3. Main differences between european domestic gaap and IAS/IFRS
Regulation 1606/2002 requires that, for each financial year starting on or after January 1, 2005, companies governed by the law of a member state prepare their consolidated accounts in conformity with IAS/IFRS if, on their balance sheet date, their securities are admitted to trading on a regulated market of any member state. The Regulator has also provided an option for member states to permit or require the application of international accounting standards in the preparation of annual accounts and to permit or require their application by unlisted companies.
Prior regulation for listed companies in Europe was based on the fourth and seventh European Directives. The objective of the Directives was to harmonize financial disclosure, that is, to reduce the number of differences in accounting standards across the European Union member states. However, the Directives did not require that the same rules be applied in all member states, but that the prevailing rules were compatible with those in other member states. Given this flexibility, the implementation of the accounting Directives has differed from country to country.
Domestic GAAP based on such directives are still in use in Europe for those firms and annual accounts that are not permitted or required to adopt IAS/IFRS.
According to Regulation 1606/2002, the fourth and seventh European Directives could not ensure a high level of transparency in financial reporting, which is a necessary condition for building an integrated capital market that operates effectively and efficiently. This implies that requiring IAS/IFRS for listed companies is expected to improve the quality of financial reporting.
The former chairman of IASB, Mr. Tweedie, explains the reasons underlying the switch from the European Directives to the IAS/IFRS as follows: “For too long, earnings have been smoothed in an effort to show investors a steady upward trajectory of profits. While this approach provides a simple and understandable model, it simply is not consistent with reality. Publicly traded companies are complex entities, engaged in a wide range of activities and subject to different market pressures and fluctuations. Accounting should reflect these fluctuations and risks (…) The current direction we are taking will be what I like to call, ‘tell it like it is’ accounting. This means an increasing reliance on fair values, when these values can be determined accurately.”
As a matter of fact, the European Directives are more concerned with the protection of debt holders and mandate more conservative accounting methods. Under the Directives, prudence prevails over accrual, and historical cost is the basic criterion for financial reporting, whereas IAS/IFRS are more focused on equity investors and conceive financial reporting in a more dynamic way. They make large use of fair value accounting and require a fuller disclosure than the European Directives.
Compared to the legalistic and politically and tax-influenced standards that have historically typified accounting in Europe, IAS/IFRS reflect more economic substance than legal form; they make economic gains and losses more timely, and curtail managers’ discretion in setting provisions, creating hidden reserves and smoothing earnings. IAS/IFRS require the entire liability to be on the balance sheet, all companies controlled, even when they carry out different activities, to be fitted within the consolidated area and to be consolidated line by line, and they require assets to be written at their fair value when this value can be determined accurately.
In particular, fair value accounting is expected to provide investors with useful information to predict the capacity of firms to generate cash flow from the existing resource base. Fair value should therefore play a key role in reducing the information asymmetry between firms and investors, thus improving the quality of information. By adopting fair value accounting, the concept of income changes from income produced to mixed income, which also includes potential revenues. The concept of net capital is divested of its strictly juridical connotation and takes a more economic meaning. In fact, the introduction of fair value makes net capital converge toward its market value.
Fuller accounting policies and explanatory notes are also expected to play a key role in reducing information asymmetries and improving firm value. For instance, IAS 36 “Impairment of assets” includes, among the information to be provided for each class of assets, the amount of impairment losses recognized or reversed, the recoverable amounts, the values in use and the discounting rate used in their estimation. In any case, financial statement users have to be provided with information concerning the evaluation models being used, which are otherwise handled within the company and kept strictly confidential. IAS 37 “Provisions, Contingent Liabilities and Contingent Assets” requires detailed information about contingent liabilities such as the estimation of their financial effects as well as the uncertainties about the amount or timing of the resulting outflows. The disclosure required by IFRS 7 “Financial instruments: disclosures” with regard to financial instruments appears to be even more detailed. It consists of a considerable supply of information, ranging from basic issues such as the amount, the nature, and general conditions of each financial instrument, to information on fair value and on risk management policies, especially with regard to interest rate and credit risk. IAS 14 “Segment reporting” establishes principles for reporting financial information by segment, that is, information about the different types of products and services, a firm produces and the different areas in which it operates. As stated by IAS 14, the explicit objectives of such detailed information are “to help users of financial statements to better understand the firm’s past performance, to better assess its risk and returns and make more informed judgments about the firm as a whole” (IAS 14). As a consequence, with IAS/IFRS adoption, part of the information previously used exclusively for management control purposes is now given to the market in order to improve the quality of public information.
