Accounting legislation in different countries. Procedure for maintaining accounting records abroad

Accounting principles are established by law. Accounting is focused more on government control.

The first model of the accounting system is focused on the information needs of a wide range of users. This model, as a rule, does not imply strict legislative regulation of accounting. Issues of its establishment and maintenance are resolved independently by each organization, based on established standards.

Standards define generally accepted rules and regulations within which a particular enterprise is given freedom to make decisions. This ensures the flexibility of the accounting system and requires a high level of education not only for accountants, but also for users of accounting information.

Standards ensure comparability of companies' reporting documentation, its uniformity, facilitate its verification and accessibility for users. They are developed by professional organizations, but not by government ones.

Under the conditions of application of such a model, information and the accounting system are divided into financial and managerial.

Financial accounting is governed by standards. Its data is summarized in financial statements intended for a wide range of external users. Thus, compliance by all organizations with the general methodological principles of accounting is achieved, obtaining objective, comparable information necessary for its users to make informed decisions.

The accounting system within the first model has features for each country.

In England, the basics of financial accounting are enshrined in law. But they are supplemented by financial accounting principles established by non-governmental organizations and accounting and reporting associations. National accounting and reporting standards in England are developed by the Accounting Organizations Advisory Committee.

Under his command:

- Audit Committee, which develops auditing standards and instructions for them;
- Accounting Standards Committee, which develops documents on standard accounting principles.

National accounting and reporting standards are called “Accounting Standards and Principles Documents” in England.

The UK has the oldest professional accounting organizations, established in the last century, such as the Institute of Chartered Accountants of Scotland, the Institute of Chartered Accountants of England and Wales, founded by decree of the Queen in 1894. These organizations have a long history of regulating accounting and developing their own national accounting standards, which these organizations began to implement even before the advent of the first IFRS. They are independent, not subordinate to any government bodies and are actively working to develop accounting and reporting methodology and train audit personnel. The development of accounting standards in the UK began back in 1969.

However, although many British and International Standards (IFRS) have similar names and address common problems, they address them differently. And large international British companies are forced to reform their reporting in accordance with international standards in cases of raising capital on international markets and listing shares on stock exchanges in other countries.

To date, differences between British and international standards have remained, in particular in relation to the accounting and valuation of fixed assets, investments, financial instruments, research expenditures, inventories, construction contracts, assets and liabilities in foreign currency, expenses on loans, as well as income recognition, pension contributions and preparation of consolidated statements. The most obvious differences between British and international standards are in approaches to the valuation of various assets, primarily fixed assets.

The accounting and auditing regulatory system in France differs significantly from the Anglo-Saxon model.

The foundation of the accounting and auditing system in France is the Commercial Code, which legislates the need for accounting and reporting. The key element of this system is the National Accounting Code, better known as. This foundational document contains more than 400 pages and includes a unified chart of accounts. The Code in France performs the same functions as the 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 instructions for it was entrusted to the National Accounting Council, created in 1947 under the French Ministry of Finance, which had the status of a government agency.

Germany has a long tradition of accounting, which influenced the formation of accounting in pre-revolutionary Russia. The legislative basis for accounting and reporting in Germany is the Commercial Code, which, along with other issues, regulates reporting issues; it discusses in detail the rules regarding the content and preparation of the balance sheet and profit and loss account. In Germany, there is a unified chart of accounts, on the basis of which sectoral plans have been developed for industry, trade, and financial organizations. Tax legislation has a huge impact on accounting and reporting in Germany, practically prohibiting the use of tax benefits if they are not reflected in accounting.

Due to the lack of formally formulated generally accepted accounting principles in Germany, many controversial reporting and accounting issues are resolved in court. The Institute of Accountants, established in 1931, develops recommendations on accounting and reporting that are not mandatory, but are nevertheless taken into account when developing legislation.

If we try to rank various German sources regulating the issues of accounting and reporting, then in order of importance we can distinguish the following groups of documents:

1) commercial regulations;
2) tax legislation;
3) tax instructions;
4) materials of accounting practice;
5) recommendations of professional organizations.

In German legislation, much more attention is paid to information about the activities of companies, i.e., reporting, than to the organization of accounting. J. Bethge’s book “Balance Sheet” provides the following definition of reporting: “Reporting is a reflection of entrusted capital in the sense that external users of reporting, as well as its compiler, receive such a complete, clear and relevant picture of the organization’s economic activities that they can make your own judgment about the property being managed and the result obtained with its help.”

Italy is rightfully considered the birthplace of accounting, since at the end of the 15th century, the Franciscan monk-mathematician Luca Pacioli formulated the principles of double entry in his “Treatise on Accounts and Records,” published in Venice in 1494. However, in the future, Italy’s leadership in the development accounting records were lost.

The legislative basis of the Italian accounting system is the Civil Code, as well as decrees of the President of the Republic and orders of the Ministry of Finance, including recommendations of professional organizations.

In Italy, there is a professional organization - the National Council of Commerce and Accounting Specialists, which issues accounting standards that have a very broad interpretation. However, these standards are used by the Italian National Exchange Commission - CONSOB. This Commission influences the reporting of joint stock companies whose shares are listed on the stock exchange.

In the Netherlands, as in the UK, accounting and reporting have been largely influenced by company law and professional bodies rather than by tax law or stock market requirements.

Before the adoption of the law on the reporting of organizations in 1970, issues of accounting and reporting in the Netherlands were practically not regulated by law. The provisions of this Law were later included in the Civil Code and subsequently brought into line with EU directives. By order of the government (1970), the Annual Reporting Council was created to issue accounting guidance, which included employers and employees, as well as accounting specialists.

