated. This fuller model consists of a number of
linked ideas which will be expressed as propositions. Part
of the model can be shown in simplied form as in Figure
2.1, which amends a diagram suggested by Doupnik and
Salter (1995). The variables have been introduced in the
text above, but now need to be marshalled.
The rst variable is a country’s type of legal and
institutional culture, and the second is the strength of its
equity-outsider nancing. It can be assumed that some
cultures develop strong equity-outsider markets and
others do not. This is an issue for economic historians and
is not examined in detail in this report. As discussed
earlier, some countries have strong indigenous systems,
whereas others have imported systems that are still
dominated, or at least heavily inuenced, from outside.
This dichotomy will be expressed by using the labels SSC
(for self-sucient nancial and legal culture) and DC (for
dominated culture). For example, a DC country whose
colonial inheritance came from a country with one type of
nancial culture would tend to have that same nancial
culture. This variable could be measured in various ways,
for example by the number of decades since one country
gained political independence from another. Many
developed countries are SSC and many developing
countries are DC, but there are exceptions.
7. Doupnik and Salter (1993).
8. Ding et al. (2007).
9. The evidence is summarised by S.J. McLeay in Section 20.5 of C.W.
Nobes and R.H. Parker, Comparative International Accounting, Prentice Hall,
2010.
12
As noted above, the second variable is the strength of
equity/outsider nancing. For most companies in any
country (insider companies), a controlling stake is in the
hands of a small number of owners. For a comparatively
few companies (outsider companies), control is widely
spread among many ‘outsider’ equity-holders. Countries
with strong equity-outsider systems generally have a large
number of outsider companies which may generate most
of a country’s GNP, but some such companies may also
exist in other countries with dierent systems.
The nal variable is the type of nancial reporting system
(or, in short, ‘accounting system’), introduced earlier as
Class A or Class B. As suggested above, this is the key
driver of the type of accounting that will be needed.
The ideas which link these variables can now be brought
together. It is worth repeating the point that more than one
accounting system can be used in any particular country
at any one time, or over time. The model can be expressed
in terms of ve propositions (P), which are then explained
and illustrated.
P1: The dominant accounting system in an SSC country
with a strong equity-outsider system is Class A.
P2: The dominant accounting system in an SSC country
with a weak (or no) equity-outsider system is Class B.
P3: As a country establishes a strong equity-outsider
market, its accounting system moves from Class B
to Class A.
P4: Outsider companies in countries with weak equity-
outsider markets will move to Class A accounting.
P5: A DC country has an accounting system imported
from the dominating country, irrespective of the
strength of the DC country’s equity-outsider system.
The analysis here relates to self-sucient countries (P1
and P2), as illustrated in Figure 2.2. For these countries, it
is suggested that a country’s nancing system will have
resulted from its particular type of culture. As suggested
earlier, for the purposes of this report, it is not necessary
to go back that far in the chain in any detail. Let us say
that ‘Type 1’ culture produces strong equity-outsider
nancing but ‘Type 2’ culture does not.
Financial and legal
culture, including
institutional
structures
Strength of equity
outsider nancing
Class of
accounting
Figure 2.1: Simplified model of reasons for international accounting differences
Figure 2.2: Application of Figure 2.1 to culturally self-sufficient countries
Country with culture
Type 1
Strong equity-
outsider nancing
(System IV)
Class A
Accounting for
outside shareholders
Country with culture
Type 2
Creditor-insider
nancing (System I)
Class B
Accounting for tax
and creditors
13
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
2. INTERNATIONAL DIFFERENCES BEFORE IFRS
The class into which the predominant accounting system
falls will depend upon the strength of the equity-outsider
market (or on its strength in the past, if there is inertia).
Strong equity-outsider systems will lead to Class A
accounting (containing the features in Table 2.3 on page
10) whereas others will lead to Class B accounting. As
explained earlier, the term ‘predominant accounting
system’ refers to the type of system used by enterprises
representing the majority of a country’s economic activity.
For example, small unlisted enterprises in strong equity
market countries might not practise Class A accounting or
indeed any nancial reporting at all.
Proposition 3 is that, if a country with a traditionally weak
equity market gradually develops a strong equity-outsider
system, a change of accounting towards Class A will follow.
Also (P4), in a country with weak equity-outsider markets,
there may be some ‘outsider companies’ (as dened
earlier). Commercial pressure will lead these companies
towards Class A accounting, even if the dominant system
in the country is Class B. For such companies, there will be
rewards in terms of lower cost of capital
10
from the
production of Class A statements, particularly if there is an
international market in the company’s shares. If legal
constraints hinder movement towards Class A accounting,
then the company can use extra disclosures or
supplementary statements.
10. It is argued that equity investors and lenders will be persuaded to
provide funds at lower returns to companies using more accepted, familiar
and transparent nancial reporting (Botosan 1997).
Figure 2.3 shows some aspects of these ideas. The
continuous arrows are those from Figure 2.2. Arrow (b)
relates to Proposition 3, and Arrow (d) Proposition 4.
Arrows (a) and (c) concern Proposition 5. Some
illustrations of these relationships are given below.
Arrow (a): New Zealand is a DC country which has •
imported British culture and institutions wholesale,
including a strong equity-outsider system and Class A
accounting. Whether Class A accounting in this case
results from the equity market or from direct cultural
pressure is not important to the model; it probably
arises from both.
Arrow (b): China is a country that had no equity-•
outsider tradition but has moved towards such a
system. Class A accounting has followed, for listed
companies.
Arrow (c): Malawi is a DC country with very weak equity •
markets but where the accountancy profession has
adopted Class A accounting, consistent with its colonial
inheritance from the UK.
Arrow (d): the Deutsche Bank, Bayer and Nestlé are •
companies from countries with traditionally weak
equity markets. These companies were interested in
world equity-outsider markets, so they adopted Class A
accounting (IFRS) for their consolidated statements in
the 1990s.
Country with culture
Type 1
Strong
equity-outsider
nancing
Class A
accounting for
outside shareholders
Country with culture
Type 2
Weak
equity-outsider
nancing
Class B
accounting for tax
and creditors
Figure 2.3: A proposed model of reasons for international accounting differences
(a)
(d)
(b) (c)
14
3.1 INTRODUCTION
Chapter 2 proposed a two-class model of accounting
systems. As recorded there, many researchers have put
countries into groups, but that is no longer appropriate
because many countries have dierent accounting systems
for dierent types of nancial reporting.
Figure 3.1 suggests an outline classication of accounting
systems. On the left, are Class A systems. One family of
such systems could be called ‘Anglo’. Many people do not
like this French-inspired term, but it is a useful short-hand
for countries with predominantly English law, English
language and British cultural roots.
It is perhaps also controversial to call IFRS ‘Anglo-Saxon’
but it is surely obvious that the IASB’s very nature (part of
a private-sector trust), location, language, style of output
and conceptual framework place it squarely in that group
rather than its being Continental European or South
American, for example.
Many Class B systems are Continental European or have
their roots there. For example, Japanese and South
American accounting systems have mostly French or
German roots (despite Iberian colonial inuence in South
America).
3. Grouping countries and accounting systems
Figure 3.1: An outline classification
Accounting systems
Strong equity-outsider nancing
Class A
Weak equity-outsider nancing
Class B
Anglo-Saxon
Standard Italian
1. Italian
US GAAP
1. US SEC registered
Standard
1. German single*
IFRS GAAP
1. Australian
2. EU listed
Standard
1. French
UK GAAP
1. Some UK
2. Some Irish
* That is, the unconsolidated statements of individual legal entities.
15
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
3. GROUPING COUNTRIES AND ACCOUNTING SYSTEMS
3.2 EUROPE
Later in this report, it will be useful to have a two-group
classication of European countries. Using the author’s
own descriptions of accounting systems (eg Nobes 1997),
Table 3.1 classies some European Union national
accounting systems before the arrival of IFRS.
Table 3.1: A two-group accounting classification of some
European countries
Class A
(strong equity, commercially
driven)
Class B
(weak equity, government
driven, tax-dominated)
Cyprus Austria
Denmark Belgium
Ireland Finland
Malta France
Netherlands Germany
Norway Greece
UK Italy
Luxembourg
Portugal
Spain
Sweden
Switzerland
Note: This table covers the EU (plus Norway and Switzerland)
before the expansion of the EU to include former Communist
countries that had no ‘nancial reporting’.
3.3 SOME OTHER COUNTRIES
It would also be easy to classify the pre-IFRS accounting of
several other countries that are neither in Figure 3.1 nor
Table 3.1. For example:
South Africa, Singapore and Hong Kong had Class A •
accounting because of UK inuence; and it suited their
important equity markets.
Former British colonies in Africa and the Caribbean •
had accounting based on former British Companies
Acts and standards, even if they had very small equity
markets.
Former or present French colonies have state-•
controlled, tax-relevant accounting governed by a
version of the French accounting plan (plan comptable
général).
Special consideration is given to the BRIC countries (Brazil,
Russia, India and China) in Chapter 5.
16
4.1 STANDARDISATION
Chapter 1 introduced the idea that standardisation might
be helpful for investors who act globally; the reduction of
international accounting dierences might also be an
advantage to multinational companies. Standardisation of
the rules of nancial reporting involves regulators of
dierent types: rule makers, rule imposers and rule
enforcers. It is possible for all three tasks to be carried out
by the same agency (eg various branches of the French
State for French GAAP). Table 4.1 gives some examples.
