Send your good work in the knowledge base is simple. Use the form below

Students, graduate students, young scientists who use the knowledge base in their studies and work will be very grateful to you.

Posted on http://allbest.ru

Introduction

Today, there are more than one hundred national models accounting. Despite the general patterns, each of them has its own characteristics and its own system of principles. Methods of accounting and valuation of inventories, depreciation and its reflection in accounting, methods of recording transactions with foreign currency, etc. are different. In addition, there are differences in approaches to the formation of reporting and the list of its indicators, methods of monitoring the activities of firms. This is due to the fact that national accounting systems allow solving certain tactical and strategic tasks of developing the economy of a particular country by issuing and implementing relevant regulatory and legislative acts regulating the national accounting system.

Attempts to solve the problem of accounting unification in the international context were repeatedly made in the second half of the 20th century. The idea of harmonizing different accounting systems has been discussed within the European Community (EC) since 1961; each country may have its own model of accounting organization and a system of standards governing it; "harmony" of accounting models is achieved through their compliance with the EU Directives, the main provisions of which are included in the national legislation of the countries - members of the community.

The relevance of this topic stems from the broad development of international, economic and financial ties, the increasing interpenetration of the economy of Russia and other countries in the context of expanding globalization. The purpose of this course work is to consider and compare various accounting models, factors influencing the formation of accounting models.

financial accounting

1. Factors influencing the formation of accounting models

International organizations of accountants, working groups of UN experts, the Committee on International Financial Reporting Standards, individual economists have studied the features, analyzed and grouped national accounting systems for a number of years. As a result of this work, it became possible to identify a number of factors that have a direct impact on the formation of a particular accounting and reporting system.

The primary factor behind the fundamental differences between national accounting systems is the information needs of users of financial information. From which group of reporting consumers is the main supplier of capital, the objectives of financial reporting, its qualitative characteristics, fundamental principles and concepts, specific accounting methods and techniques. In countries where the main creditors of enterprises are banks and the state, reporting will be strictly focused on the needs of fiscal government agencies and large credit institutions. If the formation of capital is directly related to the degree of development stock market and there is a fierce competition for additional sources of investment, then the reporting of enterprises will be guided by the requests of potential investors and creditors. Such reports contain a maximum of analytical data, namely: Additional information about the structure and territorial location of production facilities, about shares and shareholders, about the company's contribution to improving the welfare of society, about the level of professional training of employees, etc.

As the second factor influencing the formation of the accounting system, one can name the priority of the macro- or microeconomic interests of the state. Macroeconomic interests imply an interest in expanding the scale of export-import operations, selling shares and valuable papers on the stock exchanges different countries, attracting foreign capital to the country, joining the elite of the world economic community. Naturally, a country that has set these goals in the first place is faced with the need to unify its accounting principles in accordance with generally accepted norms and standards. If the priority is this moment focused on solving domestic economic problems, the accounting and reporting system will be influenced by established national traditions, which, one way or another, have their own characteristics in each country.

In addition, significant differences in the accounting methodology are introduced by the factor of division of accounting into financial, tax and managerial. Financial accounting solves the problems of relations between enterprises and the state, banks, shareholders, suppliers, i.e. issues of external activity. Management accounting is aimed at solving internal problems related to improving the efficiency of structural units (responsibility centers). The main task tax accounting is an accurate definition of the taxable base, which allows us to consider it an instrument of fiscal economic policy states. The relationship between financial, managerial and tax accounting in different countries is carried out different ways, and the priority role of one of them automatically discredits other types of accounting and affects the structure of financial reporting and the accounting system. If the principles of accounting (financial and managerial) do not contradict the norms of tax legislation, organizations have the opportunity to maintain financial accounting in the interests of investors, management accounting in the interests of the company's management and at the same time use tax accounting standards to optimize deductions to the budget. On the one hand, such a construction of accounting complicates the work, on the other hand, it is the presence of this system that most satisfies the interests of entrepreneurs and legislative authorities.

Political stability in the country and legislative protection of the interests of owners also affect the content of accounting, since the risk of unforeseen loss of capital is a determining factor for investors when choosing a method and country for investment free funds. With proper protection of the rights of investors, the number of transactions in the stock market increases dramatically, there is an influx of foreign capital into the country, and the proportion of funds raised by organizations through the issue of shares increases. In this case, accounting is "forced" to provide reliable and transparent information for the formation of financial statements.

And vice versa, if the interests and protection of creditors come first, the capital structure of enterprises and organizations is formed at the expense of banks and credit organizations, the securities market is relatively small, financial reports do not always adequately reflect the real economic situation.

The next factor affecting the accounting system is the degree of involvement of investors in business management. The Industrial Revolution in the United States led at one time to a sharp increase in national wealth and the number of companies. The source of capital for the latter was the emerging and growing wealthy middle class. The owners of companies, who at the same time were investors, gradually moved away from operational management, passing it into the hands of professional managers and economists. Thus, financial records begin to be used to monitor the efficient use of resources and become the most important source of information about the welfare of the company.

The geopolitical position of the country also influences the development of accounting. Accounting methods are exported and imported, thereby ensuring the uniformity of accounting systems in different countries. Thus, the United States, having a common geographical border and close economic ties with Canada, have a significant impact on accounting practice in that country. Canadian companies take an active part in the work of American stock exchanges. Such countries as Mexico, the Philippines, Israel, etc. experience similar influence of the United States of America.

Accounting for inflation in accounting. Inflationary processes influence the system and methods of accounting. In countries where inflation is low and economic processes predictable, accounting is based on the historical cost principle. It lies in the fact that the assets of the enterprise, the volume of sales, production costs in accounting are reflected at prices prevailing at the time of these transactions (at cost), and is based on stability monetary unit used in accounting. The realism and reliability of financial information compiled in accordance with this principle is inversely proportional to the rate of inflation.

Thus, the application of the principle of historical cost in accounting is an indicator of economic stability in the country. If accounting uses special conversion techniques to estimate the value of assets, inflation has a significant impact on the economy.

Personnel training and financial management. The degree of development of production, management, financial system, training of professional personnel together affect the formation of the accounting system in the country. More high level The development of production requires the formulation of more complex accounting problems that can be solved by highly qualified accounting personnel. So if the level vocational education in the country is low, the accounting system cannot be organized at a high level. The same can be said about the level of preparation of users of financial statements. The level of their professional culture determines the complexity of the information that must be obtained from economists and accountants.