Companies are not required to follow its guidance, which is regarded only as the opinion of an influential private group, and auditors are not required to report non-compliance with the Board's recommendations.

Tax legislation, like stock exchange requirements, has only an indirect impact on accounting in the Netherlands.

1. On the transition of Ukraine to a system of accounting and statistics generally accepted in international practice: Decree of the President of Ukraine dated May 23, 1992 No. 303.

2. Bernstein L. A. Analysis of financial statements: theory, practice and interpretation: Transl. from English / Ed. prof. Y. V. Sokolova. - M.: Finance and Statistics, 1996. - 624 p.

3. Blake J., Amat O. European accounting: Handbook: Trans. from English - M: Information and Publishing House "Filin", 1997. _400 p.

4. Efimova F, F., Goretskaya L. L. Accounting in foreign countries: Textbook. allowance. - Zhytomyr PE "Ruta", 2002. - 544 p.

5. Introduction to accounting: Transl. from English - M.: Trade and Publishing Bureau BHV, 1994. - 384 p.

6. Welsh Glen A., Short Daniel G. Fundamentals of financial accounting: Transl. from English - K.: Fundamentals, 1997. - 943 p.

7. Wood Frank. Accounting for entrepreneurs. - In 4 volumes. - NL: Askeri, in 1996.

8. Galuzin S. M., Pupshis T. F. International accounting and audit. - St. Petersburg: Peter, 2006. - 272 p.

9. Goloe S. F. Management accounting: Textbook. - M.: Libra, 2003. -704 p.

10. Golov S.F., Efimenko V.I. Financial and management accounting. - M.: Comrade. "Autointerservice", 1996. - 544 p.

11. Golov S. F., Kostyuchenko V. M. Accounting according to international standards: examples and comments: Practical guide. - M.: Libra, 2001. - 840 p.

12. Golov S. F., Kostyuchenko V. M. Accounting and financial reporting according to international standards: A practical guide. - M.: Libra, 2004. - 880 p.

13. Gray Sydney J., Needles Beleerd E. Financial accounting: a global approach: Educational method. manual: Transl. from English - M.: Wolters Kluwer, 2006. -614 p.

14. Gubacheva A. M. Accounting in foreign countries: Textbook. allowance. - M.: NMD Ukooposvita, 1999. - 226 p.

15. Gubacheva A. N. International principles of accounting: Text of the lecture. - Poltava: PKI, 1997. - 30 p.

16. Gubacheva A. N. System and technology of financial accounting in the UK and the USA: Text of the lecture. - Poltava: PKI, in 1999. - 14 p.

17. Gubacheva A. M. Financial reporting according to international standards: Text of the lecture. - Poltava: PKI, 1998. - 25 p.

16. Drury K. Management and production accounting: Textbook: Trans. from English - M.: UNITY-DANA, 2002. - 1071 p.

19. Efimenko V. Lukyanenko L. I. Accounting in foreign countries: Textbook, manual for self-employed people. studied Disc. / Ed. V. I. Efimenko. - K / .KNEU, 2005. - 211 p.

21. Karlin T. G., Makmin A. G. Analysis of financial statements (based on GAAP): Textbook. - M.: INFRA-M. 2000. - 448 p.

22. Kachalin V.V. Financial accounting and reporting in accordance with GAAP standards. -3rd ed. - M.: Delo, 2000. - 432 p.

23. Compendium / Tacis Project of the European Union "Training program in accounting in Ukraine". - M.: Delegation of the European Commission to Ukraine, Moldova and Belarus, 2004. - 136 p.

24. Kocherga S.V., Pilipenko K.A. Accounting in foreign countries: Textbook. allowance. - M.: TsNL, 2005. - 216 p.

25. Luchko M.R., Benko 1.D. Accounting in foreign countries: Textbook. allowance. - M.: Knowledge, 2006. - 311 p.

26. Malyarevsky Yu. D., Fartushnyak O. V., Peschanka and Yu. Accounting in foreign countries: Textbook. allowance. - Kharkov: Publishing house "IN-ZHEK", 2003.- 164 p.

27. International Financial Reporting Standards / Ed. L. A. Gorbatova. -M.: Wolters Kluwer, 2006. - 544 p.

28. Melnik S.I. Accounting for investments in securities and consolidated statements: Text of the lecture. - Poltava: RIO PUSKA, 2003. - 27 p.

29. Melnik S.I. Financial reporting of enterprises of the Russian Federation: Text of the lecture. - Poltava: RIO PUSKA, 2004. - 28 p.

30. Meskon M. X., Albert M., Khedouri F. Fundamentals of Management: Transl. from English - M.: Delo, 1992. - 702 p.

32. International Accounting Standards 2000 / Transl. from English edited by S. F. Head. - M.: FPBAU, 2000. - one thousand two hundred seventy-two p.

33. International accounting standards 2001: changes and additions / Transl. from English edited by S. F. Head. - M.: FPBAU, 2001.-224 p.

34. Middleton D. Accounting and financial decision making: Transl. from English - M.: Audit, UNITY, 1997. - 408 p.

35. Muller G., Gernon X., Mink G. Accounting: international perspective: Transl. from English - M.: Finance and Statistics, 1996. - 136 p.

36. Natdovska L.V. Management accounting: Textbook. for students higher textbook closing - M.: Book, 2004. - 544 p.

37. Needles B., Anderson X, Caldwell D. Principles of accounting: Transl. from English / Ed. Y. V. Sokolova. - Second ed. - M.: Finance and Statistics, 1996. - 49bs.

38. Pankov D. A. Accounting and analysis in foreign countries: Textbook. allowance. - Minsk: IP "Ecoperspective", 1998. - 238 p.