Standardisation of the rules can be called de jure
standardisation. This is of limited use unless it results in
standardisation of practices (de facto). The rest of this
report concentrates on de facto harmonisation,
particularly as driven by the IASB. As illustrated in Table
4.1, the IASB has no authority to impose IFRS on
companies. Regulators of various countries have reacted in
many dierent ways to the availability of IFRS. This chapter
investigates this.
Table 4.1: Regulators
Main rule
maker Imposer Enforcer
French GAAP State State State
US GAAP FASB* SEC SEC
UK GAAP ASB* Companies Act FRRP*, Court
IFRS in UK IASB* EU Regulation FRRP*, Court
* = private sector body
4.2 A BEWILDERING VARIETY OF METHODS OF
IMPLEMENTATION
The IASB (2010) suggests that ‘more than 100 countries
now require or permit the use of IFRSs or are converging
with [them]’. This gives a misleading impression of the
prevalence of IFRS, and hides a bewildering array of
responses, some of which are described below.
1. Adopting the IFRS process
This is the purest form of IFRS implementation, where the
regulations in a jurisdiction require companies to use IFRS
as issued by the IASB, whatever these may be at the time.
Very few countries have done this, but Israel is one. Even
so, this might be done for only some companies (eg listed)
or for only some reporting (eg consolidated). For example,
South Africa requires listed companies to follow IFRS, but
others to follow national GAAP based on IFRS.
2. Inserting IFRS (unchanged in substance) into law
This is another way of implementing IFRS. It might have
been the country’s traditional way of imposing domestic
accounting standards. Compared with method 1, this
involves delays in making IFRS available to companies, but
it need not mean dierent dates of compulsory application
from the dates of IFRS as issued by the IASB. Canada
(from 2011) and South Africa (for unlisted companies)
have taken this route. Another possible reason for this
response may be because the standards have to be
translated from English into a national language (eg
Canadian French).
3. Endorsing IFRS
This is the response of the EU. It involves detailed scrutiny
of all IFRS output, standard by standard, amendment by
amendment. In the case of the EU, many bodies are
involved, and the process can take well over one year,
running the risk that even the IASB’s compulsory
application dates will be missed. A worse problem is that
whole standards or parts of standards might not be
endorsed at all. Famously, part of IAS 39 (on the
recognition and measurement of nancial instruments)
has been ‘carved out’ (ie parts have been removed).
Another problem is that IFRS 9 (designed eventually to
replace IAS 39), issued by the IASB in 2009, can be used
in South Africa or Switzerland (from December 2009 year
ends) but not in the EU even for 2011, as the EU has not
started the process of endorsement. The resulting package
of standards cannot be called IFRS: it is ‘IFRS as adopted
by the EU’. As with any of the other methods of
implementing IFRS, not all companies need be covered.
For example, the EU Regulation that imposes EU-IFRS for
consolidated reporting by listed companies allows member
tates to impose, allow or ban IFRS for other purposes.
4. How countries react to IFRS
17
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
4. HOW COUNTRIES REACT TO IFRS
4. Fully converging with IFRS (and intending compliance)
This method of implementation is used in Australia. The
Australian Accounting Standards Board takes the IASB’s
output and amends it in various ways: giving it an
Australian number, making textual changes (eg in relation
to public sector entities), banning early adoption, and
deleting some options (between 2005 and 2007). The
result is clearly not ‘IFRS as issued by the IASB’ but it is
still designed to lead to full compliance with IFRS.
5. Adapting IFRS
A country can take IFRS as a starting point but then make
various changes. China has done this. For 2007 onwards,
the consolidated statements of Chinese listed companies
must use a set of standards based on IFRS. Nonetheless,
there are several clear dierences. For example, unlike the
rule under IAS 36, impairments must never be reversed.
Another approach is that of Venezuela, which adopted IFRS
en bloc in 2004 but had not (by mid-2011) adopted all the
subsequent changes to IFRS.
6. Allowing IFRS
A country can permit companies to use IFRS instead of
national GAAP. For example, Switzerland allows certain
options for the preparation of consolidated statements by
listed companies, one of which is IFRS as issued by the
IASB.
Figure 4.1 records these six approaches. In the bottom
part of the gure, another point is made: how likely it is
that companies in the various countries will comply with
IFRS as issued by the IASB. The approaches of South
Africa, Israel, Canada and Australia should lead to
companies’ compliance with IFRS as issued by the IASB;
such compliance is possible for EU companies. In 2011, for
example, it is merely necessary for a company to deny
itself the possibilities for extra hedge accounting allowed
by the EU’s version of IAS 39. It can then comply with IFRS
as issued by the IASB as well as with EU-endorsed IFRS.
Most EU companies achieve this, but few point it out. For
Swiss listed companies, compliance with IFRS is the norm.
The likely approaches of countries that are yet to
implement IFRS (eg India and the US) are considered in
section 4.5, after dealing with the issue of how widely IFRS
is applied within a country, and in particular, whether or
not IFRS is restricted to consolidated statements.
Implementing IFRS
Standard-by-standard Optional Not fully converged
Adopting the
process
UnlikelyPossibleYes
Company compliance with IFRS
as issued by the IASB
As issued
by IASB
Fully converged
with IFRS
As issued
by IASB, but with
deletions
Israel, South Africa
Canada
Australia SwitzerlandEU China,
Venezuela
Figure 4.1: Methods of Implementing IFRS (listed companies)
18
It is likely that nearly all the consolidated statements of EU
listed companies that comply with EU-IFRS also comply
with IASB-IFRS because, at the time of writing, the only
practical dierences between the two relate to:
(i) the IAS 39 ‘carve-out’, which has been used by only
a few nancial institutions, and
(ii) these companies’ inability to adopt certain new or
amended standards (eg IFRS 9).
So, although their nancial statements may in fact comply
with IASB-IFRS, EU companies are generally not asking
their auditors to signal that they do comply with it.
Table 4.2 shows some information about the 17 UK
companies that had dual audit reports. One obvious
reason for needing an audit report on IASB-IFRS (at least
on documents sent to the SEC) is that the SEC accepts
IASB-IFRS but not EU-IFRS from foreign registrants. Table
4.2 (bottom row) shows that 14 of the 17 companies were
fully SEC-registered or were otherwise treated as foreign
private issuers (FPI) in the United States. Interestingly, the
other obvious explanatory factor was that most of the dual
reports were provided by Deloitte; the rm stated
13
that it
encouraged clients to have such reports.
13. Martyn Jones (UK audit technical partner) reports that they had been
‘pushing it strongly…from the beginning’ (correspondence of 15 January
2008).
4.3 WHAT THE AUDITORS SAY
In Figure 4.1, companies on the far left (in Israel or South
Africa) have audit reports referring to IFRS. Australian
audit reports in 2005/7 still referred only to Australian
accounting standards, however, even though the nancial
statements complied with IFRS. This seemed to miss the
point of 40 years of eort on international standardisation:
helping users (especially those from other countries) to be
condent about comparing the nancial reports of
dierent companies. Since 2007/8, however, Australian
(and New Zealand) auditing standards require reference to
IFRS as well as to domestic accounting standards.
In the EU, auditors refer to ‘IFRS as adopted by the
European Union’, which is a warning that there might be
dierences from ‘IFRS as issued by the IASB’. The author
has investigated
11
the audit reports of the companies in
the main stock market indices
12
of ve countries in
2005/6, the rst year of IFRS adoption. The ve countries
(Australia, France, Germany, Spain and the UK) had the
largest stock markets that used IFRS, which amounted to
255 companies. At that time, all the Australian audit
reports referred to Australian standards only, not to
IASB-IFRS as well; whereas all the French and Spanish
audit reports only referred to EU-IFRS. By contrast, 22% of
the German DAX companies and 17% of the UK FTSE
companies had dual audit reports (ie, where the auditors
reported separately on compliance with IFRS).
11. Also published in Nobes and Ze (2008).
12. Respectively, the ASX 50, CAC 40, DAX 30, IBEX 35, FTSE 100 as at
June 2007.
Table 4.2: UK Dual Audit Reports in 2005/6
Company Total SEC registered Other FPI Not FPI
Deloitte & Touche 12 5 (2 with ‘US Opinion’) 5 2
Ernst & Young 3 1 1 1
KPMG 0 0 0 0
PricewaterhouseCoopers 2 1 1 0
Total 17 7 7 3
19
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
4. HOW COUNTRIES REACT TO IFRS
4.4 CONFINING IFRS TO CONSOLIDATED STATEMENTS
A proposition
A major proposition can now be made, based on Chapters
2 and 3: strong equity/outsider countries (System IV
countries that traditionally used Class A accounting) will
require or allow IFRS (or IFRS for SMEs, see section 4.6)
for unconsolidated statements; other countries will not.
The logic behind this proposition is as follows.
(i) Given that IFRS is a sort of Class A accounting, there
is little point in a System IV country maintaining two
dierent Class A accounting systems. So, once IFRS
has been adopted for any purpose, it will lead to the
immediate or gradual elimination of the national
system.
(ii) In Class B countries, national accounting rules had
a dierent purpose from IFRS: that is, to make tax
and distribution calculations rather than giving
useful information to investors. So, when IFRS is
adopted for consolidated statements for the latter
purpose, national rules are still needed for
unconsolidated statements for the former purpose.