However, it is possible that even in developing country the level of development of accounting is at a high level, financial reports meet the requirements of transparency, reliability, usefulness for making economically sound management and investment decisions. This situation is observed when the business is organized as an international corporation, the headquarters of the companies are located in the industrial developed countries, from where current management is carried out and accounting personnel and managerial personnel are exported.

2. Accounting models, their classification

Currently, we can talk about the formation of the Anglo-American, continental, South American accounting model, the Islamic model and the mixed economy model.

Anglo-American accounting model

IN The Anglo-American system (British-American-Dutch model) considers accounting not only as a system of recording, classifying and summarizing financial data by registering transactions and events in monetary units, but also as a means of providing quantitative information of a financial nature about business entities for the purpose of using this information for making managerial decisions. In other words, the accounting system is an essential element of the infrastructure of a market economy, linking together both private and public organizations.

As a rule, all categories of reporting users do not analyze the financial results of a single enterprise, but consider alternative options for placing their funds in companies of various industries. Thus, in order to conduct intercompany comparisons, the information provided by companies must be uniform, that is, standard, compiled according to uniform rules and regulations. In countries using the Anglo-American accounting model, standards are developed not by government authorities, but by public professional organizations. The top three countries (UK, US and the Netherlands) using this model, have a well-developed securities market, and corporations often separate owners of equity capital from operational management. In the US, politics business accounting(GAAP) is developed by a professional organization of independent accountants - the FASB Accounting Standards Development Board. UK uses FRS Financial Reporting Standards and SSAP Standard Accounting Practices

Currently used by: Australia, Bahamas, Barbados, Benin, Bermuda, Botswana, Venezuela, Ghana, Hong Kong, Dominican Republic, Zambia, Zimbabwe, Israel, India, Indonesia, Ireland, Cayman Islands, Canada, Kenya, Cyprus, Colombia, Liberia, Malawi, Malaysia, Mexico, Nigeria, New Zealand, Pakistan, Panama, Papua - New Guinea, Puerto Rico, Singapore, Tanzania, Trinidad and Tobago, Uganda, Fiji, Philippines, countries of Central America, South Africa, Jamaica.

Continental accounting model

A characteristic feature of the regulatory accounting of the continental model is that the state participates both in the process of developing accounting standards and in the process of putting them into practice. The reporting rules of organizations are designed in such a way as to form input information for the national accounting system, through which the state controls the economy. This circumstance is due to the centuries-old tradition of centralized management and the desire of entrepreneurs to enlist and receive state support. The latter has a significant impact on accounting by establishing a taxation system and requiring that all expenses be reflected in the accounting accounts for tax purposes. Procedures for calculating taxable income based on accounting data are strictly regulated. To determine tax liabilities, tables of accounting profit adjustments are developed. Professional accounting organizations are assigned the role of consultants on practical application norms developed by the state, as well as researchers in the field of accounting.

Accounting for this model is practiced in Europe and Japan. Business in these countries is closely connected with banks, and the government requires mandatory publication of reports. The entire accounting procedure is conservative and regulated by law. Taxation issues are a priority.

This model is used by: Austria, Algeria, Angola, Belgium, Burkina Faso, Ivory Coast, Guinea, Germany, Greece, Denmark, Egypt, Zaire, Spain, Italy, Cameroon, Luxembourg, Mali, Morocco, Norway, Portugal, Russia, Senegal, Sierra Leone, Togo, France, Switzerland, Sweden, Japan.

South- american accounting model

The South American accounting model is characterized by a focus on the needs of government planners and is usually used by "Spanish-speaking" countries that are united by a common historical development and traditions.

The generally accepted chart of accounts is the basis of accounting. It provides transparency annual accounts companies, its comparability and adaptation of accounting to the requirements of international standards, imposes strict requirements for the presentation of information for annual reporting. Thus, it should contain information about the expected distribution of the company's performance, the applicable valuation rules, including an exhaustive list of criteria for each category of assets and liabilities. Reporting should include data on rent, insurance, litigation, tangible fixed assets, inventories, equity, taxes, etc. The reporting also provides the information necessary to monitor the implementation tax policy.

Another difference of this model is the constant adjustment of reporting data for inflation rates and the unification of accounting methods.

Used in Argentina, Bolivia, Brazil, Guyana, Paraguay, Peru, Uruguay, Chile, Ecuador. It focuses on the needs of the government and differs from other models in annual adjustments for inflation rates, the presence of special methods that take into account the instability of the monetary unit and the violation of the principle of initial valuation of fixed assets.

Islamic Accounting Model

Islamic model. Included in the practice of the new Organization for Economic Cooperation of Islamic States developed under the strong influence of the Muslim religion. The main set of rules and regulations that every true Muslim must adhere to is Sharia, based on the Koran and Sunnah, the main books of Islam. Sharia obliges not only to observe numerous religious traditions and rituals, to be guided by certain principles in Everyday life, but also imposes certain requirements on finance and business. And insurance, as an important component of the economy, is no exception. Traditional insurance, in the form in which it is accepted in the Western world, is not in accordance with Sharia, and therefore - prohibited.

In commercial insurance, there are elements such as riba (usury), meysir (excitement) and gharar (uncertainty). These elements are unacceptable from the point of view of Sharia, although Muslim jurists still cannot agree on the degree of presence of these factors in the traditional relationship between the insured and the insurer.

Although Islam imposes a number of restrictions on business, it simultaneously preaches economic activity. The logic is simple: inattention to the economy can harm Islam itself, as it will be weakened financial base. In practice, this means specific prohibitions, and one of the main ones applies to gharar - transactions, the terms of which contain unjustified or excessive risk, for example, when the result depends on the occurrence of a certain event. Because of it, first of all, classical insurance schemes also require a significant revision. Another well-known restriction prohibits riba (usury), that is, loans at interest. To put it simply, money cannot buy money; fundraising must be based on the sharing of both profits and risks. Therefore, most often Islamic loans become joint venture bank and the borrower, in the classical financial interpretation resembling direct investment.