39. Accounting Manual / European Union Tacis Project "Accounting Curriculum in Ukraine". - M.: Delegation of the European Commission to Ukraine, Moldova and Belarus, 2004. - 554 p.

40. Puchkova S.I., Novodvorskt V.D. Consolidated reporting: Textbook. Manual / Ed. N.P. Kondrakov M.: FBK-Press, 1999.-224 p.

41. Regulation in the field of accounting and auditing in the EU and prospects for adapting the legislation of Ukraine / A. Velichko, S. Golov, S. Zubilevich and others; According to science. ed. S. Head. - M., 2003. - 584 p.

42. Solovyova O. V. Foreign standards of accounting and reporting: Textbook. allowance. - M.: Analytics-Press, 1998. - 288 p.

43. Terekhova V. A. International and national standards of accounting and reporting: A practical guide. - M.: Perspective; AKDI "Economics and Life", 2000. - 302 p.

44. Tkach V.I. Tkach M, V. Management accounting: international experience. - M.: Finance and Statistics, 1992. - 160 p.

45. Management Accounting: A Textbook / Don R. Hansen, Marian M. Mouven, non-white S. Elias, David V. Senkov; Per. from English from the 5th Canada. ed.; Sci. ed. N.P. Krasnik. - M.: Millennium, 2002. - 974 p.

46. Financial accounting 1: Textbook. CGA materials: Per. from English / By Tilly Jensen. Northern Alberta Institute of Technology, Canada. - Dnepropetrovsk: Balance Business Books, 2006. - 952 p.

47. Hendriksen E. S Van Breda M.F. Accounting theory: Translated from English. / Under. ed. Y. V. Sokolova. - M.: Finance and Statistics, 1997. _ 576 p.

48. Horngren C. G., Foster J. Accounting: management aspect: Transl. from English / Under. ed. Y. V. Sokolova. - M.: Finance and Statistics, 2005 - 416 p.

49. Anthony R., Fig. J. Accounting: situations and examples: Trans. from English / Ed. A. M. Petrachkova. - second ed., Stereotype. - M.: Finance and Statistics, 1996. - 560 p.

50. Bahr Gottfried. Buchfuhrung und Jaresabschlu / Gottfried Bahr: Wolf F. Fischer- Winkelman (Unler Mitarb. Von Jorn Brandstatter) - 4., uberarb. und erw. Auft. - Wiesbaden: Cabler, 1992. - 548 p.

51.Glautier MWE & Underdown D. Accounting Theory and Practice. - 4th Edition, 1992.

52. Horngren S. T., Foster G., Datar SM Cost Accounting: A Managerial Emphasis. - 10th Edition, Prentice Hall, Inc., 2000.

53. Kieso D. E "Weygandt JJ, Warfield TD Intermediate Accounting. - 10th Edition. John Wiley & Sons, Inc., 2001.

Bashkir Academy of Public Service and Management under the President of the Republic of Bashkortostan

Department of professional retraining

“Evaluation of the value of an enterprise (business)”

Coursework on the subject “Accounting and Auditing”

On the topic: “Accounting in foreign countries”

Completed:

Abubakirova N.N.

Checked:

Art. department ave.

“Accounting

and audit” USPTU

Kireeva O.A.

The purpose of the course work is to summarize the principles of accounting reporting in various national systems.

In the process of work, various research methods were used: generalization, comparative analysis, systematization, methods of logical linking of data.

The course work consists of three chapters. The first chapter examines the concept of accounting and reporting in foreign countries. The second chapter provides basic requirements for reporting. The third chapter provides an analysis of national accounting systems, and examines in more detail the French chart of accounts as the closest to the Russian one.

Chapter 1. General introduction toaccounting in foreign countries

Abroad, the basis for determining the financial result is the use of the method “input-output”, recommended for use by the standards of the International Accounting Standards Committee and the Fourth Directive of the European Economic Community in 1978.

The basis for this is the determination of the financial result commensurate costs with release in financial accounting, costs are taken into account only by element, which makes it possible to determine the newly created value and financial result in accounting.

The overall financial result is established by two options, ensuring the preservation of the features of the French and Anglo-Saxon accounting systems. In the French version, the overall result of the enterprise is determined by summing up the operational, financial and emergency results.

Financial accounting is designed to determine the financial position of the company by zone (risk, constant attention, normal operation, expansion) depending on the share of its own sources of balance and the speed of turnover of working capital, financial results That in for the period and the level of liquidity of funds and sources of the company. It is mandatory and regulated by the state. The obligation to maintain financial accounting in Eastern European countries arises when the following indicators are exceeded: number of personnel - 50 people, balance sheet total - 1 million ECU, annual sales volume - 2 million ECU. The simplified version is used by companies that, at the balance sheet date, do not exceed two wow of these three limits.

For each type, flax operates and is produced commensurate costs with the release of products uk tions (implementations) and determination of financial results. In the Anglo-Saxon version, the financial result is determined by the functions of the enterprise: production, sales and administration.

In management accounting, the financial result is determined by product and, on this basis, then by internal and external segments of activity.

Management accounting is used to determine the financial result for products, responsibility centers, new technological solutions, sales areas within the country and abroad, sales channels, categories of buyers, population groups and other positions on which tactical and strategic decisions are made. Management accounting is used by medium and large firms.

An activity segment is any position for which the financial result of comparing costs with output is determined. They are divided into internal (products, responsibility centers) and external (new product needs, sales areas and channels, representative offices, etc.).

