Topic 4: Country-Specific Accounting Systems - COMPARISON Flashcards
(6 cards)
How do France and Japan compare in their historical accounting development?
Both countries adopted continental European models initially (France with its own system, Japan from Germany). Both experienced significant US influence (France through capital markets, Japan through post-WWII occupation). Both maintained dual systems distinguishing individual company accounting (tax-influenced) from consolidated/listed company reporting (more investor-focused).
How do France and Japan compare in their approach to IFRS?
Both have taken measured approaches to IFRS: France through EU mandatory adoption for listed consolidated statements only, Japan through voluntary adoption. Both maintain national standards for unconsolidated statements. France has accepted IFRS with occasional ‘carve-outs,’ while Japan developed modified standards (JMIS) as an alternative to full adoption.
How do enforcement systems compare between France, Japan, and Anglo countries?
Japan’s JFSA resembles the US SEC with strong proactive powers, reflecting US post-war influence. France’s AMF has significant powers including advance clearance. Both contrast with the UK’s traditionally more private-sector, lighter-touch approach through the FRRP, though all systems have strengthened enforcement following financial crises.
How does the tax-accounting relationship compare between France, Japan, and Anglo countries?
Both France and Japan maintain stronger tax-accounting connections than Anglo countries, particularly for unconsolidated statements. The French ‘connexité fiscale’ and Japanese ‘definite settlement’ principles create incentives for tax-driven accounting choices, whereas UK/US maintain greater separation between tax and financial reporting.
How do France and Japan contrast with Anglo-American systems in accounting philosophy?
Both traditionally emphasize: 1) Creditor protection over investor information, 2) Conservatism over fair presentation, 3) Legal compliance over economic substance, 4) Uniformity over flexibility, and 5) Individual company over group reporting. These shared characteristics place them in Class B (Continental) versus Class A (Anglo) in Nobes’ classification despite their geographic distance.
How have accounting classifications grouped France and Japan?
Most classifications place France and Japan in similar groups despite geographic separation. Nobes (1983) grouped them as ‘macro-uniform’ systems, reflecting similar legal, tax, and financing influences. This demonstrates how institutional factors rather than geographic proximity determine accounting similarities, supporting the institutional explanation for accounting differences.