Allowed Muslims financial operations usually have analogues in classical Western business. We can say that schemes are selected that are the most just and protected from the point of view of Islam. "The study of the International Monetary Fund (IMF)," confirms MGIMO Associate Professor Renat Bekkin, "conducted back in 1987, shows that Islamic economics and Islamic banking, in particular, contribute to a fair distribution of resources, are less prone to the risks of illiquidity and insolvency" .

Mixed Accounting Model

The model of a mixed economy is typical for the countries of Eastern Europe and the states that were part of the Soviet Union, for which the transition to a market economy was a prerequisite for reforming the accounting system.

The variety of forms of ownership, which is not typical for the socialist economic system, has led to the need to provide financial information not only for state authorities, but also for shareholders, owners, managers, creditors and investors. The expansion of foreign economic activity, the absence of an "iron curtain" and the need for an influx of foreign capital have put forward the macroeconomic interests of these states as a priority, there is an objective need to provide financial statements of enterprises in accordance with the requirements of International Financial Reporting Standards (IFRS).

The practice of transition to IFRS has shown that there are two ways to solve this problem - the adoption of International Standards as a basis and the preservation of some national features (and, as a result, relative economic independence) or "duplication" of International Standards.

The system of organization of accounting in the Russian Federation is wholly and completely under the auspices of state authorities; professional organizations play the role of advisory research groups. Already developed and implemented new plan financial accounts economic activity organizations, accounting regulations (PBU) are adopted, the prototype for which was IFRS, and tax accounting has become a separate accounting industry.

However, Russian PBUs are not an exact copy of the International Standards, since not all principles, terms and concepts are consonant with the norms and requirements of our legislation, in particular the Constitution of the Russian Federation. Thus, traditional features are preserved and a kind of “symbiotic” accounting system is being formed, which, on the one hand, is focused on the principles of International Financial Reporting Standards, and on the other, is strictly controlled and regulated by state authorities.

As an illustrative example of "duplication" of IFRS, one can cite the experience of the Republic of Kazakhstan, where the accounting system is based on standards that are fully consistent with international ones. It also adopted a unified accounting chart of accounts, but differing, compared to the Russian one, in significant detail, the absence of active-passive accounts, which ensures simplicity, “transparency” and analytics of the financial information provided.

It should also be noted that the countries of continental Europe and the American GAAP accounting system have a certain influence on the formation of accounting systems in Eastern Europe. In this situation, it is not entirely correct to speak of International Financial Reporting Standards as a modern "panacea" in the field of accounting. It is quite possible that under the influence of the accounting organizations of countries defending their economic interests, the IASB will make some changes to its constitution in order to strengthen interaction with national organizations that establish their own accounting standards in their states.

Conclusion

It should be emphasized that the division into accounting models is very arbitrary - there are no two countries with completely identical accounting systems. On the other hand, due to objective processes in the global economy, the need for international accounting standardization is obvious. A number of organizations deal with the problems of unification of accounting and reporting standards.

In the context of the integration of the Russian economy into the world economy, it follows, leaving all valuable national characteristics Russian accounting, strive, at the same time, to maximize the use of international accounting standards. This will lead to improvement and reform operating system accounting at all levels of its organization, which in turn will lead to more active trade and economic contacts, an influx of much-needed Russian economy foreign investment.

In conclusion, it is necessary to pay attention to the fact that between all the listed factors and the degree of development of the accounting system, there is a “ Feedback". The lack of a proper accounting system hinders economic progress, the influx of foreign capital and adversely affects the development of foreign economic relations of different countries.

Bibliography

1. Aitman T.O. Office work: Sample documents. - M.: Publishing house RIOR, 2004.

2. Al Harran, Saad. Islamic Finance: Entrepreneurial Finance. Pelandung Publishing.2005

3. Bezrukikh P.S. Accounting: textbook. allowance: rec. Ministry of Education of the Russian Federation; Expert Council for Accounting. accounting / P.S. Bezrukin, I.P. Komissarov. - M. : UNITI, 2007.

4. Rich I.N. Paperwork and accounting: textbook. allowance / I. N.

5. Accounting: textbook. for universities: rec. Ministry of Education of the Russian Federation;

6. G. Müller, H. Gernon, G. Mink. “Accounting” International Perspective., 2007

7. Gulyaev N.S. , Vetrova L.N. The main models of accounting and analysis in foreign countries: KnoRus , 2006.

8. Klimova M.A. Accounting. Infra-M, 2008.

9. Tkach V.I., Tkach M.V. “International Accounting and Reporting System” - M., 2006.

10. Sokolova E.S. Accounting: FBK-PRESS. 2008.

Hosted on Allbest.ru

...

Similar Documents

Characteristics of accounting. Unified standards in the field of accounting and reporting. Differences between different accounting models. National accounting systems: British-American, continental, Latin American model.

term paper, added 06/10/2015

The main users of information generated in the system of financial and management accounting abroad. Anglo-American accounting model. Characteristics of financial reporting forms. Compilation of a movement report in the company Money.

test, added 10/20/2017

Characteristics of programs for accounting. Development and implementation of a configuration for accounting in a company engaged in foreign economic activity: functions, requirements for the user, software.

thesis, added 07/17/2009

Information Support economic decisions various users of financial statements. Principles of formation and problems of implementation of international accounting standards in Russia. Performance analysis federal law by accounting.

essay, added 10/04/2015

The essence and principles of accounting and the requirements for it. Preparation of financial statements - base document enterprise, its main goals. Preparation of a cash flow statement and a statement of equity.

abstract, added 11/23/2010

The study of the subject and tasks of accounting. Characteristics of the recommended accounting rules. Study of the order and main features of maintaining accounting registers. Analysis of the compilation and storage of registers in electronic form.

term paper, added 11/30/2014

Legal support and principles of organization of accounting at the enterprise. Financial and management accounting. Accounting policy- a set of methods adopted by the head for accounting and disclosure of financial statements.

abstract, added 05/10/2011

Comparative analysis of accounting systems and methods in foreign countries. Formation, normative regulation of Islamic accounting. Harmonization of accounting principles and standards. Distinctive features Anglo-American model of accounting.

presentation, added 11/07/2014

Accounting system. Law "On Accounting". Subject and main objects of accounting. Accounting methods. Normative regulation of accounting. Basic rules of accounting.

control work, added 12/11/2002

Socio-economic aspects of the development of bankruptcy, its legal regulation. Organization of accounting and financial reporting in bankruptcy and examples of their conduct at an insolvent enterprise. Drawing up the reporting of CJSC "ASTEYS".

