International Comparison Of Enterprise Accounting Mode
1, Anglo American model
Basic features: the Anglo American model is typical. Separation of Finance and taxation Financial accounting is fully independent and not subject to tax law. Taxpayers' tax matters are dealt with separately by tax accounting. There is no need to make adjustments to the financial accounting results. They are completely separate. There is no necessary connection between accounting, accounting, and taxation, and there is no need to combine the results of tax accounting with the two accounting results.
What are the reasons for the formation of the Anglo American model? There are four factors:
The first is the economic system. The main reason is that the United States has always been a market economy that advocates free competition. Therefore, enterprises play a more important role in this society. The government only assists enterprises in managing the market economy order. Therefore, from Adams MI, the government has always opposed the government's courage to make the economy, and the accounting standard system has been set up by the civil Accounting Association. Unlike US issued by the Ministry of finance, this is very different, so the relationship between the government and enterprises is still based on the market mechanism. The stock companies in the United States are very developed, and the private accounting power in the United States is also very strong, and the market mechanism plays a leading role.
The two is the legal environment. The United States is a statute law is not very developed country, precedent law is the main law, the law of economic life is also a rough line, is also more flexible, more rely on some of the power of the people to manage the economy, so the government intervention in accounting by legal means is not dominant there. In addition, the US capital market is very developed and has strong demand for accounting information disclosure.
The three is the management mode of accounting standards. The US accounting standards are not formulated by the US government, but the US government only plays an auxiliary role. This is different from the Chinese government in formulating accounting standards.
The four is the strength of accounting professional team. American accountants are highly qualified and well paid. They call the economic police a certified public accountant who maintains the order of the market economy. They are called the economic police, not the government, but the certified public accountants. The power of Certified Public Accountants in China is also strong now, but the relative strength of the government is relatively weak. This is the basic situation of the United States and the background of the pattern formation.
2, the pattern of France and Germany.
Combination of Finance and taxation The financial accounting system is completely subordinated to the tax law. The determination of the financial accounting system is also for the delivery of services. Some accounting methods of the financial accounting system are exactly the same as the calculated tax payable. This system is determined by the French government, not by the private sector. The tax law puts forward a clear requirement for accounting. The accounting standards are consistent with the requirements of the tax law. The implementation of accounting is strictly carried out in accordance with the tax law system, and is consistent with the implementation of the financial accounting standards.
The social environment of France and Germany:
(1) it is the institutional environment. In France and Germany, the organic market economy system is implemented. The government is very powerful. Unlike many private enterprises in the United States, it has a large number of public enterprises, or a large number of nationalized enterprises, or a large proportion of state control. Therefore, this restricts the development of the market economy, restricts the development of its capital market, and restricts the formation of the private accounting system, so its accounting system is determined by the government.
(2) the legal environment. France and Germany carry out the continental law system and have a complete set of legal system. Its legal system is very standard, very strict and systematic, so the enterprises carry out according to these systems, and the finance and taxation departments also carry out according to this system.
(3) it is the accounting form of accounting standards. Of course, the accounting system and accounting standards are also determined by the French government, not by the private sector.
The four is the strength of accounting professional team. The strength of accounting professional team is not very strong, because the government power is very strong, and accounting standards are also determined by the government, so the strength of accounting team is not very strong, and the status of Certified Public Accountants is not high. The capital market is also underdeveloped.
The Japanese model is neither a complete separation nor a complete one, but a mixture between the two. Its basic characteristics, tax laws and accounting systems are all determined by the government. At present, it is not determined by the private sector. Japanese enterprises are basically family owned enterprises, and bank holding accounts for a large proportion, which is equivalent to the form of state monopoly capitalism. Therefore, Japan's securities market is still relatively developed, but stocks basically do not trade externally, they are internal transactions, and do not trade much.
The tax accounting is basically based on the accounting results of the financial accounting system, which is close to the Chinese model, but it is not exactly the same. The four factors of this model are:
(1) the institutional environment. Japan follows the principle of free competition in the market economy, and the government is bold in its strength.
(2) it is a legal environment. Japan's laws are similar to those of the European Union. The system of France and Germany is complete and the legal system is very complete. It is also very strict and standardized. Therefore, it is relatively standard for the government to manage the economy by legal means, and the folk power is relatively weak.
(3) is the accounting standard management form, basically by Japan Okura Ya is the Ministry of finance to manage.
(4) it is the strength of the accounting professional team. The strength of the accounting profession is neither very strong nor weak. It serves both the business investors and the government, so it is between France and Germany.
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