Used in the UK; Australia; Canada; Cyprus; Netherlands; USA. It is characterized by orientation accounting For the needs of investors and creditors of the enterprise. This model is possible in countries with a highly developed market of securities, with a high professional level of accountants, with a large number of large corporations. This model is very flexible, is not regulated by non-government agencies, but standards that are developing professional organizations of accountants.
Continental
It uses European countries with a developed market economy: Australia; Greece; Egypt; Italy; France; Germany; Switzerland; Sweden; Japan and D.R. The following elements are characterized for it:
- Detailed Legal Regulation of Accounting and Reporting
- orientation of accounting and reporting for interests tax authorities
- big dependence on bank lending
This model is distinguished by the tough accounting regulation at the state level.
Latino American
Argentina; Brazil; Peru; Chile and D.R.
Accounting and reporting of these countries are focused on government planning requirements. State authorities affect the unification of reporting companies. The relative economic backwardness of these countries puts tax requirements predominant.
In fulfillment of the accounting reform program in accordance with international financial reporting standards, approved by the Decree of the Government of the Russian Federation of March 6, 1998 No. 283, and the orders of the Government of the Russian Federation of March 21, 1998. No. 382-P in Russia is a permanent work on improving the system of legal and methodological management of accounting, based on the maintenance of a four-level system of regulatory documents.
FROM regulatory base The concept of accounting in the transition to the market economy of Russia, approved by the Methodological Council on Accounting at the Ministry of Finance of Russia and the Presidential Council of the Institute of Professional Accountants in December 1997, in which the principles of construction were formulated russian system Accounting for the next ten and fifteen years.
The purpose of the reform:lead national System in line with the requirements market economy and IFRS.
Tasks of reform:
1. Build a system of accounting standards and reporting.
2. Ensure intercommunication of the accounting system in Russia with IFRS.
3. To provide methodological assistance to organizations for the transformation of their accounting.
To achieve these tasks, you need:
- Improve the legislation of the Russian Federation for accounting;
- to form a system of national standards;
- Prepare high professional accountants;
- Actively work in international organizations, adopt their experience.
At this stage, the following tendencies of the transformation of the accounting process are observed.
The importance of international financial statements (IFRS) and development procedures
1. Characteristics of existing accounting models.
2. The procedure for the development and implementation of IFRS.
3. Using IFRS in the Russian accounting system.
1. Characteristics of existing accounting models
There are a large number of accounting models in the world. Their differences are caused by both historical, political, economic and geographical conditions in which enterprises are functioning different countries.
Thus, in countries with a large number of investors and creditors, the composition of which is quite diverse, and the owners of the companies are increasingly separated from operational management, financial and duty is the most important source of data on the company's welfare. In these countries (United Kingdom, United States), financial statements aims to inform the information needs of investors, creditors and is distinguished by significant analyticality. In other countries (Switzerland, Germany, Japan), financial policy is determined by a small number of very large banks that satisfy a significant part of business needs. The information necessary to substantiate additional financial investments is formed in the process of direct contacts of stakeholders. In this case, reporting is aimed at protecting the interests of banks of creditors. Financial statements here less detailed and compiled taking into account the principles of conservatism in assessing assets. In countries where governments play a decisive role in managing national resources, (France, Sweden) accounting Focusing on the needs of state planners. Firms are forced to follow rigid standards in the field of accounting and reporting.
The accounting system of the country may depend on its international socio-economic relations. Accounting technologies are exported and imported. So the United States has a significant impact on the accounting practice of Canada, thanks to geographic proximity and close economic relations. Also, American accounting standards are widely used in Japan, which is explained by the expansion of Japanese capital to America. A significant impact on the development of theory and practice of accounting in their former colonies is the United Kingdom (Metropolia). Among them are Australia, New Zealand, Malaysia, India, etc.