Accounting, like politics and ideology, knows no national boundaries. Accounting technologies are exported and imported, proving that the accounting systems used in different countries have much in common. There are especially many similarities in countries that are closely interconnected economically, politically, and also have common geographical borders. Almost all former British colonies keep records according to the British system. The influence of the UK is so great that not only accounting methods are exported, but also training systems. Significant influence in the field of accounting practice is exerted on their former colonies by Germany and France, although they have fundamental differences in the organization of accounting, in assessing the role and purpose financial accounting.

Consideration of accounting systems, in the structure of a certain classification, is of no small importance, because it:

allows for an effective approach to the description and comparison of various accounting systems;

contributes to the development of accounting, for example in terms of its harmonization;

assists in the training of accountants and auditors operating in international level;

allows you to solve problems, predict and prevent their occurrence, based on the experience of other countries using a similar accounting model.

As the differences in accounting practices in different countries became more and more obvious, attempts began to classify accounting systems. Currently, there are several classifications.

1. K. Nobes' hierarchical classification, which divides the accounting systems of Western capitalist countries into two main categories: micro-oriented; macro oriented .

The basis of the classification according to K. Nobes (developed in 1983) is the different practice of financial reporting of companies listed on stock exchanges (Fig. 4.1.).

TYPES OF ACCOUNTING AND FINANCIAL REPORTING SYSTEMS

Figure 4.1- Hierarchical classification of K. Nobes

For countries micro level characteristic: Anglo-Saxon common law; a strong, old and numerous accounting profession; developed capital markets (securities exchanges); the focus of financial accounting on a fair presentation, on the needs of shareholders; disclosure of a large amount of information in the reporting; department tax rules from financial accounting; priority of content over form; professional standards. Due to the specific features, the Netherlands is singled out in a separate subgroup (fewer regulations and a strong influence of microeconomic theory). In addition, countries are identified that are oriented to English accounting practice (note that this approach is close to the approach of international financial reporting standards) and to American accounting practice, which is more detailed.

For countries macro level characteristic: Romanesque (codified) law; weak, young and small accounting profession; underdeveloped capital markets (securities exchanges); regulation of financial accounting by legislation and its focus on creditors; trade secret; focus on taxation; predominance of form over content; state regulation. Macro-level countries are divided into subgroups, depending on the predominance of certain characteristics.

For example, in France, Belgium, Spain and Greece, detailed accounting rules are determined by charts of accounts, in Germany accounting is regulated by laws (Commercial Code), in Sweden, the influence of the state, which is engaged in economic planning and tax collection, is strong.

It is interesting to note the general tendency of the countries of the second group to move towards the countries of the first group. Since the beginning of the 90s. large companies, in some macro-level countries, have begun to use rules that are internationally recognized (GAAP US and International Financial Reporting Standards) for compiling consolidated reporting(for example, most of the 50 largest companies Germany prepare reports according to international or American standards).

2. Classification by Muller G., Gernon H. and Mick G., which defines four basic accounting models:

1) Anglo-American;

2) continental;

3) South American:

4) a mixed economy model (which includes the countries of Eastern Europe and the states of the former Soviet Union).

Anglo-American model. The underlying principles of this model were developed in the UK and the US. Huge contribution Holland also contributed to its development, so it is more correct to call this model Anglo-American-Dutch. And at present the role of these countries continues to be extremely active. There is an active development of the joint-stock form of capital ownership. Traditionally, securities markets have been widely developed in these countries and the main participants in the capital market are small investors who require complete and detailed financial reporting.

This model, in most countries, involves the use of the principle of accounting at cost.

The impact of inflation is small and business transactions (sales, purchases financial assets, the product of costs) are reflected at prices at the time of transactions.

The number of large, including transnational, companies that are difficult to manage is very large, which requires a high educational level from both managers and investors.

These countries belong to common-countries, i.e. the legislation in them operates on the principle of "everything that is not prohibited is allowed." Therefore, in the regulation of accounting, the main role is played by professional organizations, and not by the state, and the rules are very detailed.

It should also be noted that the problem of high inflation is currently not in these countries (in the mid-70s of the last century, as a result of the oil crisis, inflation increased, and the Financial Accounting Standards Board required companies to provide reporting adjusted for inflation).

The main idea of this model is the orientation of accounting to the information requests of investors and creditors. In the three leading countries using this model, as already mentioned above, securities markets are well developed, where most companies find additional sources of financial resources.

The system of general and vocational education also meets high standards, which fully applies to both accountants and users of accounting information.

The Anglo-American accounting concept was subsequently "exported" to the former British colonies and close trading partners of the UK and the US. Currently, it is used by many countries of the world: Australia, Botswana, Venezuela, Hong Kong, Israel, India, Indonesia, Ireland, Canada, Colombia, Malaysia, Mexico, New Zealand, Pakistan, Singapore, Philippines, South Africa, etc.

So, the main features of this model are the completeness and detail of financial reporting, focused on a wide range of small investors, a high general level of education, the absence of legislative regulation of the accounting system and, as a result, its flexibility, low inflation.

continental model. This model is followed by most European countries and Japan. They were also the founders of the model. The specificity of accounting here is due to the fact that business is focused on large bank capital, has close ties with banks, which basically satisfy the financial needs of companies. Therefore, the financial statements of companies are intended primarily for them, and not for participants in the securities market.

For example, in Germany, Japan, Switzerland financial policy 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 often the owners of the companies. Thus, in Germany, most of the shares of a number of joint-stock companies open type are under the control or significant influence of banks, in particular such as Deutsche Bank, Dresdner Bank, Commerce Bank and others.

In Japan, Switzerland, and other countries of this model, the financial policy of companies is determined by a relatively small number of large creditors, the exchange of financial information takes place through direct contacts between a narrow circle of interested parties. State authorities oblige companies to publish reporting data. However, financial reporting is much less detailed than in Anglo-American countries.

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 bodies, 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.