The financial result is reflected in a special account “Analytical financial result”, the result of which is usually equal to the operational result of financial accounting. At the same time, in management accounting, the result is established by costing items when using the full cost or only by variable costs when calculating the truncated cost. In the latter case, two margin categories are defined. Margin is the difference between the price of a product and variable costs. The margin of the first category is determined after subtracting variable costs, the second category - after subtracting direct fixed costs. It is used in pricing to determine the dead point, at which the profit level is zero and below which there is a loss zone, and above which there is a profit zone.

1.2. International accounting standards.

The problem of mismatched accounting models is global. In the process of work of preparers and users of financial statements around the world, the problem of unification of accounting arises.

Bashkir Academy of Public Service and Management under the President of the Republic of Bashkortostan

Department of professional retraining

“Evaluation of the value of an enterprise (business)”

Coursework on the subject “Accounting and Auditing”

On the topic: “Accounting in foreign countries”

Completed:

Abubakirova N.N.

Checked:

Art. department ave.

“Accounting

and audit” USPTU

Kireeva O.A.

The purpose of the course work is to summarize the principles of accounting reporting in various national systems.

In the process of work, various research methods were used: generalization, comparative analysis, systematization, methods of logical linking of data.

Chapter 1. General introduction toaccounting in foreign countries

application of IFRS as national standards. These countries include: Cyprus, Kuwait, Latvia, Malta, Pakistan, Trinidad and Tobago, Croatia;
the use of IFRS as national standards, but with the condition that for issues not covered by international standards, national ones are developed. Such countries are Malaysia and Papua New Guinea;
the use of IFRS as national standards, but in some cases it is possible to modify them in accordance with national characteristics. These are Albania, Bangladesh, Barbados, Zambia, Zimbabwe, Kenya, Colombia, Poland, Sudan, Thailand, Uruguay, Jamaica;
National standards are based on IFRS and provide additional clarification. Among such countries are China, Iran, Slovenia, Tunisia, the Philippines;
National standards are based on IFRS, but some standards may be more detailed than IFRS. Such countries are Brazil, India, Ireland, Lithuania, Mauritania, Mexico, Namibia, the Netherlands, Norway, Portugal, Singapore, Slovakia, Turkey, France, Czechoslovakia, Switzerland, South Africa;
National standards are based on IFRS, except that each national standard includes a clause comparing the national standard with IFRS. (Australia, Hong Kong, Denmark, Italy, New Zealand, Sweden, Yugoslavia.)

The issue of adoption of IFRS by EU countries is currently being discussed, at least in relation to companies whose shares are listed on stock exchanges. Because these standards provide a system that allows new financial institutions to apply an internationally recognized accounting framework, many developing countries have begun to use them.

Let's look at the positive and negative features of International Financial Reporting Standards.

Their objective advantages over national standards in individual countries are:

clear economic logic;
generalization of the best modern world practices in the field of accounting;
ease of understanding for users of financial information around the world.

At the same time, international standards make it possible not only to reduce the costs of companies in preparing their reports, especially in the context of consolidation of financial statements of enterprises operating in different countries, but also to reduce the costs of raising capital.

However, the disadvantages of IFRS should also be noted. These include, in particular:

the generalized nature of the standards, providing for a fairly wide variety of accounting methods;
lack of detailed interpretations and examples of applying standards to specific situations.

In addition, the implementation of standards around the world is hampered by factors such as national differences in the level of development and traditions, as well as the reluctance of national institutions to give up their priority in the field of regulation and accounting methodology.

The International Accounting Standards Committee takes these negative factors into account and is actively working to eliminate them. Thus, on January 1, 1989, the Committee published document E32, “Comparability of Financial Statements,” which contains 29 proposals to limit the choice of accounting methods permitted by current IFRSs. This document is considered by many experts as one of the best projects of the IASB. It allows, to a certain extent, to eliminate a number of differences in the content of reporting and simplify the procedures for its transformation when conducting comparative analysis in the international context.

Chapter 2. National accounting systems

2.1. Types of national accounting systems

National principles governing record keeping vary significantly. But it is possible to identify groups of countries that adhere to similar approaches to building an accounting system, and there are no two states where the accounting rules would be absolutely identical. One of the most common is the three-model classification of accounting systems. It includes:

British-American model (Great Britain, USA, Netherlands, Canada, Australia, etc.);
Continental model (Germany, Austria, France, Switzerland, Italy, etc.);
South American model (Brazil, Argentina, Bolivia, etc.)

The first model is characterized by an orientation towards the needs of a wide range of investors (it is due to a highly developed securities market, the lack of legislative regulation of accounting, which is regulated by standards developed by professional organizations of accountants), flexibility of the accounting system, and a high educational level of both accountants and users of financial information.

The second model is distinguished by the presence of legislative regulation of accounting, close ties between enterprises that are the main suppliers of capital, the orientation of accounting to the state needs of taxation and macroeconomic regulation, and the conservatism of accounting practice.

Third model. Its main feature is the orientation of the accounting methodology to a high level of inflation.

The presence of different approaches to the formation of accounting systems makes it difficult for national enterprises to “communicate” at the international level. Since rules for preparing and publishing financial statements vary across countries, there is a need to study these differences.

One of the factors that determines significant differences in the financial reporting of different countries is, undoubtedly, the legal system. Depending on the type of legislation and the degree of influence of the state on various aspects of life, most countries can be conditionally divided into two groups:

those countries that have legislation of general legal orientation;

2) countries that have an extensive code of laws.

In states belonging to the first group, laws seem to indicate the limits within which individuals and legal entities have freedom of action. This common law system was originally formed in Great Britain and is present in many countries that have traditionally close ties with it (US federal law, the legal system of Ireland, India, Australia and a number of other countries). The activities of companies are not regulated in detail, and the rules for the preparation and publication of financial statements are not specified. Accounting standards in these countries are not regulated by the government, but are determined by various professional organizations of accountants.