Circumstantial evidence in favour of the above is that
Australia and Canada have not maintained national rules
alongside IFRS (even for unconsolidated statements),
whereas France and Germany have. A larger case study, of
17 European countries, is given below.
It is worth adding a coda to this discussion. The reason for
a brake on the adoption of IFRS for unconsolidated
statements or unlisted companies in Class A countries is
that the investor purpose is not so obvious for such
reporting; a related point is that IFRS might demand too
many costly disclosures for that reporting. The solution is
for such countries to adopt IFRS for SMEs (IASB 2009) for
some purposes. This is being done in South Africa and
(approximately) in the UK, for example, and helps to bring
about the demise of national rules predicted above.
A case study
We can now use 17 European countries (most
14
of the EU
before expansion to include former Communist countries,
plus Norway) to test the above proposition. Table 3.1 put
those countries into two groups by style of pre-IFRS
accounting: Classes A and B. The prediction is that Class A
countries will require or allow IFRS for unconsolidated
statements, and Class B countries will not. The facts are
available on an EU website (European Commission 2010).
They are expressed in reverse in Table 4.3; that is, whether
national rules continue to be required for unconsolidated
statements.
14. This excludes Finland and Greece, for which the position on IFRS is
complicated because some types of company are allowed to use IFRS for
unconsolidated statements.
Table 4.3: Whether European countries mandate national
rules for unconsolidated accounting
Not required Required
Cyprus Austria
Denmark Belgium
Ireland France
Italy Germany*
Luxembourg Portugal**
Malta Spain
Netherlands Sweden
Norway Switzerland
UK
* Required for tax and distribution accounting but, for large
companies, not for publication.
** Except companies included in an IFRS consolidation.
Source: European Commission (2010).
Inspection reveals a strong association between the
left-hand sides of Tables 3.1 and 4.3. To be more formal,
we can set up a null hypothesis:
H
01
The classication of countries in Table 4.3 is only
associated by chance with the classication in Table 3.1.
A chi-square test enables one to reject the null hypothesis
at more than 99% signicance. So, the proposition at the
start of this section can be accepted. Indeed, the only
countries that are not correctly classied by using Table
3.1 are Italy and Luxembourg. One explanation as to why
Italy granted permission to use IFRS is that Italy likes to be
seen to be modern and international and that, in practice,
companies will not volunteer to use IFRS for their
unconsolidated statements because they would then have
to produce a dierent set for tax purposes. Nevertheless,
in principle tax and nancial reporting can now be
separate in Italy, which is a major legal change.
Luxembourg has a long history of extending to companies
any choices that are available within EU rules.
20
4.5 IFRS ADOPTIONS OF THE FUTURE
Several important countries have not yet adopted IFRS.
Some of these are considered now.
The United States has accepted IFRS statements from
foreign registrants since 2007. In a consultation of 2008,
the Securities and Exchange Commission (SEC) proposes
to require IFRS from US registrants, starting with the
largest companies from 2014. At the time of writing, it is
unclear whether this proposal will be carried through but
the general trend is in that direction.
An important question about the US is which
implementation method (of those in section 4.2) might be
chosen. The SEC currently uses the rst approach
(adopting the process) for US GAAP. That is, the SEC
requires the use of the standards produced by the
Financial Accounting Standards Board. It could take the
analogous approach to the IASB. The SEC’s writ runs only
for listed companies, and it requires consolidated
statements only. Section 4.6 notes how the IASB might be
relevant in the US beyond that.
In Japan, convergence with IFRS has been proceeding
slowly for at least a decade. At the end of 2009, it was
announced that certain Japanese listed companies could
choose to use IFRS instead of Japanese GAAP for periods
ending 31 March 2010. The present option of using US
GAAP is removed from 2016. In 2012, a decision is to be
taken about whether to require IFRS from 2016.
Of the ‘BRIC’ countries, China was included in section 4.2.
Brazil and Russia are shown by the IASB (2010) as ‘require
or permit IFRSs’. In Brazil, IFRS is required from 2010 for
listed companies and any other nancial institutions. In
Russia, the picture is much less clear; for many years, a
law has been under consideration that would require the
use of IFRS for consolidated statements. It has not, so far,
been approved by the Duma (by the time of writing, in the
middle of 2011). The IAS Plus website (Deloitte 2011)
shows Russia as ‘IFRSs not permitted’. It seems unlikely
that Russia will successfully adopt IFRS in the near future.
India is requiring the use of ‘notied Indian standards that
have been converged with IFRS’ for large listed (and some
other large) companies from 2011. This will be extended to
all listed companies by 2014.
4.6 IFRS FOR SMEs
Although this report is largely concerned with full-scale
adoption of IFRS, it is important to note the arrival in 2009
of the IASB’s IFRS for SMEs. In terms of the number of
entities applying it, this document will no doubt far exceed
the reach of IFRS.
IFRS for SMEs has already been adopted (unchanged) in
South Africa. The UK’s Accounting Standards Board has
proposed it as the basis of a new regime to replace UK
GAAP from 2014. It could also be used for unlisted
companies in the US, where there are at present no
reporting requirements for such companies.
The issue discussed in section 4.2 (the variety of
implementation methods) is also relevant to SME-IFRS. For
example, SME-IFRS could be adopted by at or inserted
into law or adapted into law. Also, using the arguments of
section 4.4, we can predict that IFRS for SMEs will have
greater application in Class A countries than in Class B
countries.
21
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
5. DIFFERENT NATIONAL PATTERNS OF IFRS PRACTICE
5.1 INTRODUCTION
Up to now, we have been looking at how countries can
implement IFRS dierently into their regulatory systems.
For the next four chapters of this report, we turn to a
dierent aspect of IFRS: do the IFRS practices of
companies dier along national lines? That is, assuming
that IFRS has been implemented in a series of countries,
do companies use IFRS dierently in dierent countries?
This chapter investigates whether there might be motives
for the existence of such national patterns of IFRS practice,
and then whether IFRS contains opportunities for such
motives to be exercised. Chapter 6 examines whether the
motives and opportunities actually led to observable
national patterns on the transition to IFRS in some major
countries in 2005/6. Chapter 7 looks at whether any
national patterns have survived after several years of IFRS
practice. Chapter 8 asks if the groupings of countries in
Chapter 3 are relevant for this new type of international
dierence. For example, are Australian and UK IFRS
practices similar, at least compared with French or Spanish
IFRS practices?
5.2 MOTIVES FOR NATIONAL PATTERNS OF IFRS
PRACTICE
The obvious place to start looking for motives for dierent
national patterns of IFRS practice is in the literature about
why pre-IFRS national accounting systems were dierent.
That was summarised in Chapter 2 of this report, which
particularly focused on nancing systems, legal systems
and tax systems. We can ask now whether these factors
might be relevant for IFRS practice. Let us take Germany
and the UK as examples of dierent approaches to
accounting, as suggested by the classications in Chapter 3.
In Chapter 2, Germany was seen to have a weak equity
market compared with the UK or the US. There have been
changes over time, but the contrast is still clear. If many
German listed companies are still dominated by ‘insider’
nance, that might still aect their attitudes to accounting,
eg they might see no need to try to over-state earnings or
to make some types of disclosure.
Legal systems were also divided into two types in Chapter 2:
Roman codied law and common law. This is still
potentially relevant because nancial reporting, even
‘international’ reporting, is carried out under national laws.
Also, the quality of nancial reporting is monitored and
enforced by national agencies. Some national laws tinker
with IFRS, and some national agencies do a better job of
monitoring and enforcement than others.
The greater dominance of tax over nancial reporting
under German (compared with the UK’s) domestic rules
was also noted in Chapter 2. At rst sight, this should not
aect the consolidated IFRS reporting of German groups of
companies. Nonetheless, tax-driven choices in German
unconsolidated statements might ow through to IFRS
consolidated statements. For example, suppose that
German companies under German GAAP tend to choose
weighted average cost (AVCO) for inventory valuation
because tax law restricts the use of LIFO and FIFO.
15
It
would then be likely that AVCO will ow through to the
IFRS consolidated statements, given that it is acceptable
under IAS 2.
In addition to company motivations, there might be
government motivations. In some cases, the latter might
reect the former. For example, in late 2008, the French
government publicly demanded that an option should be
added into IAS 39 to allow reclassication of nancial
assets out of ‘trading’. This presumably reected the
desire of French nancial institutions, among others. By
contrast, the Spanish central bank’s interpretation of IAS
39 on the impairment of receivables relates to the
prudential regulation of banks.
5.3 OPPORTUNITIES FOR NATIONAL PATTERNS OF IFRS
PRACTICE
There are many opportunities for dierent IFRS practice
among companies, including:
dierent versions of IFRS (eg Australia and the EU as •
discussed in section 4.2)
dierent translations of IFRS•
transitional issues•
imperfect enforcement•
gaps in IFRS•
overt options in IFRS (eg FIFO and weighted average in •
IAS 2)
covert options in IFRS•
estimations in IFRS.•
These will now be examined in turn. The rst four are
related to a company’s jurisdiction. The other four involve
choices and estimations, which could tend to be made
dierently depending on the company’s jurisdiction.
15. Last in, rst out (LIFO) and rst in, rst out (FIFO).
5. Different national patterns of IFRS practice
22
Different versions of IFRS
As explained in section 4.2, EU-endorsed IFRS contains
more exibility on hedge accounting than does the IASB’s
IAS 39. As another example noted earlier, the Venezuelan
version of IFRS does not contain the dozens of
amendments to IFRS of the last six years. So, there are
dierent versions of IFRS in dierent countries, and
therefore dierent practices can result.