There is an approach, according to which all countries, depending on the type of legislation and the extent of its impact on the practice of conducting accounting, are divided into two groups:
having branched code of laws
having overall orientation legislation
In the first case, laws are harshly deterministic in nature, representing, in fact, a series of prescriptions - "You must". Accounting standards are built into the rank state lawsAnd the procedures for conducting accounting are detailed and sufficiently guess are regulated. The main task of accounting in these countries - calculation state taxes And control over their full payment. Among these countries - Argentina, France, Germany (in accordance with Art. 71 of the Constitution of the Russian Federation, the rules of accounting are established by the state).
The second group of countries is limited to the Code of Law common lawrepresenting a series of restrictions - "You should not". The laws of this type indicate the limits within which the enterprise operates. Accounting standards in these countries are not regulated by the state, but are determined by professional accountants. These standards are more flexible and affected by various innovations.
Taking into account all the conditions of the accounting system in different strange, 4 models of accounting are allocated.
British-American - based on the satisfaction of the information needs of small and medium investors in the conditions of highly developed stock markets. It is characterized by the maximum degree and quality of information disclosure, as well as a relatively low degree of state intervention. This model uses United Kingdom, USA, Netherlands.
Continental model - Banks are the main investors. This model adheres to most European countries - France, Germany, Denmark, etc., as well as Japan. The business of these countries is closely associated with banks that satisfy the main financial requests of companies. Accounting is regulated by law and is distinguished by significant conservatism.
South American model - Clearly oriented on the needs of the state, primarily tax. For the countries of this model, a large unified and smaller complexity of reporting, as well as developed mechanisms for accounting inflation are characterized. Used in the countries of the Southern Continent of America - Argentina, Brazil, Chile, Uruguay, etc.
Islamic model - It is used by countries such as Turkey, Iran, Pakistan, etc. They build their legislative systems under the influence of theological ideas. So, since the Quran is prohibited by usurism, the reporting documentation cannot show the mechanism of financial non-dealercy. At the same time, resources and debts of companies are taken into account at market prices.
Continental model
The experts of continental Europe and Japan are considered by the experts of this model. Here the specificity of accounting is due to two factors: business orientation on large bank capital and compliance with the requirements of fiscal bodies. Attracting investments is carried out with the direct participation of banks, and therefore the financial statements of companies is intended primarily for them, and not for the participants of the securities market. In the continental model, a significant impact on the procedure for compiling reports state bodies. This can be explained by the priority of the task of the state to collect taxes. Basically, the country with this model is also guided by the principle of unchanged initial assessment. Russia refers to the continental accounting model, Germany and France also had a certain influence on our accounting.
This model is used: Austria, Algeria, Angola, Belgium, Burkina Faso, Côte d "Ivoire, Guinea, Germany, Greece, Denmark, Egypt, Zaire, Spain, Italy, Cameroon, Luxembourg, Mali, Morocco, Norway, Portugal, Russia, Senegal, Sierra Leone, Togo France, Switzerland, Sweden, Japan.
For example, a system for regulating accounting and auditing in France is significantly different from the British-American model.
The foundation of the accounting and audit system in France is the Commercial Code (Code de Commerce), the legislatively enshrine the need for accounting and reporting. The key link of this system is the National accounting Code National Accounting Code is more famous as Plan CompTable General). This fundamental document contains more than 400 pages and includes a single account of accounting accounts. The Code in France performs the same functions that standards in the UK, its tasks are closely related to the tasks of national statistics and taxation. The development of this document and the necessary methodological guidelines to it was assigned to the National Council on Accounting (CNC) created in 1947 (CNC), who had the status of a government agency.
Germany has a long-standing tradition of accounting, which has influenced the formation of accounting in pre-revolutionary Russia. The legislative framework of accounting and reporting in Germany is the Trade Code, which, along with other issues, regulates reporting issues; It addresses in detail the rules regarding the content and preparation of balance and income statement. In Germany, there is a single billion plan, on the basis of which sectoral plans for industry, trade, financial institutions have been developed.
A great impact on accounting and reporting in Germany has tax lawpractically prohibiting use tax benefitsIf they did not find reflections in accounting.