In countries of the other group, legislation is based on Roman law. This legal system stipulates laws of a strictly determined nature; individuals and legal entities must follow the letter of the law. Most countries introduce accounting standards into law; All activities in the field of accounting are detailed and quite strictly regulated. The main task of accounting in such countries is the calculation of state taxes and control over their payment. Such states include Germany, France, Argentina and others.

Differences in the preparation and publication of accounting reports are greatly influenced by the existing financial system in the country, as well as the forms of companies and types of ownership in which they are located. For example, in Germany, Japan, and Switzerland, financial policy is determined by a small number of very large banks. The latter not only satisfy a significant part of the financial needs of the business, but are also often the owners of companies. Thus, in Germany, the majority of shares of a number of open joint stock companies are under the control or significant influence of banks, especially such as Deutsche Bank, Dresdner Bank, Kommerz Bank and others.

In France, Italy, Sweden and a number of other countries where small family businesses predominate, accounting has a slightly different orientation. The main providers of capital in their markets are both banks and government agencies, which not only control the financial capabilities of the business, but also act (if necessary) as an investor or lender. In the above countries, firms must follow unified accounting standards due to the influence of government authorities on the preparation and preparation of financial statements. In a number of countries (Germany, France and Italy), legislation obliges companies to publish detailed, audited financial statements. In France and Italy, the government has established special bodies to regulate and control the securities markets, which may mean significant shifts in the development of financial reporting associated with the Anglo-American experience.

Another factor in the existence of differences in international financial reporting is the tax system. An example of such an impact is the practice of “deferred” taxation used in the British accounting model. It lies in the fact that the income of companies, measured according to general accounting rules, often differs from the income on which taxes are levied. The most common reason for this discrepancy is that the tax credit for accelerated depreciation is deducted from income, regardless of the depreciation method chosen. It should be noted that there are some differences in tax calculations within the British-American model. You can consider the tax on the entire amount of income on which it will be levied, and the difference between the amount received and the one that will actually be paid in a given reporting period, considered as long-term debt, or you can limit tax deductions to the amount of the current payment. In the USA and Canada, the first option is used, that is, “full tax distribution”. This approach contrasts with the practice in the UK, where “partial tax sharing” is used, which amounts to an intermediate position between the two alternatives. Such differences have a significant impact on the comparability of after-tax income between US and UK companies. In this regard, in the US, UK and other countries using the British-American accounting model, the issue of deferred taxation has generated considerable debate and led to a large amount of standardized documentation.

In countries that use the continental accounting model, the tax rules are largely the same as the accounting rules, and therefore there is no deferred tax problem as such. Thus, in Germany, tax legislation establishes depreciation rates based on the expected useful life and applied to strictly defined assets. However, in some cases, accelerated depreciation is allowed, for example, for industries that produce energy-saving and environmentally friendly products. However, depreciation charges, which reduce profit before taxes, although reflected in the financial statements, do not cause deferred tax problems.

Significant differences in financial statements arise when accounting in conditions of inflation. Currently, there are two widely used methods for preparing financial statements:

current value accounting;

2) accounting based on total purchasing power.

There are also some differences in approaches to the problem of reflecting inflationary processes in financial statements. In Great Britain in the late 60s. There were significant changes in the economy associated with rising prices, and between 1971 and 1974 a number of documents were developed on this issue, based on the method of total purchasing power. However, in the annual balance sheets of companies that provide additional financial statements based on changes in overall purchasing power, there was conflicting information regarding the meaning of the revised figures.

In continental Europe, inflation accounting has not received sufficient development. After much discussion among accounting professionals in EU member states, it was agreed that accounting would be subject to price increases at acquisition prices, although EU member states were allowed discretion to allow or disallow companies to value assets based on inflation-adjusted data. In general, it can be noted that European countries are not inclined to deviate from the principles of accounting based on historical cost.

Depending on the country of application, there are also significant differences in the theory and practice of consolidated accounting. These differences relate to the extent to which consolidated financial statements are used; definitions of the concept of “group” (association of companies) for the purpose of applying consolidated financial statements; the nature of the information provided by the external user, as well as methodological issues.

Consolidated accounting statements first appeared in the United States at the beginning of the century and were widely developed. In the UK, the need to maintain single accounts, most often in the form of consolidated accounts, was enshrined in law in 1947 and is currently regulated by national standards. In continental Europe, the implementation of consolidated reporting has been slower and there are still different approaches to addressing this issue.

Since the Companies Act 1989, UK law has treated a group as an entity that controls the activities of its subsidiaries and significantly influenced entities. American practice is based on the parent company concept and the equity method of accounting; The fusion method is widely used. German legislation and legal practice on consolidation issues previously diverged quite seriously from their British and American counterparts, but they came closer to them as a result of the implementation of the fundamentals of the 7th EU Directive, adopted in 1983. In France, enterprises are separated under the sole control of the consolidating company (fully consolidated); entities under joint control (consolidated in an appropriate proportion) and entities over which significant influence is exercised. Dutch practice is similar to UK practice and requires that financial information relating to subsidiaries must be included in the group's annual report prepared on a consolidated basis. The equity accounting method is also widely used, and, unlike other EU countries, this method is used both in subsidiaries and in the financial statements of holding companies; thus, the profit of the latter is equal to the consolidated profit. In Belgium and Spain, consolidation was rare until the 1980s, leaving third-party investors and lenders, especially foreign nationals, with inadequate information even about large groups.