Different translations of IFRS
It is essential for IFRS to be translated into several
languages. There are, for example, two ocial IASB
translations into French (one EU and one Canadian). Often,
meanings can be lost in translation. Sometimes, there are
clear errors, of which three examples can be given.
Cash ow statements are required by IAS 7, reconciling •
to ‘cash and cash equivalents’. The term ‘cash
equivalents’ is dened in paragraphs 6 to 9 of IAS 7,
including: ‘An investment normally qualies as a cash
equivalent only when it has a short maturity of, say,
three months…’. This is an attempt to avoid writing a
rule, as opposed to establishing a principle. The
Portuguese translation of IAS 7 omits the word ‘say’.
This makes the standard easier to use, but does not
translate it accurately. As a result, it will be more
dicult in Portugal than in Spain to argue successfully
that an investment with a maturity of just over three
months is a cash equivalent.
IAS 41 (para. 34) requires that an unconditional •
government grant related to a biological asset be
recognised as income when the grant becomes
‘receivable’. The Norwegian version translates this as
mottas, which means ‘received’. A grant could be
receivable many years before it is received.
The German translation•
16
of IAS 19 requires the
discount rate for pension liabilities to be set by
reference to Industrieanleihen (industrial bonds),
whereas the original refers to corporate bonds (para.
78), which is a wider category.
Such problems could lead to dierences in IFRS practice.
Transitional issues
On transition to IFRS, companies are allowed (by IFRS 1) to
retain several gures from their previous balance sheets.
For example, most UK companies had the following
goodwill treatment in 2003 under UK GAAP:
goodwill arising before 1998 was written o against •
reserves on acquisition, and
goodwill purchased after 1998 was being amortised •
over 20 years.
16. This refers to the EU translation and (until 2011) the IASB’s
translation. In 2011, the IASB’s translation was corrected.
The resulting meaningless total became the opening
balance of goodwill on 1 January 2004 for transition to IFRS
(for a company with a 31 December year end). Companies
from other countries had various opening gures that were
also meaningless for dierent reasons. These country-
based IFRS dierences will survive for many years.
Imperfect enforcement
As noted briey in section 5.2, monitoring and
enforcement of IFRS remains a national matter. In some
countries, there are powerful governmental regulators, at
least for listed companies. An example is the Autorité des
Marchés Financiers in France. In other countries, there is a
private-sector body, such as the UK’s Financial Reporting
Review Panel (FRRP), which can take companies to court
for defective accounting. In countries that have no eective
regulator, audited nancial statements that assert
compliance with IFRS might not in fact comply.
Gaps in IFRS
We now turn to four more opportunities for companies to
adopt dierent IFRS practice. These are not intrinsically
national like those above but they could lead to national
biases in the choices made by companies.
The rst of these is gaps in IFRS. The most obvious gaps
relate to accounting for insurance contracts and for
mineral extraction (including oil and gas). Although these
topics are addressed by IFRS 4 and IFRS 6, respectively,
those standards place few constraints on companies. The
result is that, generally, pre-IFRS practice continues. So,
Australian insurance companies continue with Australian
practices, and Spanish companies with Spanish practices.
Overt options for IFRS
Throughout the nearly 30-year life of the International
Accounting Standards Committee (IASC), standards
needed a 75% majority of votes in order to be passed by
its Board. One result was the inclusion of many national
options. The IASC started to remove these, notably in an
‘improvements’ project completed in 1993. The IASB has
been removing more options, though creating a few new
ones.
17
Table 5.1 lists all the options available
18
in 2010. The
motives discussed in section 5.2 might lead companies to
make choices among these along national lines. For
example, German law requires investment properties to be
measured at cost (or lower), whereas UK GAAP (SSAP 19)
requires them to be measured at a current market value.
IAS 40 (para. 30) allows companies an enterprise-wide
choice of cost or fair value. We can guess, then, that when
moving from national practice to IFRS, German companies
would continue with cost whereas UK companies would
choose fair value. Whether such guesses turn out to be
correct is investigated in Chapters 6 and 7.
17. For example, there is a choice for the calculation of goodwill in the
context of non-controlling interests (IFRS 3, para. 19, issued in 2008).
18. According to the author’s analysis.
23
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
5. DIFFERENT NATIONAL PATTERNS OF IFRS PRACTICE
Table 5.1: Examples of overt options in IFRS, 2010
IAS 1 No format requirements for statements of nancial
position or comprehensive income (paras 79 and 82).
IAS 2 Either FIFO or weighted average for the
determination of the cost of inventories (para. 25).
IAS 2 Marking to market allowed for inventories of
commodity broker-traders (para. 3).
IAS 7 Net basis allowed for cash ow statements
(para. 21).
IAS 7 Choice of classication for interest and dividend
ows (para. 31).
IAS 16 Either cost or fair value measurement basis for
classes of property, plant and equipment (para. 29).
IAS 19
Actuarial gains and losses can be taken (a)
immediately in full to the statement of recognised
income and expense (SORIE), (b) immediately in full
to the income statement, (c) in full to income over
the remaining useful lives of employees in the plan,
(d) in full to income over a shorter period (paras
92–93A).
IAS 20 Asset grants can be shown either as a deduction
from the asset or as deferred income (para. 24).
IAS 27
In parent statements, subsidiaries can be shown
either at cost or as available-for-sale investments
(para. 37).
IAS 28
In investor statements, associates can be shown
either at cost or as available-for-sale investments
(para. 38).
IAS 31
In group statements, there is a choice of either
proportional consolidation or equity accounting for
joint venture entities (para. 30).
IAS 31
In venturer statements, joint ventures can be shown
either at cost or as available-for-sale investments
(para. 46).
IAS 38 Either cost or fair value measurement for some types
of intangible asset (para. 72).
IAS 39
Choice of either cost basis or marking to market for
some nancial assets and liabilities (para. 9). (Other
choices are also available within para. 9.)
IAS 40 Permission to classify a property held under an
operating lease as an investment property (para. 6).
IAS 40 Entity-wide choice of either cost or fair value as the
measurement basis for investment property (para. 30).
IFRS 3 Choice on the calculation of goodwill in the context
of non-controlling interests (para. 19).
Covert options in IFRS
There are many cases of vague criteria that can lead to
dierent interpretations. Each year, there are large
numbers of queries to the IFRS Interpretations Committee
on issues about which companies or auditors think that
IFRS is unclear. Some of these lead to ocial
interpretations or amendments of IFRS. This process is a
symptom of the complexities of business, accounting and
the content of IFRS. There are still many issues where
dierent interpretations are plausible (and which are, in
eect, covert options), and where IFRS practice might
follow national traditions.
A long-standing example of the need to interpret criteria is
the requirement in IAS 11 (and in many national GAAPs) to
use the percentage-of-completion method if the outcome
of the contract can be estimated reliably. Varying degrees
of conservatism in the accounting cultures of dierent
countries might lead to dierent conclusions about the
same contract. Table 5.2 gives examples of covert options
in IFRS, most of which involve probability estimates or
assessments of some other kind of percentage.
Estimations in IFRS
Any interesting accounting topic requires estimations as
part of the measurement of items. Table 5.3 gives
examples in the context of IFRS. Taking the topic of
impairment, it is rst necessary to judge whether an
impairment test is needed (a covert option) and then, if it
is, to estimate cash ows and discount rates. These
estimations might, again, be aected by national
accounting culture. There is also scope for a tax eect. In a
country where impairments are tax deductible, there will
be a tendency to nd them and to estimate them to be
large in unconsolidated statements under national GAAP.
These gures might ow through to IFRS consolidated
statements.
24
Table 5.2: Examples of covert options or vague criteria in
IFRS, 2010
IAS 1
Determination of whether a liability is current on
the basis of the expected date of settlement or
purpose of holding (para. 60).
IAS 8 The determination of materiality for various
purposes (para. 5).
IAS 11
Use of percentage of completion method only if
the outcome of a contract can be estimated
reliably (para. 22).
IAS 12
Recognition of a deferred tax asset for a loss carry
forward only if future taxable prot is probable
(para. 34).
IAS 12
Recognition of a deferred tax liability on
unremitted prots from subsidiaries only if
dividends are probable in the foreseeable future
(para. 39).
IAS 17
Lease classication based on ‘substantially all the
risks and rewards’ with no numerical criteria
(para. 8).
IAS 21 Determination of functional currency based on a
mixture of criteria (paras 9–12).
IAS 23
Cessation of capitalisation of borrowing costs when
‘substantially all’ the activities to prepare the asset
are complete (para. 22).
IAS 27 Identication of a subsidiary on the basis of ‘power
to control’ (para. 4).
IAS 28 Identication of an associate on the basis of
‘signicant inuence’ (para. 2).
IAS 31
Identication of a joint venture on the basis of joint
control of ‘strategic nancial and operating
decisions’ (para. 3).
IAS 36 Identication of an indication of impairment based
on a mixture of criteria (paras. 12–14).
IAS 37 Recognition of a provision based on probability of
outow of resources (para. 14).
IAS 38 Capitalisation of development costs when all
criteria are met (para. 57).
IAS 38 Amortisation of intangible assets only if useful life
is assessed as nite (para. 88).
IAS 39 Use of cost basis where equity instruments cannot
be measured reliably (para. 46).