Due to the absence of officially formulated generally accepted in Germany accounting principles Many controversial issues of reporting and credentials are solved in court. The development of recommendations on accounting and reporting that are not compulsory, but nevertheless taken into account in the development of legislation, the Institute of Accountants is engaged in the Institute (Institut Der WirtschaftSpufer), created in 1931
If you try to rank various German sources governing accounting and reporting issues, then the following documents can be distinguished by significance:
1) commercial regulations;
2) tax legislation;
3) tax instructions;
4) accounting materials;
In German legislation, much more attention is paid to information about the activities of companies, i.e. reporting than accounting organizations. In the book, Y. Bethe "Balancing" provides the following definition of reporting: "Reporting is a reflection of entrusted capital in the sense that external reporting users are reflected, as well as its compiler, they get so complete, clear and relevant idea of \u200b\u200bthe economic activity of the organization, which can To make our own judgment about the managed property and obtained with its help. "
Also, Italy is rightfully considered to be home to accounting, since at the end of the XV century. Franciscan monk-mathematician Luka Pacheli formulated the principles of a double entry in his "Treatise on accounts and records", published in Venice in 1494. However, in the future, the leadership of Italy in the development of accounting was lost.
The legislative basis of the Italian accounting system is Civil Code, as well as the decrees of the President of the Republic and the orders of the Ministry of Finance, containing the recommendations of professional organizations.
Italy has a professional organization - the National Council of Commerce and Accounting Specialists (Consiglio Nazionale Dei Dottori Commercialisti E Dei Ragionaieri - CNDCR), publishing accounting standards that differ in very wide intercomposition. However, these standards are used by the Italian National Commission on Exchange - Consob (Commissione Nazionale Per Le Societa E La Borsa is an analogue of the American SEC). This Commission has an impact on the reporting joint-stock companieswhose shares are quoted on the stock exchange.
In the Netherlands, as in the UK, legislation on companies and professional organizations, and not tax legislation or the requirements of the stock market, were greatly influenced by accounting and reporting. Prior to adoption in 1970, the Issues of Accounting and Reporting Organizations in the Netherlands were practically legally regulated in the Netherlands. The provisions of this law were later included in the Civil Code and are submitted in line with EU directives. At the direction of the Government (1970), an accounting instructions for accounting on accounting annual reporting, which included employers and employees, as well as accounting specialists.
Companies should not obligatory To follow its instructions that are regarded only as the opinions of an influential private group, and the auditors are not obliged to state the facts of non-compliance with the recommendations of the Council.
Tax legislation, as well as requirements stock ExchangeIt has only an indirect effect on accounting in the Netherlands.
Latin American model
With the exception of Brazil, the state language of which is Portuguese, these countries combines a common language - Spanish, as well as the common past. The main difference of this model from the above is permanent adjustment of the impact of credentials to inflation rates. Accounting for inflation is carried out in Latin American countries, and Argentina, Brazil, Uruguay and Chile introduced inflation rate and national legislation. In these countries, the official general price index is used as the main correction index, on the basis of which data on share capital and basic (non-current) funds are recalculated, commodity-material reserves are overestimated by rehabilitation cost. Obligations B. foreign currency Recalculated at the exchange rate at the end of the reporting year.
In general, accounting is focused on the needs of government tax and planned bodies, and the metering methods used in enterprises are rather unified.
State bodies in these countries practically regulate the metering methodology. Professional accounting organizations do not have any significant impact on the methodology and accounting practice.
The South American model is used by: Argentina, Bolivia, Brazil, Guyana, Paraguay, Peru, Uruguay, Chile, Ecuador.
Thus, in countries with similar socio-economic conditions and accounting systems have a lot in common.
In the USA, Great Britain, the Netherlands used "British-American" model of accounting, which is focused on the needs of investors and creditors of the company. From a technical point of view, it is most liberal - each company generates an account plan independently, there is no uniform approved numbering of accounts. At the same time, there are general requirements for the organization of accounting, described by the "generally accepted accounting principles" system (General Accepted Accounting Principles - GAAP). Such requirements are produced by professional accountants associations.