Thus, despite the fact that international accounting practice has still not been brought to a single denominator, in most developed countries of the world the fact that differences in national accounting systems are becoming a brake on the development of economic cooperation between them is becoming more and more clear, narrowing possibilities for integrating their economies. In this regard, their efforts to bring national accounting systems as close as possible and level out the differences between them are becoming more and more noticeable.

3.2. French chart of accounts

The transition to separate financial and management accounting requires significant adjustments to the current Chart of Accounts. The French Chart of Accounts can be taken as a basis as it is closest to the one adopted in our country and at the same time ensures separate maintenance of financial and management accounting.

The French chart of accounts includes 10 classes (sections). Of these, 7 classes are allocated for financial accounting accounts:

class 1 - capital accounts;
class 2 - fixed asset accounts;
class 3 - accounts of inventories and work in progress;
class 4 - third party accounts;
class 5 - financial accounts;
class 6 - expense accounts;
class 7 - income accounts.

In each class of accounts, the correspondence of accounts is strictly regulated and organized. Two classes of accounts (eighth and ninth) are allocated for management accounting. There is no strict regulation of accounts; each enterprise resolves these issues independently. One class of accounts (zero) is allocated for off-balance sheet accounts.

The added value created by the organization is calculated as the difference between revenue from sales of products (accounts 70-74) and expenses (accounts 60-62). From an economic point of view, accounts 60, 61 and 62 accumulate all settlements with third-party organizations, which can be considered as “exchange transactions” between business entities that do not lead to the creation of added value.

According to the definition, added value is the contribution of a specific organization to the process of production and sales of products. The organization's contribution directly depends on the number and qualifications of personnel, as well as on the availability of equipment necessary for the production and sale of products. Added value reflects the real economic weight of the organization. It allows performance results to be compared and acts as an indicator of economic growth.

As defined in the French chart of accounts, the operating balance represents the resources received in the course of operating activities and intended to a) replenish and increase working capital, and b) pay financial compensation for the use of borrowed or equity funds. The operating balance is the main source of income for an organization, ensuring its liquidity. The share of the operating balance in value added depends on the specific sector of the economy.

It should be emphasized that standardized codification of accounts facilitates the procedure for calculating all intermediate results. This advantage acquires particular importance when analyzing economic activities at the state level.

The Bureau of Financial Analysis of the Bank of France analyzes the annual reports of companies and produces a report that contains analytical data on the financial activities of each company. Companies voluntarily submit their balance sheets and profit and loss statements to the Bureau.

The Bureau's report can be viewed as a comparative analysis that allows a quick examination of various aspects of a company's financial position. Indicators reflect the strengths and weaknesses of the enterprise, which helps to focus on the most pressing problems that require serious analysis. The main purpose of accounting is to provide information for decision making. As for the Bureau's financial report, it helps entrepreneurs develop business strategies.

Bibliography

1. Astakhov V.P. Accounting theory. - M., March, 2001.

Babaev Yu.A. Accounting theory. - M., Unity, 2001.
Bakaev A.S. Trends in the development of accounting in Russia // Accounting. 1994. - N 8.
Valebnikova N.V. Study of accounting according to international standards // Accounting. 1994.- N 6.

6. Garifullin K.M., Mansurov R.R. On the preparation of consolidated statements in Germany // Accounting.-1997.-No. 5.

7. Danilevsky Yu.A. Increasing the role of international standards // Accounting. 1994. - N 5.

Kalinin N.G. System of accounting and national accounts // Accounting. 1995. - N 1.
Kovalev V.V. Standardization of accounting: international aspect // Accounting. - 1997.- No. 11.
Kolyago M.D. On the way to the international standard // Accounting. 1996. - N 7.
Litvinenko M.I. Review of international financial reporting standards // Glavbukh. - 1998. - No. 1
Malkova T.N. Theory and practice of international accounting. - M., Business Press, 2001.
Marenkov N.L., Kravtsova T.I. International standards of accounting, auditing and accounting policies of companies. - M., URSS, 2000.
Muller G., Gernon H., Mink S. Accounting: an international perspective. Per. from English - M., Finance and Statistics, 1993.
Needles B., Anderson H., Caldwell D. Principles of accounting.: Transl. from English - M., Finance and Statistics, 1993.
Ostrovsky O.M. Accounting standards in Russia // Accounting. 1994.- N8.
Pankov D. A. Accounting and analysis in foreign countries. - Minsk, Ecoperspective, 1998.
Poponova N.A. Some features of enterprise reporting in developed countries//Finance.-1994.-No.9.
Sokolov Ya.V. Fundamentals of accounting theory. - M., Finance and Statistics, 2000.
20. Weaver V.I., Weaver M.V. International accounting and reporting system. - ., Finance and Statistics, 1992.