IAS 39 Estimation of hedge eectiveness as a condition
for use of hedge accounting (para. 88).
IAS 40
Use of cost basis, despite entity-wide choice of fair
value, for an investment property whose fair value
cannot be measured reliably (para. 53).
IAS 41 Use of cost basis for a biological asset whose fair
value cannot be measured reliably (para. 30).
IFRS 3 Identifying the acquirer in a business combination
presented as a merger of equals (para. 20).
IFRS 5 Treatment of assets as held-for-sale if expected to
be sold within one year (para. 8).
IFRS 8 The determination of reportable segments based
on a mixture of factors (para. 11).
Table 5.3: Examples of measurement estimations in
IFRS, 2010
IAS 2 Net realisable value of inventories
(paras. 30, 31).
IAS 11 Costs attributable to a contract
(para. 16).
IAS 12
Tax rate for deferred tax calculations based
on the expected manner of settlement or
recovery (para. 51).
IAS 16
(and IASs 17, 38,
40)
Depreciation (or amortisation) based on
estimates of useful life, residual value, and
pattern of consumption (paras 50, 51 and 60).
IAS 16
(and IASs 38, 40)
Fair value when selected as a measurement
basis (paras. 31–34).
IAS 19 Pension obligations based on estimates of
mortality, nal salary, etc (para. 64).
IAS 36 Discounted cash ows or net realisable
values for impairments (para. 18).
IAS 37 Best estimate of provisions based on
percentage likelihoods of outows (para. 40).
IAS 39 Fair values of certain nancial assets and
liabilities (para. 48).
IAS 41 Fair values of biological assets
(para. 12).
IFRS 2
Fair value of equity instruments (eg share
options or shares in an unlisted company)
granted to employees (para. 11).
IFRS 3
Allocation of cost of a business combination
to assets and liabilities of acquiree based on
fair values (para. 36).
25
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
6. NATIONAL PATTERNS ON TRANSITION TO IFRS
6.1 CHOOSING COUNTRIES AND COMPANIES TO STUDY
The next two chapters seek to discover whether the
motives and opportunities for dierent national patterns of
IFRS practice (as examined in Chapter 5) have actually led
to such patterns. This chapter examines the earliest year
for which there were IFRS reports from companies on
several major stock markets. As explained in Chapter 4,
IFRS practice has not yet arrived in mainland China, Japan
or the US. Of the world’s 10 largest stock markets, only
Germany required the use of IFRS before 2005 but several
other major countries introduced requirements for 2005
onwards. Therefore, this chapter, examines IFRS practice
for accounting years beginning on or after 1 January 2005.
The countries chosen were those with the world’s ve
largest stock markets in 2005 that required use of IFRS for
the consolidated statements of listed companies
(according to data from the World Federation of Stock
Exchanges, June 2005). The countries are Australia,
France, Germany, Spain and the UK. This list includes
countries from both classes A and B in Chapter 3.
Large listed companies were chosen from these ve
countries for two reasons. First, their annual reports (in
English) are easy to obtain. Secondly, any ndings are
likely to be generalisable. That is, the largest companies
are likely to be the most international and the least likely
to exhibit country-specic practices. Therefore, even if they
exhibit such practices, it is likely that most companies in
that country do.
We take the companies that compose the main stock
market indices: ASX 50, CAC 40, DAX 30, IBEX 35 and
FTSE 100. Germany was a special case for two reasons: (1)
many companies had adopted IFRS earlier, and (2) seven
of the DAX 30 were still using US GAAP, as allowed for
2005 and 2006 by German law. For the study of the most
recent reports (see Chapter 7), however, all the DAX
companies can be included. Excluding companies using
US GAAP and a few foreign companies (eg a Belgian
company in the CAC 40 index), this led to a sample of 232
IFRS reports.
6.2 HYPOTHESIS OF COMPANY BEHAVIOUR ON
TRANSITION
Although the main purpose of this chapter is to discover
whether national patterns of IFRS practice exist, it will be
useful to go further by explaining why a particular pattern
is found in a particular country. For this, a hypothesis is
helpful:
When a company uses IFRS for the rst time, it will
tend to continue its previous accounting policies
wherever possible.
There are several reasons for expecting this behaviour
(apart from inertia).
It continues to full whatever incentive led to the policy •
choice in the rst place.
It reduces the costs of data handling, training and •
audit.
It assists users of nancial statements by maximising •
continuity.
In order to predict which accounting policies a company
will choose under IFRS, it is necessary to create a list of
topics that allow choices and then to discover which choice
the company made under pre-IFRS national rules. For
many topics, a company had no choice under pre-IFRS
national rules, so it is not necessary to look at all policies
for all companies individually.
Table 6.1 contains a list of policy choices, drawn from the
list of overt options in Table 5.1. Policy choices that do not
aect consolidated statements are omitted. Table 6.1 also
contains a record of which practice was required by
pre-IFRS national rules. In a few cases, the predominant
practice of large companies is recorded instead. The
information for all this comes from a variety of reference
works.
19
19. Australian and UK accounting standards; German Commercial Code
(HGB); French and Spanish accounting plans; Ordelheide and KPMG
(2001).
6. National patterns on transition to IFRS
26
Table 6.1: IFRS policy choices and pre-IFRS practices
IFRS Option Aus UK Ger Fra Spa
1* (a) Balance sheet shows assets = credits – – R R R
(b) Balance sheet shows net assets R P – – –
2* (a) Balance sheet liquidity increasing – R R R R
(b) Liquidity decreasing (starts with cash) R – – – –
3* (a) Income statement by function – – – – –
(b) Income statement by nature – – – – R
4* (a) Equity accounted results included in ‘operating prot’ – – – – –
(b) Immediately below ‘operating prot’ – R R – –
(c) Below nance – – – R R
5 (a) Statement of changes in equity (SCE) – – – – –
(b) SORIE, excluding owner transactions – R – – –
6* (a) Direct operating cash ows R – – – –
(b) Indirect operating cash ows – – – – –
7* (a) Interest paid as operating cash ow R – – R –
(b) As nancing – R – – –
8 (a) Only cost for property, plant and equipment (PPE) – – R R R
(b) Some PPE at fair value – – – – –
9 (a) Investment property at cost – – R R R
(b) Investment property at fair value – R – – –
10 (a) Capitalisation of interest on construction R – – – P
(b) Expensing – – – – –
11* (a) FIFO for inventory cost – P – – –
(b) Weighted average only – – P – –
12 (a) Actuarial gains/losses to SORIE – R – – –
(b) To income in full – – – – –
(c) Corridor – – P – –
13 (a) Proportional consolidation of JVs – – – R R
(b) Only equity method R R – – –
* = Non-nancial companies only
R = Required
P = Predominant
27
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
6. NATIONAL PATTERNS ON TRANSITION TO IFRS
Table 6.2 Policy choices (percentages of companies by country), 2005/6
Aus UK Ger Fra Spa
1 (b) Balance sheet shows net assets 100 85 0 0 0
2 (a) Balance sheet liquidity increasing 0 100 85 100 96
3 (a) Income statement by function 59 47 76 55 4
3 (b) Income statement by nature 30 14 24 45 96
3 (c) Neither 11 39 0 0 0
4 (a) Equity accounting results included in ‘operating prot’ 63 25 19 7 0
4 (b) Immediately below ‘operating prot’ 16 32 62 3 8
4 (c) Below nance 21 43 19 90 92
5 (b) SORIE only (not SCE) 66 84 22 6 25
6 (b) Indirect operating cash ows 0 98 100 100 88
7 (a) Interest paid as operating cash ow 91 68 62 89 39
8 (b) Some PPE at fair value 14 12 0 0 0
9 (b) Investment property at fair value 43 73 0 0 0
10 (a) Capitalisation of interest on construction 76 48 22 40 94
11 (a) FIFO for inventory cost 27 50 0 12 6
11 (b) Weighted average only 59 29 71 58 88
12 (a) Actuarial gains/losses to SORIE 73 85 48 20 13
12 (b) To income in full 18 3 0 6 37
12 (c) Corridor 9 12 52 74 50
13 (a) Proportional consolidation of JVs 5 22 31 81 85
6.3 WHICH IFRS POLICIES DID COMPANIES CHOOSE?
The next stage was to obtain the annual reports of the 232
companies for 2005/6 and to discover their choices for the
13 policy issues listed in Table 6.1. It was necessary to
hand-pick the data for this, because no convenient
database exists. The results of this research are shown in
Table 6.2.
Some statistical tests are reported below, but inspection of
Table 6.2 immediately reveals major dierences between
countries. This is most obvious for policy choices 1, 2, 6, 9
and 13. Some countries have no examples of a certain
practice, whereas it is the majority choice in others.
A chi-square test can be used to measure whether a policy
choice is independent of country. For 12 of the 13 policy
choices a null hypothesis of equal practice across
countries can be rejected at the 1% level. For the
remaining policy choice (8, measurement of PPE), it can
be rejected at the 5% level. This is very strong evidence of
the existence of national patterns of IFRS practice.
Furthermore, in nearly all cases where a practice was
required or predominant before IFRS (shown as ‘R’ or ‘P’
in Table 6.1), it is the predominant choice under IFRS
(shown by high percentages in Table 6.2). This can be
conrmed by binomial tests, for issues that have two
choices, using conventional methods of approximations to
the normal distribution. For example, on option 1, Australia
and the UK are expected to show net assets, whereas the
other countries are not. So, Australia can be compared
with France, then Spain, then Germany; and then the UK
can be compared with France, then Spain, then Germany.