The government plays the leading role in the management of national resources in the countries of this model, and enterprises are obliged to adhere to the state economic policy and be guided by the macroeconomic interests of their countries.

As you can see, focusing on the management requests of creditors is not a priority task of this accounting model. On the contrary, accounting practice is primarily aimed at meeting the requirements of governments, in particular with regard to taxation in accordance with the national macroeconomic plan. The reason for this is the centuries-old tradition of centralized management and the desire of entrepreneurs to receive state support. The legislation is very strict, operating on the principle of "only what is allowed" (code - countries), the role of professional organizations in the regulation of accounting is small. Hence the peculiarities - a significant conservatism of accounting practices, the orientation of accounting to the fiscal state needs, the close connection of companies with banking structures.

This model is used by: Austria, Algeria, Belgium, Greece, Denmark, Egypt, Spain, Italy, Luxembourg, Norway, Portugal, France, Germany, Switzerland, Sweden, Japan.

South American model. With the exception of Brazil, whose official language is Portuguese, the countries of this model are united by a common language - Spanish, as well as a common past.

Inflationary processes in the economy had a key impact on the formation of accounting systems in South American countries.

The main difference of this model from others is the use of the method of permanent adjustment of reporting indicators for inflation rates. Adjustment of indicators for inflation is necessary to ensure the reliability of current financial information.

In general, accounting is focused on the needs of state planning bodies, accounting methods used in companies are quite unified. The information necessary to control the implementation of tax policy is also well reflected in accounting and reporting. This cluster includes: Argentina, Bolivia, Brazil, Guyana, Paraguay, Peru, Uruguay, Chile, Ecuador.

Accounting in Brazil is regulated by the Accounting Council (Counselho Federal de Contabilidade). The most important professional accounting organization in Brazil is the Brazilian Institute of Accountants (Instituto Brasileiro de Contadores). Accounting principles and practices in Brazil are mainly the precepts of corporate and income tax laws and the Securities Commission's restrictions on independent corporations.

The main law governing the procedure for financial accounting and reporting in Brazil is the Law on Corporations. It contains items related to corporate financial reporting and brings Brazilian accounting procedures closer to the level of world accounting technologies. The law has had some US influence, so there are few significant differences in accounting rules and reporting requirements between Brazil and the US today, except for accounting for inflation.

Inflation is accounted for in Brazil through year-end adjustments to historical cost real assets, accumulated depreciation, reserves for unforeseen losses in the value of real assets and equity. Adjustments are made using the national currency devaluation coefficient set by the federal authorities. This procedure is considered simple to apply, but has some disadvantages: for example, inventories are not revalued and are recorded at unadjusted cost, as a result of which inventories are underestimated in the balance sheet, the cost of goods sold is overestimated, and therefore income too.

The model of a mixed economy, typical for the countries of Eastern Europe and the states of the former Soviet Union. The collapse of the communist system in Eastern Europe, at the end of the 80s, was accompanied by an "onslaught of democracy and capitalism", initiated by the former Soviet Union. Economist Healy describes the situation in Eastern Europe before 1989 as follows: “Since 1945, the region of Eastern Europe has been a commercial black hole. The economy was characterized by central planning, most enterprises belonged to the state. Western investment was held back by bureaucratic regulation and official disapproval.

In a centralized economy, the unification of financial statements was due to the goal of control. The tasks of accounting were to register the facts of economic life, and not to provide information for decision-making processes at the enterprise level. Moreover, accounting served as an instrument of centralized control. The concepts of profitability and share capital were not taken into account. Instead, accounting was designed to determine the costs of producing products. Muller, Gernon and Meek characterized the accounting of that time as follows: “Financial accounting as such does not exist. The entire accounting system is represented by what is called management accounting.

The group of Eastern European countries is not homogeneous. Currently, it has about thirty independent states with their own special culture, history, as well as production and social structure. At a certain stage, all the states of Eastern Europe will join the European Union.

In addition to the accounting and analysis models described above, considered within the framework of existing classifications, two more formed and developing accounting models can be distinguished.

First, this Islamic model . Islamic countries traditionally include the countries of the Arab East, Iran, Pakistan, Turkey, the former Central Asian republics of the USSR and Kazakhstan.

Muslim countries, in terms of important gross characteristics, occupy prominent positions in the world economy. They account for 42% of the planet's territory, 35% of human resources. The Islamic world is undoubtedly the leader in terms of reserves of such a strategic natural resource like oil. In 2012, the US Department of Energy estimates that OPEC, which consists mainly of Muslim countries, received $434 billion in oil export revenues. There are about 340,000 high net worth individuals in the Middle East. Their combined wealth, according to research by leading American companies, reaches $2.3 trillion. dollars.

However, such an impressive potential of Islamic countries does not translate into comparable development indicators. At present, from an economic point of view, Asia continues to look rather weak: low industrial development; unbalanced trade balance; weak social protection of the population; rising poverty; underdeveloped legal infrastructure; loss of confidence from foreign investors.

The share of the countries of the traditional spread of Islam in global GDP does not exceed 4.5%, in R&D expenditures it was less than 1%, the market capitalization of business does not reach one and a half percent of the world, the share in world merchandise exports barely exceeded the mark of 7%. At the same time, the last indicator in 2012 was still at the level of 15%. The decline in the role of Muslim countries in international trade was accompanied by an increase in the deficit of their trade balance - up to 155 billion US dollars. In addition, they have accumulated 25% of the world's existing external debt.

The concept of "Islamic economy" sounds somewhat strange for modern society.

Speaking about the Islamic economic model, it should be noted that the economy, like physics, cannot be Islamic, Christian, etc. The term "Islamic economy" refers to the standard economic system, which differs only in that it is heavily influenced by theological ideas. The corresponding dogma - Sharia and the Koran - impute to it a moral code, as a necessary factor in systemic balance. This specific feature of this model, of course, does not abolish the known basic laws that operate in the Islamic economy in the same way as in any other. Islamic model financial activities The couple is based on the notion that money is not a commodity that can be sold, having received income from such a sale itself. In addition to other important applied properties of this model, the view of money is a key provision of the Muslim economic doctrine, which distinguishes it from the traditional, Western theory and practices.