3. Main differences between european domestic gaap and IAS/IFRSRegulation 1606/2002 requires that, for each financial year starting on or after January 1, 2005, companies governed by the law of a member state prepare their consolidated accounts in conformity with IAS/IFRS if, on their balance sheet date, their securities are admitted to trading on a regulated market of any member state. The Regulator has also provided an option for member states to permit or require the application of international accounting standards in the preparation of annual accounts and to permit or require their application by unlisted companies.Prior regulation for listed companies in Europe was based on the fourth and seventh European Directives. The objective of the Directives was to harmonize financial disclosure, that is, to reduce the number of differences in accounting standards across the European Union member states. However, the Directives did not require that the same rules be applied in all member states, but that the prevailing rules were compatible with those in other member states. Given this flexibility, the implementation of the accounting Directives has differed from country to country.Domestic GAAP based on such directives are still in use in Europe for those firms and annual accounts that are not permitted or required to adopt IAS/IFRS.According to Regulation 1606/2002, the fourth and seventh European Directives could not ensure a high level of transparency in financial reporting, which is a necessary condition for building an integrated capital market that operates effectively and efficiently. This implies that requiring IAS/IFRS for listed companies is expected to improve the quality of financial reporting.The former chairman of IASB, Mr. Tweedie, explains the reasons underlying the switch from the European Directives to the IAS/IFRS as follows: “For too long, earnings have been smoothed in an effort to show investors a steady upward trajectory of profits. While this approach provides a simple and understandable model, it simply is not consistent with reality. Publicly traded companies are complex entities, engaged in a wide range of activities and subject to different market pressures and fluctuations. Accounting should reflect these fluctuations and risks (…) The current direction we are taking will be what I like to call, ‘tell it like it is’ accounting. This means an increasing reliance on fair values, when these values can be determined accurately.”As a matter of fact, the European Directives are more concerned with the protection of debt holders and mandate more conservative accounting methods. Under the Directives, prudence prevails over accrual, and historical cost is the basic criterion for financial reporting, whereas IAS/IFRS are more focused on equity investors and conceive financial reporting in a more dynamic way. They make large use of fair value accounting and require a fuller disclosure than the European Directives.Compared to the legalistic and politically and tax-influenced standards that have historically typified accounting in Europe, IAS/IFRS reflect more economic substance than legal form; they make economic gains and losses more timely, and curtail managers’ discretion in setting provisions, creating hidden reserves and smoothing earnings. IAS/IFRS require the entire liability to be on the balance sheet, all companies controlled, even when they carry out different activities, to be fitted within the consolidated area and to be consolidated line by line, and they require assets to be written at their fair value when this value can be determined accurately.In particular, fair value accounting is expected to provide investors with useful information to predict the capacity of firms to generate cash flow from the existing resource base. Fair value should therefore play a key role in reducing the information asymmetry between firms and investors, thus improving the quality of information. By adopting fair value accounting, the concept of income changes from income produced to mixed income, which also includes potential revenues. The concept of net capital is divested of its strictly juridical connotation and takes a more economic meaning. In fact, the introduction of fair value makes net capital converge toward its market value.Fuller accounting policies and explanatory notes are also expected to play a key role in reducing information asymmetries and improving firm value. For instance, IAS 36 “Impairment of assets” includes, among the information to be provided for each class of assets, the amount of impairment losses recognized or reversed, the recoverable amounts, the values in use and the discounting rate used in their estimation. In any case, financial statement users have to be provided with information concerning the evaluation models being used, which are otherwise handled within the company and kept strictly confidential. IAS 37 “Provisions, Contingent Liabilities and Contingent Assets” requires detailed information about contingent liabilities such as the estimation of their financial effects as well as the uncertainties about the amount or timing of the resulting outflows. The disclosure required by IFRS 7 “Financial instruments: disclosures” with regard to financial instruments appears to be even more detailed. It consists of a considerable supply of information, ranging from basic issues such as the amount, the nature, and general conditions of each financial instrument, to information on fair value and on risk management policies, especially with regard to interest rate and credit risk. IAS 14 “Segment reporting” establishes principles for reporting financial information by segment, that is, information about the different types of products and services, a firm produces and the different areas in which it operates. As stated by IAS 14, the explicit objectives of such detailed information are “to help users of financial statements to better understand the firm’s past performance, to better assess its risk and returns and make more informed judgments about the firm as a whole” (IAS 14). As a consequence, with IAS/IFRS adoption, part of the information previously used exclusively for management control purposes is now given to the market in order to improve the quality of public information.
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