This makes six testable hypotheses. All of them enable the
rejection of a hypothesis of equality of practice at the 1%
level. A large number
20
of such tests provides very strong
statistical evidence that IFRS choices can be predicted by
pre-IFRS national practices.
20. 68 such binomial tests were carried out: 56 led to rejection at 1%, 10
to rejection at 5%, and 2 to no rejection.
28
6.4 WHAT ARE THE NATIONAL PATTERNS?
The predictions based on pre-IFRS practices of Table 6.1,
slightly corrected by the ndings of real IFRS practices as
reported in Table 6.2, can be used to record the typical
IFRS practices of a particular country. Table 6.3 does that
for the ve countries examined in this chapter. In that
table, ‘Y’ means ‘yes’, and is recorded where the score in
Table 6.2 is over 70%; ‘N’ means ‘no’ and is recorded
where the score is under 30%. In a few cases, Y* or N* are
recorded where the 70/30 thresholds are narrowly missed.
A question mark (‘?’) is recorded in those few cases where
no typical IFRS can be predicted.
6.5 HOW IMPORTANT ARE THE DIFFERENCES IN
PATTERNS?
So far, this chapter has examined 13 IFRS policy options
(see Table 6.1). The choices made by companies are easy
to observe. The options can be divided into three types.
A. Those that are unlikely to hamper international
comparisons, eg balance sheet formats (options 1
and 2).
B. Those that can be adjusted for by alert analysts,
eg the position of interest paid in the cash ow
statement (option 7) or whether actuarial losses are
included in the calculation of earnings (option 12).
C. Those that cannot be adjusted for, eg from a
by-nature income statement to a by-function one
(option 3) or from equity accounting to proportional
consolidation (option 13).
Table 6.3 National patterns of IFRS practice, 2005/6
Aus UK Ger Fra Spa
1 Balance sheet shows net assets Y Y N N N
2 Balance sheet starts with cash Y N N N N
3 Income statement by function Y* ? Y ? N
4 Equity accounting prots included in ‘operating prot’ Y* N* N N N
5 SORIE only (not SCE) Y* Y N N N
6 Indirect cash ows N Y Y Y Y
7 Interest paid as operating cash ow Y Y* Y* Y N*
8 Only cost for PPE Y Y Y Y Y
9 Investment property at cost ? N Y Y Y
10 Capitalisation of interest on construction Y ? N ? Y
11 Weighted average only for inventory ? N* Y ? Y
12 Actuarial gains/losses to SORIE Y Y ? N N
13 Proportional consolidation of JVs N N ? Y Y
An indication of the importance of the dierence in
patterns can be gained by looking at the two options
mentioned in type B: interest paid and actuarial losses.
For each, we have selected a country with diverse
practices: the UK for interest paid (see 7a in Table 6.2),
and Germany for actuarial losses (see 12a in Table 6.2).
Interest paid (UK)
The cash ow statements of 24 UK non-nancial
companies (33% of the sample) treat interest paid as a
‘nancing’ cash outow. For these companies, Table 6.4
shows the amount of interest paid and the size of
operating cash ows. The ‘%’ column shows how much
smaller the operating cash ow would have been if each
company had adopted the majority practice of treating
interest paid as ‘operating’. As may be seen, in one case
(Cable and Wireless), this would have caused operating
cash ow to be negative. The average of the percentages in
Table 6.4 is 20.3%. By contrast, the average for the
majority of companies (that show interest paid as
operating) was 15.6%. This dierence is statistically
signicant at the 1% level. It suggests that management
choice of accounting policy is aected by a desire to
improve the look of operating cash ows.
29
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
6. NATIONAL PATTERNS ON TRANSITION TO IFRS
Table 6.4: Interest paid and operating cash flows for UK
non-financial companies 2005/6 that show interest paid as
‘financing’ (£m)
Interest
paid £m
Operating
cash ow
£m %
AngloAmerican 547 6781 8.1
Antofagasta 23.3 1304.7 17.9
Associated British Foods 47 419 11.2
BAT 371 2324 16.0
BG 72 1606 4.5
BSkyB 105 875 12.0
BT 1086 5387 20.2
Cable & Wireless 61 56 108.9
Daily Mail 50.1 350.8 14.3
DSGI 20.5 3367 6.1
Enterprise Inns 234 465 50.3
Gallaher 163 572 28.5
Glaxo 381 5958 6.4
Imperial Tobacco 199 1155 17. 2
Johnson Matthey 30.6 212.3 14.4
Kingsher 39.3 304.1 12.9
M&S 142.8 1096.0 13.0
National Grid 834 2971 28.1
Next 21.4 398.2 5.4
Punch Taverns 319.1 535.1 59.6
Rolls Royce 88 1060 8.3
Royal Dutch Shell 1124 30113 3.7
Unilever 643 4353 14.8
Vodafone 1254 20595 6.1
Average of the percentages 20.3
Actuarial losses (Germany)
A majority of German non-nancial companies (71%) took
actuarial gains and losses (AGL) to the SORIE. The SORIE
was the statement that contained what is now called ‘other
comprehensive income’. In all but one case, the AGL was a
loss (see Table 6.5). Adopting the SORIE treatment
protects the income statement from losses but increases
the pension liability. It is somewhat complex to work out
the percentage eects because it involves calculating what
would be the size of the corridor and the length of
amortisation. However, an academic study of German
companies (Stadler 2010) shows strong evidence that the
SORIE treatment is chosen by companies that would have
AGL in excess of the corridor.
It is easy to give an indication of how important this policy
choice is. Table 6.5 shows the size of actuarial gains and
losses as a proportion of the prot (pre-tax, in each case).
As may be seen, pre-tax prot would have been greatly
reduced for many companies if AGL had been charged to
income. Use of the corridor would have reduced the eect.
Table 6.5: Actuarial gains/losses of German companies
presenting a SORIE, 2005 (€m)
Company
Actuarial gain
(loss) (€m)
Pre-tax prot
(€m) %
Adidas (9) 655 (13.7)
BASF (1075.9) 5925.6 (18.2)
Bayer (1207) 2199 (54.9)
BMW (736) 3287 (22.4)
Henkel (72) 1042 (6.9)
Linde (73) 789 (9.3)
Merck (113.6) 893.4 (12.7)
Thyssen 385* 2623 14.7
Tui (2 97.6) 385.5 (77. 2)
Volkswagen (1231) 1722 (71.5)
* loss of 760 in previous year.
30
6.6 MORE COMPLEX IFRS PRACTICES
The evidence concerning national patterns (discussed in
sections 6.3 to 6.5) is important even for options referred
to as type A in section 6.5 (ie those unlikely to hamper
international comparisons) because it bolsters the
following proposition:
Given the strong evidence for national patterns of
IFRS practice from accounting policy choices which
are easily observed, we can expect national patterns
of practice on topics that cannot easily be observed.
The following are among the important topics for which
national patterns are likely but are dicult to uncover.
Impairment indicators
Under IAS 36, impairment testing is only necessary, for
most assets, if there are indications of a possible
impairment. Identifying these indications requires
judgement. Accountants in some countries might be more
than averagely prudent in this identication, for example,
because of a long history of conservatism or the tax-
deductibility of impairments under national rules.
Impairment measurements
IAS 36 requires the measurement of discounted cash ows
or fair value or both. For damaged, used assets this
involves considerable judgement (in estimating cash ows,
choosing discount rates, etc). As above, the degree of
prudence might dier internationally.
Recognising development assets
IAS 38 requires development costs to be capitalised rather
than expensed when a series of criteria are met. This
leaves scope for dierent national traditions to continue.
Contract accounting
Under IAS 11, the percentage-of-completion method
should be used when the outcome of a contract can be
reliably estimated. Again, dierent national traditions of
prudence could lead to dierent interpretations of this.
Deferred tax assets
Under IAS 12, deferred tax assets should be recognised
when they are more likely than not to be recovered. In
some national traditions, however, deferred tax assets do
not exist (because there are no timing/temporary
dierences) or are only recognised when virtually certain,
or highly probable, etc. This tradition could aect the
behaviour of accountants under IFRS.
Scope of consolidation
Under IAS 27, group A should consolidate entity B if B is
controlled. This can sometimes occur if A holds less than
half the voting rights or even no shares at all. Accountants
from some national traditions might tend, in practice, to
base identication of control on reliable criteria such as
shareholdings. The same applies to the identication of
signicant inuence under IAS 28.
31
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
7. HAVE NATIONAL PATTERNS PERSISTED?
7.1 INTRODUCTION
Chapter 6 has shown that national patterns of IFRS
practice existed in ve important capital markets in
2005/6. Nevertheless, that was a transition year for most
of the 232 companies surveyed. It is possible that, faced
with the major task of transition, companies took the
easiest route by maintaining their previous policies
wherever possible. In subsequent calmer times, however,
they might have learnt to exploit the options available in
IFRS. Although IAS 8 attempts to restrict changes to
accounting policy, it will often be possible to make changes
on the grounds of better accounting or altered
circumstances.
This chapter investigates to what extent changes to
policies were made in the rst three years after transition,
and whether national patterns of IFRS practice can still be
discerned.