21. Fedotova G.A., Tsyplenkova I.G. Accounting in foreign countries // Tr./Kuban.gos.agrar.un-t. - 1996. - Issue 351.

22. Hendriksen E.S. Accounting theory. - M., Finance and Statistics, 2000.

23. Chernyshov S.I. Accounting in foreign countries. - M., Unity, 1997.

Application

Table1.Basic comparative characteristics of financial and management accounting

Comparison areas	Financial accounting	Management accounting
1. Obligation to keep records	Required by law	By decision of the administration
2. Accounting purposes	Compiling financial reports for users outside the organization	Assisting administration in planning, management and control
3. Main consumers of information	Persons and organizations outside the enterprise	Various levels of enterprise management
4. Types of accounting systems	Double entry system	Any system that satisfies management information needs
5. Freedom of choice	Mandatory adherence to generally accepted accounting principles	The main criterion is the suitability of information
6. Meters used	Monetary unit at the rate in effect at the time of the transaction	Monetary and natural units of measurement calculated at current or future value
7. Main object of analysis	Business unit as a whole	Degree of detail required for management purposes
8. Frequency of reporting See: Marenkov N.L. Kravtsova T.I. International standards of accounting, auditing and accounting policies of companies. - M., URSS, 2000, p. 56 - 70. See: Fedotova G.A., Tsyplenkova I.G. Accounting in foreign countries // Tr./Kuban.gos.agrar.un-t. - 1996. - Issue 351, p. 75 - 93. See: Litvinenko M.I. Review of international financial reporting standards // Glavbukh.-1998.-No.1.-P.69-75. See for example: Garifullin K.M., Mansurov R.R. On the preparation of consolidated statements in Germany//Accounting.-1997.-No.5.-P.80-83. See: Pankov D. A. Accounting and analysis in foreign countries. - Minsk, Ecoperspective, 1998.

Organizational and legal forms of entrepreneurship

Accounting often called "the language of business" (“the language of business”). Like any language, accounting is constantly evolving and changing to meet the needs of society. According to the definition provided by the American Institute of Certified Public Accountants, the term accounting means "the art of recording, classifying, and summarizing in a significant manner and in terms of money, transactions and events which are, in part at least, of financial character, and interpreting the results thereof" (the art of recording, classifying and summarizing in monetary terms transactions and events that are to some extent financial in nature, and interpreting the results obtained).

In foreign countries, there are various organizational and legal forms of entrepreneurship, but the main ones are three types, which differ in the number of capital owners, their rights and responsibilities. In the USA they are called: sole proprietorship, partnership, corporation. And in the UK it is: sole tradership, partnership, limited company(Fig. 1.1).

Rice. 1.1. V

Sole proprietorship (sole ownership) is a company that is created by one person, which allows the owner to control its business activities. A sole proprietorship is not a legal entity, and therefore the profits of a sole proprietorship are treated as the personal income of its owner. Hence it is not subject to income tax, but is subject to personal income tax. Since the tax rates on personal income and the tax base are usually higher than when taxing the profits of legal entities, this is a disadvantage of sole proprietorships.

The sole proprietor's liability is unlimited, and therefore, in the event of bankruptcy, he may lose not only the business, but also his own property.

In the USA according to Uniform Partnership Act, adopted in 1914 and valid in 44 of the 50 states, partnership(partnership, partnership) is defined as “an association of two or more persons to carry on business as co-owners for the purpose of making a profit.” In the UK according to Partnership Act 1890 partnership is defined as “a relationship of private individuals who jointly carry on a business for the purpose of making a profit.” Partners can be both individuals and legal entities, the total number of which is not limited.

Partnerships have limited lifetime (limited period of activity), that is, in cases where one of the partners refuses, becomes bankrupt, or is unable to continue to participate in the activities of the partnership, it requires re-registration.

in Result mutual agency each partner is a full representative of the partnership and can enter into business transactions for the entire partnership within the framework of its main activities. Each partner has the right to participate in the profits of the company. A partnership, like a sole proprietorship, is not a legal entity and therefore taxes are levied on each partner's individual income.

Rice. 1.2. V

The main feature of general partnerships is unlimited liability. That is, if a partnership goes bankrupt, each partner is required to assume full responsibility for the debts of the enterprise, even if these debts are more than the capital of the partnership. Moreover, if one of the partners cannot pay his part of the debt, the other partner must do it for him through the sale of his own property. But even in limited partnerships there must be at least one person who bears full responsibility. Her name is general partner (main partner), and this is usually the partner who manages the affairs of the partnership. Other partners who are liable only to the extent of their investment are called limited partners (limited partners).

Since partnerships make it possible to pool the capital and talents of individuals, the most common are societies created on a professional basis, for example, societies of accountants, lawyers, and doctors.

The main features of corporations, as opposed to partnerships, are perpetual lifetime (unlimited period of activity) And limited liability (limited liability of its owners). Corporate legislation in different countries is too ramified, and the definition of the concept of a corporation is very vague. Thus, in the United States, at the federal level, to regulate the procedures for the creation and functioning of corporations, there are Revised Model Nonprofit Corporation Act (Amended Model Nonprofit Corporation Law) And Revised Model Business Corporation Act (Amended Model Business Corporation Law), according to which corporation characterized as an economic unit that issues shares.

Share (promotion) - this is a security without a specified circulation period, which certifies a person’s equity participation in the capital of a company and grants him the right to receive a portion of the profit in the form dividends (dividends) and participation in the management of the corporation and the distribution of its property in the event of liquidation. Shareholders (shareholders) may be individuals or legal entities.

During the registration process of a corporation, the draft bylaws specify the maximum number of shares that it will be allowed to issue - authorized shares. As a rule, at the time of formation the corporation produces a smaller number of them - issued shares so that unissued shares release in case the corporation decides to expand its activities. Thus the number of shares that are issued and outstanding outstanding shares less than the number allowed for release.

Shares may be par value shares (shares with par value) or no-par stock (no-par shares). No-par shares may be issued with stated value (declared value) - when the board of directors sets their value at any time) and no-stated value (without declared value).

In some cases, a corporation, in order to increase earnings per share outstanding, buys back some of the shares that were issued. Such shares are called treasury shares (repurchased shares). The difference between repurchased shares and non-repurchased shares is that the re-sale of repurchased shares is allowed at a price below par (Fig. 1.3).

Rice. 1.3. V

US corporations are required to include one of the following words or an abbreviation thereof in their corporate names: "corporation" or "corp.";"incorporated" or "inc.";"company" or "co.";"limited" or "ltd."