From this difference grows another, expressed in the concept of "riba" ("increment", "excess"), and in the economic context - loan interest. Islam considers riba as a sin and outlaws it. Striving for the creation of a fair economic system, Islam (without denying such a phenomenon as the "time value" of money outside the sphere credit operations) believes that money cannot increase in value on its own, as happens when it is lent at a pre-fixed interest rate, depending on the term of the loan. Capital receives remuneration on an equal footing with other factors of production in accordance with the contribution to the transaction and its result. But if the size of the contribution is initially set and constant, then the result, on the contrary, cannot be precisely known in advance. Therefore, the reward may not be related to the costs of human energy, time and capital. In the Islamic model, it is forbidden to receive financial dividends for the sake of dividends themselves.

Into Islamic reality economic model embodied in the form of financial institutions called Islamic banks, which are developing at a rapid pace. Every year in the world financial market there is a growing interest in financial institutions, investment and banking products built on Islamic technologies.

Significantly simplifying, it is permissible to say that the main technical difference between Islamic finance and the world's dominant model can be reduced to the rejection of interest on loans. This allows Islamic economists to introduce a much more adequate category of "capital efficiency" instead of such an instrument as the "price of money".

For the Islamic model, due to the lack of unified accounting and reporting standards, the problem of supervision and regulation is very relevant. banking. In the world, there is practically no data on international Islamic banking, the volume of international banking operations conducted on the principles of Shariah.

In this model, market prices is given preference in the valuation of assets and liabilities of the company. It is believed that this model has not reached the level of development that is inherent in the financial accounting of the above models.

Another model getting everything more development - international . It stems from the need for international accounting consistency, primarily in the interests of multinational corporations (MNCs) and foreign participants in international currency markets.

Each country has its own history, its own values, political system - undoubtedly, this leaves an imprint on the system of accounting culture, accounting and reporting. Thus, accounting principles in the USA and other countries differ significantly: information in the framework of financial accounting in the USA is aimed primarily at meeting the needs of companies that are an investor or creditor, and usefulness from the standpoint of making managerial decisions is the most important criterion for its quality; in France and Sweden, governments play a decisive role in the management of national resources, acting as an investor or lender when necessary, so accounting is tailored to the needs of national planners.

Nevertheless, the business community of all economically developed countries, including Russia, comes to the need to follow IFRS, which are developed by the International Accounting Standards Committee, even though these standards are advisory in nature, the opinion is being strengthened that the standards comply world-class international principles. Currently, in all these countries there is a permanent process of harmonization and standardization of accounting, in accordance with the requirements of international standards.

Today, only a small number of large corporations can claim that their annual financial statements comply with IFRS.

It should be noted that Russia did not belong to any of the above models, and before the beginning of the accounting reform it belonged to the so-called communist model. At present, Russia is steadily moving towards the Anglo-American model.

4.3. Differences in international accounting practice

Under the influence of various factors in accounting practice, a number of problems have been identified that are solved in different countries in their own way. Even in countries where accounting practices are broadly similar, individual details may differ significantly.

GOODWILL

Goodwill is a term used in accounting to describe the difference between the value of a business as a whole and the sum of all of its individual component assets. It arises from a number of important but not quantifiable factors, such as existing trade relations, accumulated work experience of employees, relationships with suppliers and general state business contacts in the business world. In other words, goodwill is the value of the brand, name, reputation or other intangible (intangible) assets of an enterprise.

In accounting, goodwill is recognized (acquisition cost) only when the asset is acquired. For some companies, goodwill may even be negative: in this case, the value of the business as a whole is less than all of its individual components of the assets, so the question arises: “If the business has negative goodwill, why do not its owners sell individual components of the assets and make a profit?”

However, there may be good reasons for owners to continue doing their business in this case, such as because the cost of liquidating the case may be very high or because certain obligations must be met. However, if the calculations show negative goodwill, then it is advisable to double-check the value of all tangible assets and find out how real they are. Document IAS 22 "Accounting for various combinations of businesses" defines the term "intangible fixed capital" as the difference between the cost of acquiring a new business and the "undistorted price" of acquired assets (IAS - International Accounting Standards - International Financial Reporting Standards (IFRS)). Therefore, these new business assets should be recorded in the books of the acquiring company at their undistorted price on the date of acquisition, and not at the original price when they were first acquired.

This accounting objective can be achieved in the group accounts by either revaluation in the books or by adjusting the entire consolidated statement. Valuation in this case is the process of allocating the entire acquired value, which is the original cost of all assets, among their individual components. So it's easy to show these components at their original cost in accounting documents the acquiring company is absolutely wrong.

There are two general approaches to reflect indicators of intangible capital.

1. The acquired intangible fixed capital can be considered as an "outlier" issued by the accounting system, which
needs to be smoothed out as quickly as possible. According
with the approach specified in document IAS 22, immediate
write-off of intangible fixed capital from share capital.

Another approach, not covered by IAS 22, is to record intangible fixed capital on the balance sheet either as an asset or as a dangling debit representing a deduction from equity.

2. Conversely, intangible fixed assets can be viewed as an acquired asset that must be reported on the financial statement and amortized over the expected life of the acquired assets. IAS 22 allows this approach, given that each year the amount of intangible fixed capital will be revalued and written off to the extent that it has depreciated for the company. Some countries that have adapted this approach set a maximum write-off period.

The choice between the two general approaches can affect accounting documents in different ways.

For negative intangible capital, IAS 22 provides for different rules. It is clear that in this case it would be imprudent to write off the capital difference immediately. Therefore, such goodwill can be treated in two ways: 1) treat it as deferred income and systematically amortize it; 2) allocate it to depreciable non-monetary assets in proportion to their undistorted value. This approach will result in a reduction depreciation charges in subsequent years and, accordingly, a gradual transfer of negative goodwill into profit.

Directive No. 7 requires that intangible fixed capital be depreciated over a period not exceeding the useful life of the assets forming it, and proposes that this period be a maximum of five years. Member States are also allowed to resort to the option of subtracting the amount of negative intangible capital stock from the amount of share capital in a takeover.

Different countries have their own approaches to the definition of goodwill.

In Great Britain. SSAP 22 Goodwill Accounting and Reporting requires that goodwill be calculated as the difference between the undistorted cost of the entire purchase and the undistorted cost of its individual components. ( SSAP - Statements Of Standard Accounting Practice - Rules of Accounting and Reporting Standards established by IASB).