7.2 POLICY CHANGES FROM 2005/6 TO 2008/9
In order to examine IFRS policy changes from 2005/6 to
2008/9, the same companies are considered as in Chapter
6, except that of these, 22 no longer presented IFRS
consolidated statements in 2008/9 (largely because of
takeovers). The resulting sample is 210 companies. The
same 13 policy choices are used as in Chapter 6, all of
which were still available in 2008/9.
For a few of the options, the IASB had announced
amendments by the time the 2008/9 statements were
prepared.
IAS 1 had been amended in 2007 for compulsory •
adoption in 2009/10. This aects option 5 of the tables
in Chapter 6: an entity is now required to present (i)
other comprehensive income either as a separate
statement (like a SORIE) or as part of a comprehensive
income statement; and (ii) a statement of changes in
equity.
IAS 23 had been amended in 2007 for compulsory •
adoption in 2009/10. This aects option 10: the option
of expensing interest is removed.
ED 9 was issued in 2007, proposing to remove IAS 31’s •
option of proportional consolidation. This would aect
option 13, although no Standard had been issued by
the end of 2009.
In this section these three options are considered
separately from the others.
Table 7.1 shows the average number of policy changes per
company from 2005/6 to 2008/9. As may be seen, the
changes are few, especially for Australia and the UK. When
the changes related to amendments to IASs 1, 23 and 31
are excluded there are very few changes indeed. For
example (not shown in Table 7.1), there were no policy
changes for the great majority of Australian and UK
companies: 83% and 85%, respectively. The noticeable
dierence in the number of policy changes between the
‘Anglo’ companies (Australia and the UK) and the
Continental European companies is examined in Chapter
8, along with other dierences between these two groups.
Table 7.1: Policy changes per non-financial company
Country
Average number of policy
changes
Australia 0.30
UK 0.34
Germany 0.65
France 1.03
Spain 1.25
7.3 ONE MAJOR POLICY CHANGE
Of the policy changes that were not related to early
adoption of amendments to IFRS, a majority were on one
topic: the treatment of actuarial gains and losses (AGL). In
IAS 19, there are three possible methods for AGL.
A Taking them immediately to the SORIE/other
comprehensive income (OCI) (option introduced in
2004).
B Ignoring small AGL, and taking the rest to prot and
loss slowly (the corridor approach).
C Taking AGL to prot and loss immediately.
From 2005 to 2010, most companies had actuarial losses
rather than gains.
21
Method A above protects the
calculation of earnings from those losses (and from
volatility, if there are gains). Method B reduces volatility of
earnings and protects the balance sheet from big
increases in pension obligations. Method C is simplest but
causes the most volatility to earnings and liabilities.
21. See, for example, Stadler (2010).
7. Have national patterns persisted?
32
We can now make some predictions based, among other
things, on the arguments of Chapter 4.
‘Anglo’ companies (eg Australian and UK) will be •
especially interested in stock market reactions, and will
therefore be averse to volatility, and will use the SORIE.
UK companies will take the SORIE approach under •
IAS 19 on transition in 2005/6 because it preserves
pre-IFRS UK practice.
French and Spanish companies are less worried about •
stock market reactions, and had no SORIE in pre-IFRS
practice, so will not use the SORIE.
German companies will not use the SORIE in 2005 •
because there was no SORIE option in pre-2004 IFRS
practice or in German GAAP.
Over time, some Continental European companies will •
learn to use the new (SORIE) option to protect earnings.
Table 7.2 shows the percentages of companies using the
SORIE for 2005/6 and 2008/9. As may be seen, all the ve
above propositions about AGL can be conrmed as follows.
Nearly all Australian and UK companies use the SORIE.•
Few French and Spanish companies used the SORIE in •
2005 (most used the corridor).
German companies generally did not use the SORIE in •
2005 (55% used the corridor).
Companies that were not using the SORIE in 2005 •
gradually learnt to use it by 2008.
One further possibly relevant explanation for the use of the
corridor is a listing in the US (or other cause of SEC
registration), given that the corridor is used in US GAAP.
Even so, there is little evidence in favour of this
explanation. About one-third of the 23 German companies
that used IFRS in both 2005 and 2008 were using the
corridor in 2008. These are about equally divided into SEC
registrants and non-registrants. Of the seven additional
German companies that had used US GAAP in 2005, only
two used the corridor under IFRS in 2008.
Table 7.2: Percentages of companies using the SORIE for
actuarial gains and losses
Year
%
Australia
%
UK
%
France
%
Spain
%
Germany
2005 73 83 21 14 45
2008 86 86 50 63 63
7.4 PERSISTENCE OF NATIONAL PATTERNS
Given how few changes of policy there were after 2005/6,
the national patterns identied in Chapter 6 could be
expected to have persisted. To check this, the chi-square
test used in section 6.3 was repeated for the choices on
the 13 topics for the 210 companies. The seven German
DAX companies that had been using US GAAP in 2005
were included. As before, for all the topics except PPE
measurement, a hypothesis of equal practice across the
countries can be rejected at the 1% level.
The conclusion is that the national patterns of IFRS
practice remain largely the same as in 2005/6 and are still
very clear. Table 7.3 updates the national patterns (as
shown in Table 6.3 on page 28 for 2005/6) to the
practices of 2008/9. The main change is to options 5 and
12, which are related. For these, continental companies
have moved to the ‘Anglo’ practices.
Table 7.3: National patterns of IFRS practice, 2008/9
Aus UK Ger Fra Spa
1 Balance sheet shows net assets Y Y N N N
2 Starts with cash Y N N N N
3 Income statement by function ? ? Y Y* N
4 Equity prots in operating prot Y* ? N* N N
5 SORIE only Y* Y N N N
6 Indirect cash ows N Y Y Y Y
7 Interest paid as operating prot Y Y* Y* Y ?
8 PPE at cost Y Y Y Y Y
9 Investment property at cost ? N Y Y Y
10 Interest capitalisation Y ? N ? Y
11 Weighted average only ? N* Y ? Y
12 AGL to SORIE Y Y Y* ? Y*
13 Proportional consolidation of JVs N N ? Y Y
33
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
8. COUNTRY GROUPS AND NATIONAL PATTERNS OF IFRS
8.1 INTRODUCTION
Chapter 3 examined the evidence for the existence of
groups of countries that have similar accounting systems.
In Chapter 4, these groupings were useful in explaining
how dierent countries reacted with varying degrees of
enthusiasm to IFRS.
This chapter considers whether national patterns of IFRS
fall into similar groups, and whether the frequency of IFRS
policy changes is related to this. For this, the data on
topics and countries that were collected for Chapters 6
and 7 can be used.
8.2 CLASSIFICATION OF COUNTRIES BY IFRS PRACTICES
Using the data on the IFRS policy choices made by
companies in 2005/6 (see Table 6.2), statistical techniques
can be used to examine whether the ve countries fall into
groups. Previous researchers
22
in the eld of classication
have used principal component analysis, cluster analysis
and multidimensional scaling. All these tests have been
performed here and they lead to the same conclusion:
there is an ‘Anglo’ group (Australia and UK) and a
Continental European group. This is best illustrated by the
dendrogram that results from cluster analysis, shown as
Figure 8.1.
The conclusion is that the two-group classication of
national practices (discussed in Chapters 3 and 4) can still
be found in national versions of IFRS practices.
22. For example, Frank (1979) and d’Arcy (2001).
8. Country groups and national patterns of IFRS
Figure 8.1: Dendrogram showing classification of
countries by IFRS practices
L2 dissimilarity measure
200
150
100
50
0
Australia UK Germany France Spain
34
8.3 COUNTRY EFFECT ON POLICY CHANGES
As shown in Table 7.1 on page 31, there were clearly more
policy changes (from 2005/6 to 2008/9) for Continental
European companies than for ‘Anglo’ companies. This is a
statistically signicant nding. So, again, a two-group
classication can be found for this aspect of accounting.
As explained in section 7.3, most of these changes
concerned the treatment of actuarial gains and losses and
the related presentation of other comprehensive income.
8.4 A MAJOR IMPLICATION
We can now consider a major question behind much of the
discussion in this report: are options and exibility within
Standards useful (or perhaps even necessary) for good
nancial reporting in an international context? We can
summarise the arguments for and against having such
exibility.
For
There are major, deep-seated and long-lasting dierences
between countries. These include culture, legal systems,
tax systems, nancial systems and language. Therefore,
international dierences in nancial reporting are
expected, inevitable and welcome. Options and exibility in
IFRS help companies to adapt to it. Dierent countries
have dierent ways of doing business, dierent contract
types, dierent predominant industries, and so on. So,
options are necessary.
Against
Whereas international dierences in nancial reporting
might, indeed, be useful for accounting designed for
domestic purposes (eg for tax or dividend calculations), for
companies that are competing in the same international
market for capital, comparable nancial reporting is
required. For these purposes, therefore, options and
exibility in IFRS are not helpful. If there are two types of
transactions/contracts/etc that should have two types of
nancial reporting, the solution is not to create options and
exibility. A Standard should set out principles for
determining which of the two economic conditions is
present. It should then require method 1 accounting for
type 1 conditions, and method 2 accounting for type 2
conditions. The problem with options and exibility is that
they can be deliberately misused or that national traditions
persist for no good economic reason.