In France, Germany, Japan and some other countries, an "continental model" is used, oriented to the needs of tax authorities. It is more formalized, since it relies on a single state-approved billion plan.
In countries with a high rate of inflation, the "Latin American model" is used, which is characterized by a constant adjustment of indicators for inflation rates.
Accounting systems of different countries differ significantly. The causes of such differences are both socio-economic and political and geographical factors. As socio-economic reasons, it is possible to distinguish the nature of the development of capital markets, the number of investors and lenders, participation in international capital markets, the level of inflation, the size and organizational structure of enterprises, the overall level of education, the types of legislative systems. Traditionally, in Germany and the United Kingdom, securities markets have been widely developed, the main suppliers of capital for companies are a large number of small investors who need permanent and complete information on the activities of the firms they receive with the help of financial statements. In Germany and France, the needs of the companies in capital are compiled mainly by a small number of large banks that have access to additional (in addition to the information contained) information on enterprises. In France and Sweden, a large role in the economy and, accordingly, the state is played in the financing of companies, which implies the orientation of the accounting and reporting system to meet the requirements of state bodies. One of the criteria for division can be the level of inflation: countries, therefore, are divided into having a high and low level of inflation. First include, primarily the countries of South America. In order for the information contained in the financial statements, it has been useful for users, it must be adjusted to inflation indices. For C. C. low level Inflation such a problem is not relevant. By virtue of the high level of development of the economy in the UK, the Netherlands, Germany and others developed countries Enterprises of these countries differ rather large sizes, complex organizational structure and high level of education of employees. This leads to the complexity of accounting information, which adequately reflects the existing economic reality and is adequately perceived by users. In the underdeveloped countries, the accounting systems are quite simple, due to the small size of the enterprises and the low level of general education.
Figure 1- diagram of the main characteristics of classical accounting models
The historical development of legislative systems also had a great influence on the accounting systems. Countries are usually divided into two large groups: legislator countries (Code-Law Countries; Legalistic Orientation) and illegtector countries (Common-Law Countries; Non-Legalistic Orientation). The first differences in the prescription of the laws on the principle: "Allowed what is allowed. By virtue of this, the accounting rules are rigidly regulated and are determined by law. These countries include, for example, Germany, France, Austria and others. For countries of illegtector, a permitting approach is characterized by the principle: "It is allowed that it is not prohibited." Accordingly, the accounting systems are distinguished by greater multivariance and flexibility, they are usually the outlined framework in which enterprises are given freedom of choice. Accounting rules or standards are not determined by law, but are developed by professional accountants organizations. This approach is used in the UK, France and a number of other countries.
Accounting systems can be exported as well as any other products. The impact of the accounting rules of one country to the accounting rules of the other may be due to political or economic dependence, geographic proximity.
1. British-American model (United Kingdom, USA, Netherlands, Canada, Australia, etc.).
2. Continental model (Germany, Austria, France, Switzerland, Italy, etc.).
3. South American model (Brazil, Argentina, Bolivia, etc.).
2. British American accounting model
The main characteristics of the first model are the orientation of accounting for the needs of a wide range of investors, due to the highly developed securities market; The lack of legislative regulation of accounting, which is governed by the standards developed by professional accountants' organizations; the flexibility of the accounting system; High educational level both accountants and users financial information. The second model is distinguished by the presence of legislative accounting; close connections of enterprises with banks that are the main suppliers of capital; orientation of accounting for state needs of taxation and macroeconomic regulation; conservatism accounting practice. And, finally, the main feature of the third model is the orientation of the accounting methodology for the high level of inflation and the needs of state regulation.
The British-American model is an exceptional self-regulation of accounting. The state formally does not direct accounting practice. This accounting system is developing by various professional accountants associations, flexible accounting standards (they are developing on the basis of accumulated experience, arguments, etc.). The basis of this model is the system of legislation of the overall orientation (the laws of general law, it is allowed that it is not prohibited). Such legislation does not regulate the life of physical and legal entities, and sets the boundaries of freedom of action. Distributed in the USA, England, Holland, etc. The main body engaged in the publication of accounting standards is the Board on Standards financial accounting (FASB). The main goal of the Council is the development and improvement of accounting standards intended for use in the private sector of the economy, auditors and accounting reporting users.