Positive goodwill can be calculated in one of the following ways:

Through immediate write-off to the reserve;

Through depreciation in the income statement over the economic life of the assets.

Negative goodwill must go directly to the reserve.

In Germany. Goodwill in consolidated financial statements usually reflects the difference between the market value of acquired net assets and investment costs. Goodwill may be written off on acquisition from the capital reserve or may be amortized. Although the law mentions that the normal amortization period is four years, nevertheless, it is considered in companies within 40 years, and everyone agrees with this in practice.

Negative goodwill at normal conditions should not appear, as this leads to a decrease in the value of assets during their revaluation. If this happens, then it should be treated as a liability, the release from which is possible only when making a profit.

In France. Goodwill includes intangible assets that are not shown elsewhere on the balance sheet, but are necessary for the continued operation of the company. They may appear in assets when a company acquires them. Therefore, following the provisions of Directive No. 4, goodwill may arise in a transaction.

There is no limit to the amortization period for goodwill, although the excess due date must be motivated and indicated in the comments to accounting reports. For those companies that do not publish consolidated group accounting reports, it is common practice not to write down the value of goodwill.

In Sweden. The Accounting Act prescribes that where goodwill appears in a company's accounting records, it may be treated as fixed capital, at least 10% of which must be depreciated annually. As stated in the recommendations of the Professional Organization of Accountants (FAR), consolidated goodwill should be treated similarly and treated as fixed assets and amortized over a period of no more than 10 years. It seems that this approach is becoming common practice, although until recently many companies stretched out the amortization period up to 40 years. Some companies choose to write off goodwill from equity after a takeover.

FOREIGN CURRENCY CALCULATION

In general, the EU does not specify how foreign currency conversion should be carried out. The only requirement under Directive No. 7 is to indicate the basis used for the calculations. In the course of these operations, a number of accounting problems arise.

1.What exchange rate to use in recalculation? Two types of rates are usually used: the "original" rate, which is applied to the time the transaction was actually completed, and the "closing" rate, linked to the date of the balance sheet. Therefore, when different options recalculation either proceed from one of these options, or apply them simultaneously.

2. How to keep a profit and loss account in foreign currency? Information about such profits and losses can be provided in two ways:

a) information about transactions. This approach is used in cases where there is a difference between the exchange rates at the beginning of the transaction and its end. The resulting profit or loss is tied to the transaction itself, and there is general agreement that they should be posted through the income statement;

b) informing about the recalculation. This option is applied when there is a difference between the exchange rates of the day when the results of the transaction are recorded in accounting documents and the day when they are recalculated when drawing up the balance sheet.

3. In many countries, differences in the translation of a company's own accounting data from one currency to another are recognized in the income statement, and translation differences for its foreign subsidiary are often recorded directly in reserves.

4. A separate problem arises when recalculating the accounting documents of companies operating in countries with a high level of inflation. It is associated with the manifestation of two important economic factors:

a) the Fisher effect, according to which there is a correlation between interest rates and forecasts of changes in exchange rates;

b) parity effect purchasing power, according to which there is a correlation between the inflation rate and the strength of the currency (the higher the inflation rate, the weaker the currency, and vice versa).

These economic factors act as inviolable laws and are increasingly manifested in practice.

There are four main conversion methods, the first three of which are based on a combination of the original exchange rate and the closing rate.

1.Current long term method. Under this method, current transactions, such as shares, debtors, bank overdrafts, are translated at the closing rate, and long-term transactions and items, such as fixed assets or debt obligations, are translated at cost.

2.Monetarist-non-monetarist method. Monetary items that are assets or liabilities expressed in monetary terms, such as cash, loans, debtors, creditors, are translated at the closing rate, while commodity items, such as fixed assets and shares, are translated at cost.

3.Time method. This method is based on the fact that the items should be translated in accordance with the exchange rates in force on the day when the value was established in the accounting documents. For money items these will be closing rates, so what monetary value expresses their value on the closing day.

For accounting reports with unchanged original values, commodity items will be recalculated to their original cost, i.e. the temporary method will be applied as a monetarist-non-monetarist method. However, when in accounting reports revalued assets will be paid in, the exchange rate at the revaluation date will be used. For fixed assets, the revaluation taking into account initial costs in accounting documents in a number of European countries is common practice. Inventory is usually shown at the estimate that it is below cost. Where accounting for disposal cost or replacement cost is used, all items are expressed at balance sheet closing date value, i.e. in this case, with the time method, the closing rate is applied to all items.

4. Exchange rate closing method. Here, the closing exchange rate is applied to all balance sheet items, and either the average annual rate or the closing rate is applied to profit or loss items. Since all balance sheet items are subject to restatement, the net investment in each foreign enterprise is also reported, which is why this method is also often referred to as the closing rate and net investment method.

continental model

The countries of continental Europe and Japan are considered to be the ancestors of this model. Here, the specificity of accounting is due to two factors: business orientation to large banking capital and compliance with the requirements of fiscal authorities. Attracting investments is carried out with the direct participation of banks, and therefore the financial statements of companies are intended primarily for them, and not for participants in the securities market. In the continental model, state bodies have a significant influence on the reporting procedure. This can be explained by the priority task of the state to collect taxes. In general, countries with this model are also guided by the principle of immutability of the initial assessment. Russia belongs to the continental model of accounting, Germany and France had a certain influence on our accounting.

For example, the system of accounting and audit regulation in France differs significantly from the British-American model.

The foundation of the accounting and auditing system in France is the Commercial Code (Code de Commerce), which legislates the need for accounting and reporting. The key element of this system is the National Accounting Code (National Accounting Code, better known as the Plan comptable general). This foundational document is over 400 pages long 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 guidelines for it was entrusted to the National Accounting Council (Conseil national de la comptabilite - CNC), created in 1947 under the Ministry of Finance of France, which had the status of a government agency.

Germany has a long tradition of accounting that influenced the formation of accounting in pre-revolutionary Russia. The legal basis for accounting and reporting in Germany is the Commercial Code, which, along with other issues, regulates reporting; it discusses in detail the rules relating to the content and preparation of the balance sheet and income statement. Germany has a unified chart of accounts, on the basis of which sectoral plans for industry, trade, and financial organizations have been developed.