This leads to the conclusion that, although international
variety is welcome in many other elds (eg cuisine,
language), and it is harmless in some others (eg possibly
in accounting by private companies), where international
comparability is required (eg in IFRS reporting to
international investors), variety can be dangerous unless it
reects underlying dierences in reality rather than
national traditions or preferences. For example, there
seems to be no compelling underlying economic reason
why only 16% of German companies should proportionally
consolidate their joint ventures in 2008/9, whereas 91% of
Spanish companies do so. Apart from anything else, this
greatly increases the cash and sales gures of the Spanish
companies compared with the German companies,
rendering the nancial statements non-comparable.
There is no obvious reason to justify the continuation of
any of the 13 policy choices documented in Chapters 5
to 7.
35
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
9. DOES SIZE MATTER?
9. 1 INTRODUCTION
Some of the ndings in Chapters 6 and 7 are surprising.
For example, the majority of German companies use the
by-function income statement, even though this was not
allowed in Germany until 1987 (with the revision of the
Handelsgesetzbuch after the Fourth Directive). Such
discoveries raise the question as to whether very large
companies might be atypical of their country. This chapter
makes a preliminary investigation of this question by
examining the 13 accounting options of Chapter 7 for the
same period (2008/9) for smaller listed companies.
German companies have been selected here because an
inspection of the policies of large companies (eg Table 7.3)
suggests that it is the German ones that might be
especially aected by international pressures to move
away from traditional German practices.
9.2 DATA AND RESULTS
The 25 smallest listed non-nancial companies were
selected from the list of the Deutsche Börse. This is a
similar sample size to that in Chapter 7. Data were then
hand-picked for the 13 options of Chapter 7 from the
2008 annual reports (all of which were available in English).
The results of the investigation are shown in Table 9.1.
As may be seen in Table 9.1, there are considerable
dierences between the practices of small and large
German companies on several options. As the table shows,
three of these dierences are highly signicant and two
are signicant at the 5% level. There were limited data on
topic 13, so the signicance of the large dierence could
not be conrmed.
The dierences can be summarised as showing that
smaller companies stay closer than large companies to
traditional German practices. In general they:
use the by-nature income statement•
use a liquidity-increasing balance sheet•
do not present a SORIE•
do not capitalise interest•
do not take actuarial gains/losses to the SORIE.•
9.3 IMPLICATIONS
This preliminary study suggests that there are signicant
dierences between the IFRS policies of small and large
companies. Further investigation is warranted.
The ndings reinforce those of Chapters 6 to 8. That is,
small German companies have an even more distinct
pattern of policies (eg more removed from the practices of
UK companies) than do large German companies. If small
companies have even more distinct national proles than
large companies, then the country groupings discovered in
Chapter 8 would be even more distinct for smaller
companies (ie most companies).
9. Does size matter?
Table 9.1: Policy choices of German non-financial companies 2008 (percentages)
Large companies Small companies Dierence
1 (b) Focusing on net assets 0.0 0.0 0.0
2 (a) Balance sheet liquidity increasing 69.6 92.0 +22.4**
3 (a) Income statement by function 82.6 36.0 –46.6***
4 (a) Equity accounting results included in ‘operating prot’ 22.7 15.4 –7. 3
5 (b) SORIE only 43.5 8.0 –35.5***
6 (b) Indirect operating cash ows 100.0 100.0 0.0
7 (a) Interest paid as operating cash ow 68.2 76.0 +7. 8
8 (b) Some PPE at fair value 0.0 0.0 0.0
9 (b) Some investment property at fair value 0.0 0.0 0.0
10 (a) Capitalisation of interest on construction 43.5 11.1 –32.4**
11 (b) Weighted average only 75.0 68.4 –6.6
12 (a) Actuarial gains/losses to SORIE 73.9 25.0 –48.9***
13 (a) Proportional consolidation of JVs 18.8 42.9 +24.1
*** = 1% level signicance
** = 5% level signicance
36
10.1 CONCLUSIONS
The rst important conclusion of this report relates to
identifying the main inuences on a country’s accounting
system. If a country’s regulatory and nancial culture has
been dominated by another country’s, then that will
explain its accounting system. Otherwise, the main
explanatory factor for a country’s type of accounting is the
nancing system and the related mix of corporate owners.
If a country changes its nancing system, the purpose of
accounting (and, therefore, the type of accounting)
changes. On the basis of this, accounting systems can
initially be divided into two classes, depending on whether
or not the country has a large number of outside
shareholders. Any one country can use more than one
system for dierent purposes.
For companies that raise money on an international basis,
there is a strong argument for comparability of nancial
reporting, perhaps based on IFRS. There are many ways to
implement IFRS in a jurisdiction. Few jurisdictions require
companies to comply directly with IFRS as issued by the
IASB.
The two-group classication of countries by their
accounting systems (‘Anglo’ compared with Continental
European) is useful for predicting and explaining how a
jurisdiction will react to IFRS, eg whether IFRS is allowed
for unconsolidated reporting.
The motives that led to dierences between national
nancial reporting systems might still drive dierences in
the way in which IFRS is practised. The most obvious
opportunity for these dierences to arise is the existence
of options in IFRS, but unobservable dierences might be
even more important. On rst-time adoption of IFRS, a
company is likely to continue with its previous policies, and
this applies to many accounting policies.
An examination of the IFRS policies of large listed
companies of ve major countries in 2005 provides strong
evidence for this hypothesis of continuing national
practices. This means that national patterns of IFRS
practice do exist and can be described.
A study of the IFRS policies of the same companies in
2008 reveals few policy changes, and therefore indicates
the persistence of national patterns. One major change
between 2005 and 2008 was the move by Continental
European companies to the ‘Anglo-Saxon’ policy of
treating actuarial gains and losses as other comprehensive
income (and, therefore, having to present a statement
showing such income).
The previously discussed two-group classication of
pre-IFRS accounting systems was still statistically apparent
when looking at the 2005 policy choices. This classication
was also apparent in the amount of policy change over the
period from 2005 to 2008, with the Continental
companies making more changes.
Another factor that might aect IFRS policy choices was
investigated: size. Taking Germany as an example, small
listed companies choose signicantly dierent IFRS
policies from the largest companies. The above ndings on
national patterns and on country groups for larger
companies would probably be even clearer for smaller
companies (ie for most companies).
10.2 RECOMMENDATIONS
Several recommendations and policy implications follow
from the ndings in this report. First, there are still very
large dierences between IFRS and US GAAP. It is not clear
that the SEC was wise to remove the reconciliation
requirement for foreign registrants. Analysts should note
that it is dangerous to compare IFRS and US nancial
statements without adjustment.
Secondly, the simplest way for a jurisdiction to implement
IFRS is to adopt the IASB’s process rather than to absorb
or endorse standards one-by-one. Even if jurisdictions do
not require entities to comply with ‘IFRS as issued by the
IASB’, they should require auditors to give an opinion on
that, assuming that such compliance is intended or
allowed. For developing countries with few or no listed
companies, it is doubtful whether IFRS is appropriate, and
such countries should consider the issue carefully.
Thirdly, multinational companies that use IFRS for
consolidated statements might have to wait a very long
time before they can use IFRS for all purposes (eg for
statutory reporting for most European subsidiaries).
Analysts, accountants and auditors should be alert to the
many opportunities for dierent practices within IFRS
itself, ie that IFRS statements might not be comparable.
Using this report, analysts, accountants and auditors can
consult a chart of typical IFRS practices for major
countries. Analysts should realise that major international
dierences in IFRS practices are likely to exist in other
topic areas, but these dierences may not be observable.
Finally, given the persistence of national patterns of IFRS
practice, without any apparent underlying economic need
for them, the IASB should continue its eorts to remove
options.
10. Conclusions
37
INTERNATIONAL VARIATIONS IN IFRS ADOPTION AND PRACTICE
10. CONCLUSIONS
10.3 FURTHER RESEARCH
A number of opportunities for further research arise from
the discussion in this report. First, Figure 2.3 on page 13
shows a model that is designed to explain the development
of dierent accounting practices in dierent countries and
examples of its potential application are given.
Researchers could take an extensive list of countries and
examine them over a long period (eg 20 years) in order to
see if the model holds in general.
Secondly, Figure 4.1 on page 17 shows methods of
implementing IFRS and some examples of countries are
given. Researchers could develop a more extensive
classication of countries. Similarly, EU member states
were classied by their degree of acceptance of IFRS. This
could be extended to the rest of the world. An exercise
similar to that in Figure 4.1 could be carried out in order to
classify ways of implementing the IFRS for SMEs.
Next, there has been no thorough research into dierent
translations of IFRS. It would be useful to examine whether
any translation errors or translation diculties have
created important dierences between the accounting
practices of dierent countries.
Another area for investigation is the quality of enforcement
of standards. Some work has been done (eg in Germany)
in the period of voluntary adoption of IFRS. Even so, there
is little published research on whether dierences in IFRS
practice from 2005 onwards might result from poor
enforcement in some countries.
This report studies the use of IFRS options by companies
from ve countries. There is an almost unlimited
opportunity for researchers to extend this to other
countries. This report concentrates on overtly measurable
IFRS options. There might be ways of investigating
international dierences that arise from covert options and
measurement estimations (eg the recognition and
measurement of impairment). This report studies IFRS
reporting in 2005 and 2008. Future researchers will be
able to examine whether the patterns discovered here
persist.
Lastly, the classication of Figure 8.1 page 33 (showing
country groups by IFRS policy choices) could be extended
to include other countries; and the preliminary research
into whether smaller German companies make dierent
choices from larger ones could also be extended to other
countries.
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