The Council is independent. Independence is ensured that the observation of the activities of the Council is carried out by the Financial Accounting Foundation. In addition to the Council, the Council was formed on accounting standards in public institutions. In parallel with this advice regulation of accounting practices, the Government Organization of the Commission on securities and stock exchanges (presentation and protection of investors' interests in accordance with the Securities Act).
The totality of the norms regulating financial accounting forms generally accepted accounting standards (GAAP). These methods proceed from the priority of the needs of external users of financial statements. Applied by many private companies. Although for many private companies does not exist mandatory audit etc., they often adhere to these generally accepted norms.
3. Continental model of European accounting
Continental model - Legal regulation of accounting, unification of the principles and procedures of accounting (Germany, France, Spain, etc.).Continental essentially conservative model formed on classical accounting principles, with state regulation, orientation for requirements tax accounting and capital movement through banking system. Here the accounting standards have status of state acts. This approach is largely generated by the action in these countries of the Codes of laws, administrative and permits are established legal regulation (strictly by the letter of the law).
Gradually, the country included in the overall market will achieve freedom of movement of goods, labor, etc. Secondary legislation is formed by the European Commission. It forms a number of documents. Directives:
1. Through the EU directive in 1978 was adopted, and it proposes recommendations on the formation of annual reporting of joint-stock commune commander societies, LLC. Feature:
4 options for balance and 2 options for income statement and loss are offered;
The rules for evaluating certain types of property are given;
Balance and profit and loss statement is complemented by a report on the financial position of the Company;
2. EU directive. Regulates the preparation of free consolidated reporting.
4. The system of international standards.
Committee of PO international standards - Authority heading the process of standards development (1974)
Currently there are about 40 standards, a cat. Regulate various aspects of accounting and reporting.
A number of standards are aimed at standardization of fixed assets. intangible assets, investment activities. They are almost completely covered by the corresponding PBUs.
A whole group of standards is devoted to the accounting of the laws of the organization, accounting for revenues.
Analysis of both models reveals the main features modern Systems Regulation of accounting. The purpose of regulating accounting is most accurate and fully formulated by the UN International Group: providing accessible and comparable information, including non-financial information, the provision of true and objective financial status, income and losses in financial statements.
In most countries, accounting regulation is focused on financial statements (accounting principles, assessment methods, information circle in reporting, etc.).
BIBLIOGRAPHY
Strettle F. Daily Structures: Possible and Impossible. - M., Progress, 1986.
Ivanov Yu.V. Basics of national office. M., 2003.
Malkova T.N. Ancient Accounting: What was she? M., Finance and Statistics, 1995
Seslavsky I. Azbuk Accounting. - M., Moscow worker, 1962.
Sokolov Ya. V. Luka Pacheti and his time: the formation and development of accounting. M., 1983.
Sokolov Ya.V., Sokolov V.Ya. History of accounting. M., 2003.
Sokolov Ya.V. Essays on the history of accounting. - M.: Finance and Statistics, 2001.
Hendrixen E.S., M.F. Van Breda. Accounting theory. - M.: Finance and Statistics, 2000.
Tsygankov K.Yu. Essays of accounting history: the origin of dual accounting: Tutorial For universities. M., 2004.
International accounting models Features of the organization of accounting in budget organizations
National principles governing accounting are essentially vary. But it is possible to highlight groups of countries that adhere to the same type approaches to building the accounting system, while there are no two states, where accounting rules would be absolutely identical.
The need for classification of accounting models is as follows:
Classification assists a more accurate definition of similarities and differences between countries and accounting systems;
Classification assists the choice of the system, which is most suitable for the country;
Classification provides the ability to choose a country-an example to form a specific type of accounting system.
The most generalized models of the classification of accounting accounting are:
1. British-American (Anglo-Saxon) model Orientation to information requests for investors. For the functioning of this model in the country should be developed stock marketAnd companies do not have the right to overestimate investment attractivity (profit). For this model, firm reg-lamentation of accounting is uncharacter. This model in most countries involves the use of accounting principles at the initial cost.