Depending on the method of sale of shares, in the USA a corporation receives the status of open or closed (Fig. 1.4). Stock general corporation shares are freely traded on stock exchanges close corporation are not traded on stock exchanges and are owned by a narrow circle of shareholders.

Fig.1.4. V

The difference between corporations and sole proprietorships and partnerships is that a corporation is a legal entity, and therefore its income is subject to double (or triple) taxation: the first time - with federal income tax; the second time - state income tax; for the third time - tax on dividends. However, after tax reform in the United States in 1986, the concept Small Corporation(S-Corporation) - small corporation, which, like partnerships, is not subject to income taxation. Getting status S-Corporation possible if the following conditions are met: the corporation is American, issues one type of shares and has no more than 35 shareholders, who, as a rule, must be private individuals resident in the United States. All other corporations can issue two main types of shares, each of which has its own specifics (Fig. 1.5).

Ordinary shares (ordinary shares), or c ommon stock (common shares) give their holders the right to vote in the management of the company by electing Board of directors (board of directors) and receiving dividends in proportion to their quantity.

Preferred shares have no voting rights, but give their owners preference in receiving dividends and distributing property upon liquidation of the corporation. The amount of dividends on preferred shares is set as a percentage of their par value or in dollars per share. Quite often, such shares are distributed among corporation employees on preferential terms. If preferred shares have the right to be exchanged for ordinary shares, they are called convertible preferred shares. Otherwise, preferred shares are nonconvertible shares (non-convertible shares).

Rice. 1.5. V

Ownership of both common and preferred shares does not guarantee receipt of dividends declared by the board of directors. Thus, if no dividends were declared in the current year, then they are deposited in the next year only if an agreement is concluded between the shareholders and the corporation that the shares are cumulative preferred shares (cumulative preferred shares). In all other cases - if the shares are ordinary or noncumulative preferred shares (non-cumulative preferred shares), shareholders will never receive dividends for this year.

Corporations often purchase shares of other corporations for the purpose of receiving dividends or influencing their operating and financial policies. Depending on the share of shares acquired by the investor company, the size of its influence on the invested company is determined.

According to international practice, to obtain significant influence (significant influence) for an invested enterprise, the investor must own from 20 to 50% of the ordinary shares of the invested enterprise, and to obtain full control (control) - more than 50% of ordinary shares of the invested enterprise, i.e. a controlling stake. So, for example, a trading corporation can buy controlling stakes in companies that produce goods in order to be sure that it will receive the required quantity of goods of the required quality at a price that it sets.

An investor company can obtain a controlling interest in another corporation either by creating a new corporation, retaining more than 50% of the shares (or even all 100%), or by acquiring more than 50% of the shares of a corporation that already exists. Both methods of obtaining a controlling stake are quite common. Acquiring a controlling interest in a corporation that already exists can occur through an acquisition or merger.

Acquisitions occurs when a controlling interest in another company is obtained by acquiring it with cash, other assets, or debt.

Mergers occurs when a controlling interest in another company is obtained by exchanging it for its own shares. In this case, both corporations become shareholders of each other.

However, the invested enterprise can also be a partnership if another enterprise owns part of its capital. According to IAS 27 And IAS 28 To designate enterprises that are in such relationships, the following terms and their meanings are used:

associated company(associated company)- is a business entity, including a non-corporate enterprise, such as a partnership, over which the investor has significant influence and which is neither a subsidiary nor an interest in a joint venture;

subsidiary company(subsidiary)- is a business entity, particularly an unincorporated business entity, such as a partnership, that is controlled by another business entity (known as a parent);

parent company(parent company)- a business entity that has one or more subsidiaries.

For different reasons and in different ways, enterprises create associations. But if previously common forms of enterprise associations were cartels, syndicates, trusts, associations, concerns, consortia, then in recent decades the following have become widespread:

groups(groups)- the totality of the parent company and all its subsidiaries;

holding(holdings)- the totality of the parent company and all its subsidiaries and associated companies.

A type of holding is conglomerate (conglomerates), which arise as a result of the absorption by one large company of many small and medium-sized companies of various industries and areas of activity that are not related to each other either by industry or technology. The purpose of their creation is to invest in the most profitable areas and maximize profits.

The structure of holdings can be either simple, if they consist of a parent company and one or more subsidiaries and associated companies, or complex, if subsidiaries also act as parent companies in relation to other companies. This multi-stage structure, that is, the presence of subsidiaries and grandson companies, is a characteristic feature of modern holdings. The main company that is at the head of the holding is called holding company (holding company).

International associations of enterprises created under a holding structure have acquired the greatest importance. Such associations are called multinational company- MNC (multinational companies), multinational corporations- MNC (multinational corporations), transnational corporations- TNCs (transnational corporations), multinational enterprises- MNE (multi-national enterprises) and even corporations worldwide(global corporations).

According to the existing UN methodology, to TNC Subordinate foreign enterprises are considered not only subsidiaries, but also associated companies, which include corporations in which from 10 to 50% of the share capital belongs to a foreign investor.

The rapid development of international business pursues such goals as gaining access to new sources of resources and new markets, gaining competitive advantages, and increasing efficiency. TO MNC include not only manufacturing companies, but also transnational banks, telecommunications and auditing companies, investment and pension funds. By structure MNC distinguished between vertically oriented and horizontally oriented. The first include MNC, which produce goods in some countries and supply them to others, and belong to the second MNC, who produce similar products in different countries.

American magazine data "Fortune" which annually publishes a list of the 500 largest private and public corporations by gross income indicates that the world's largest corporations are multinational (Table 1.1).

Table 1.1. V Ten largest corporations from the listFortune for 2011