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In many standard textbooks on comparative international accounting, a separate chapter is devoted to classification models of national financial reporting systems. Typically, the authors of 'international accounting classification models' not only organize national financial reporting systems into certain groups and assign descriptive labels to these categories. Rather, they also tend to draw analogies with the disciplines of the natural sciences so as to justify the methodology which underlies their theoretical constructs. The validity of these methodological claims is indirectly being examined in this paper, which argues predominantly from an empirical angle. The focus of the essay is on the notion - usually advanced by the authors of the models under discussion - that German financial accounting practice can be described as 'uniform', thus forming a contrast to the 'fair-judgemental' approach to financial reporting which is commonly held to prevail in the United Kingdom. In order to test these propositions, the accounting policies in the area of foreign currency translation in the consolidated accounts of a sample of British and German chemical companies are subjected to scrutiny. [ABSTRACT FROM AUTHOR]

The European Union Eighth Directive on the approval of auditors covers auditor independence only to a very limited extent. The provisions in the five articles on this subject are far less detailed than they were in the drafts of the directive, so that almost all specific regulation is left to the Member States. An examination of the development of the articles dealing with independence and integrity shows how the need to compromise, in order to reach an agreement, frustrated the intentions of the harmonizers. This paper traces the development of the independence rules in the Eighth Directive from the avant projet through the drafts to the final directive. It assesses the extent to which pre-Eighth Directive regulation in the UK and Germany may have affected the directive and then examines the implementation of the directive in the two countries. It concludes that national culture and accounting traditions prevented harmonization of independence rules through the Eighth Directive. [ABSTRACT FROM AUTHOR]

In an attempt to move away from dichotomous expositions of state-run Germany and self-regulated Britain this paper seeks to analyse the regulation of auditing in terms of a state-profession axis (Hopwood, 1988: 559) that shifts over time. Stereotypical beliefs of Britain and Germany representing diametrically opposite systems of regulation can be contradicted in the light of increasing state involvement in Britain and the recognition that the German system is not adequately characterized by rigid and exhaustive codification, but relies to a significant degree on professional expertise. However, differences do exist, especially in the nature of regulation, which takes an informal shape in Britain, and in the production and diffusion of knowledge where academics and preparers are much more involved in Germany. The case of auditor independence illustrates some of the similarities and differences exposed by an analysis that aims to interpret regulatory systems in their national and historical context rather than producing simplistic general models. [ABSTRACT FROM AUTHOR]

After a brief historical introduction, the paper examines the true and fair view (TFV) requirement in the Fourth Directive, and in the corresponding company legislation in UK, France and Germany. Differences and nuances are explored from a language and translation viewpoint and also related to pre-Fourth Directive requirements and culture. The extent of true harmonization is questionable. Recent experience and usage of TFV in the UK is critically described and related to the broader European context. The general drift of the argument is that countries are tending to interpret TFV in the context of national culture, national accounting tradition and national GAAP. From a properly European perspective there is a need for changes in attitude from all concerned. TFV and GAAP are living and dynamic concepts. They are affected by the cultures within which they are used. Homogeneous attitudes to such concepts imply homogeneous cultural contexts, and this raises questions of a most fundamental nature. [ABSTRACT FROM AUTHOR]

Article 31 of the Fourth Directive, which specifies the general valuation principles to be applied in the preparation of financial statements, shows a difference in emphasis between the different language versions. Except for the English version of the Directive, all others emphasize prudence, as opposed to the other valuation principles required by the article. The earlier drafts of the Directive are examined in an attempt to trace the development of this difference between the English and the other language versions. It seems that the particular wording of Article 31 with its relatively greater weight on prudence probably results from UK influence, more specifically from SSAP 2. A possible solution is then suggested as to why this particular emphasis on prudence was not retained in the English version of the Directive. Further, it is noted that German law did not explicitly make prudence an overriding concept before the Fourth Directive and nor does the German implementation of Article 31. [ABSTRACT FROM AUTHOR]