Most industrial enterprises The Anglo-Saxon Group of the Group use a permanent accounting system for stocks, which is based on continuously registering them (that is, all current changes in raw materials, work in progress and finished products Displays the accounts of the corresponding reserves).
The basis for the allocation of accounts to account for the cost of the enterprise in this system is a functional feature. For this, the "Production", "Production Overheads", "Sales" and "General Administrative Costs" apply. The first two accounts displays the costs associated with production. Straight production costs Displays directly on the "Production" account, and the indirects accumulate in the "Production Overheads" account, and at the end of the reporting period are written off at the expense of "Production" and are distributed between calculation objects.
The costs of units that carry out non-manufacturing functions (management, sales, etc.) are not included in the production cost of products. These costs are written off at the expense financial results therein reporting periodin which they were implemented.
This model is typical for countries such as USA, Canada, Netherlands, Australia, Bahamas, Barbados, Benin, Bermuda, Botswana, Venezuela, Ghana, Hong Kong, Dominican Republic, Zambia, Zimbabwe, Israel, India, Indonesia, Ireland, Cayman Islands, Kenya , Cyprus, Colombia, Liberia, Malawi, Ma Lysia, Mexico, Nigeria, New Zealand, Pakistan, Panama, Papua New Guinea, Puerto Rico, Singapore, Tanzania, Trini Dad and Tobago, Uganda, Fiji, Philippines, countries Central America, South Africa, Jamaica.
2. Continental (Franco-German, or European) Mo del Characteristic to European countries in which there are close connections of companies with banks and the state. These countries have a harsh tax policy, so the accounting system is characterized by significant conservatism.
In the continental model, government agencies have a significant impact on the procedure of co-pointing reporting. It is moled - but to explain the priority of the task of the state to collect the nano-gov. Basically, the country with this model is also guided by the principle of the invaluance of the initial assessment. For this metering model, it is characteristic of the allocation of two autonomous accounts of accounts, respectively, for the purposes of financial and managerial accounting.
In the system of financial accounting accounts, periodic stocks of stocks are carried out, the costs are grouped by elements (materials, salary, depreciation, etc.), and the models of income - by type of activity (basic, financial, emergency), the calculations with debtors and creditors are displayed. The general fi-malna result is determined.
In the system of accounting accounting accounts, there is constant accounting of stocks, the cost of production costs and accounting for the centers of responsibility is calculated, the financial results of the main activity of the enterprise are determined.
Financial and managerial accounting accounts will not correspond with each other. The relationship between them is achieved with the help of special (display) accounts ("displayed reserves", "from-shown purchases", "displayed costs", etc.). These accounts are unsystematic (without accounting records) Financial accounting data on costs and reserves, which are then rearranged for managerial accounting purposes.
This model is characteristic of countries such as Austria, Spa-Nia, Italy, Denmark, France, Germany, Japan, Switzerland, Sweden, Egypt, Luxembourg, Mali, Morocco, Norway, Porto Galia, Russia, Belgium, Algeria, Angola, Burkina -Fafaso.
3. South American model. The key impact on the level of accounting in South American countries was inflationary processes. Therefore, the distinctive characteristic of this model is the method of adjusting reporting indicators, taking into account the change in the overall level of prices. Inflation Amendment is necessary to ensure the accuracy of current financial information (especially in relation to long-term assets). Correction of OT-parity is focused on the state's needs for the execution of the budget revenue.
The South American model is used in countries: Argentina, Bo-Libya, Brazil, Guyana, Paraguay, Peru, Uruguay, Chile, Ecuador.
In addition to the listed models, some countries use mixed systems with national specifics. For example, specialists allocate an Islamic model that developed under the strong influence of Muslim religion.
Islamic model Developed under the influence of theological ideas, in accordance with which the receipt of financial di-visions is prohibited for their own profits (Iraq, Iran, Afghanistan, Pakistan).