A huge impact on accounting and reporting in Germany has tax law practically prohibiting the use tax incentives if they are not reflected in the accounting.

Due to the absence in Germany of officially formulated generally accepted accounting principles many contentious issues of reporting and accounting data are resolved in court. The Institute of Accountants (Institut der Wirtschaftspufer), established in 1931, is developing recommendations on accounting and reporting that are not mandatory, but nevertheless taken into account in the development of legislation.

If you try to rank the various German sources that regulate the issues of accounting and reporting, then the following groups of documents can be distinguished in terms of importance:

1) commercial regulations;

2) tax legislation;

3) tax instructions;

4) materials of accounting practice;

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

Also, Italy is rightfully considered the birthplace of accounting, since at the end of the 15th century. Franciscan monk-mathematician Luca Pacioli formulated the principles double entry in his "Treatise on Accounts and Records", published in Venice in 1494. However, later Italy's leadership in the development of accounting was lost.

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

In Italy, there is a professional organization - the National Council of Commerce and Accountants (Consiglio Nazionale dei Dottori Commercialisti e dei Ragionaieri - CNDCR), which publishes accounting standards that are very broadly interpreted. However, these standards are used by the Italian national commission on exchanges - CONSOB (Commissione Nazionale per le Societa e la Borsa - an analogue of the American SEC). 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 has been heavily influenced by company law and professional bodies rather than tax law or stock market requirements. Prior to the adoption of the Organization Accountability Act in 1970, accounting and reporting in the Netherlands was practically not regulated by law. The provisions of this Law were later incorporated into the Civil Code and further harmonized with EU directives. At the behest of the government (1970), an Annual Reporting Council was established to issue accounting instructions, which included both employers and employees, as well as accounting specialists.

Companies do not have to necessarily follow its instructions, which are regarded only as the opinions of an influential private group, and auditors are not required to state the facts of non-compliance with the recommendations of the Council.

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

Latin American model

With the exception of Brazil, whose official language is Portuguese, these countries share a common language - Spanish, as well as a common past. The main difference between this model and those described above is the permanent adjustment of the impact of accounting data on inflation rates. Inflation accounting is traditional in Latin American countries, while Argentina, Brazil, Uruguay and Chile have introduced inflation accounting standards and national legislation. In these countries, the official index of the general price level is used as the main adjustment index, on the basis of which data on equity capital and fixed (non-current) assets are recalculated, inventories are revalued at replacement cost. Liabilities in foreign currencies are recalculated at the exchange rate at the end of the reporting year.

In general, accounting is focused on the needs of state tax and planning authorities, and the accounting methods used by enterprises are quite unified.

State bodies in these countries practically regulate the accounting methodology. Professional bodies of accountants do not have any significant influence on the methodology and practice of accounting.

The South American model is used by: Argentina, Bolivia, Brazil, Guyana, Paraguay, Peru, Uruguay, Chile, Ecuador.

Thus, in countries with similar socio-economic conditions, accounting systems have much in common.

In the USA, Great Britain, the Netherlands, the "British-American" accounting model is used, which is focused on the needs of investors and creditors of the company. From a technical point of view, it is the most liberal - each company forms a chart of accounts on its own, there is no single approved numbering of accounts. At the same time, there are general requirements for the organization of accounting, described by the system of “generally accepted accounting principles” (GAAP). Such requirements are developed by professional associations of accountants.

In France, Germany, Japan and some other countries, a “continental model” is used, focused on the needs tax authorities. It is more formalized, since it is based on a single chart of accounts approved by the state.

In countries with high inflation rates, the “Latin American model” is used, which is characterized by constant adjustment of indicators for inflation rates.

Accounting systems of different countries differ significantly. The reasons for such differences are both socio-economic and political, and even geographical factors. As socio-economic reasons, one can single out the nature of the development of capital markets, the number of investors and creditors, participation in international markets capital, inflation rate, size and organizational structure of enterprises, general level of education, types of legislative systems. Traditionally, in Germany and the UK, the securities markets have been widely developed, the main suppliers of capital for companies are a large number of small investors who require constant and complete information about the activities of firms, which they receive through financial reporting. In Germany and France, companies' capital needs are met mainly by a small number of large banks that have access to additional information (in addition to those contained in the reporting) on the activities of enterprises. In France and Sweden, the state plays an important role in the economy and, accordingly, in the financing of companies, which implies that the accounting and reporting system is oriented towards meeting the requirements of state bodies. One of the division criteria can be the level of inflation: countries are thus divided into those with high and low levels of inflation. The former include, first of all, the countries of South America. In order for the information contained in the financial statements to be useful to users, it must be adjusted for inflation indices. For countries with low level inflation is not an issue. Due to the high level of economic development in the UK, the Netherlands, Germany and other developed countries, the enterprises of these countries are quite large, complex organizational structure and a high level of education of employees. This leads to difficulty accounting information, which adequately reflects the existing economic reality and is adequately perceived by users. IN underdeveloped countries accounting systems are quite simple, because small size enterprises and a low level of general education.

Figure 1 - Scheme of the main characteristics classic models accounting

The historical development of legal systems has also had a major impact on accounting systems. Countries are usually divided into two large groups: code-law countries (legalistic orientation) and non-legislative countries (common-law countries; non-legalistic orientation). The first are distinguished by prescriptive laws according to the principle: "what is allowed is allowed." Because of this, accounting rules are strictly regulated and determined by law. Such countries include, for example, Germany, France, Austria and others. Non-legislative countries are characterized by a permissive approach based on the principle: “what is not prohibited is allowed”. Accordingly, accounting systems are more versatile and flexible, as a rule, they have a defined framework in which enterprises are given freedom of choice. Accounting rules or standards are not determined by legislation, but are developed by professional organizations of accountants. This approach is used in the UK, France and a number of other countries.

Accounting systems can be exported in the same way as any other goods. The influence of the accounting rules of one country on the accounting rules of another may be due to political or economic dependence, geographical proximity.

Thus, the accounting systems of different countries are diverse. However, it is possible to single out groups of countries that adhere to the same type of approaches to building accounting systems. (At the same time, there are no two countries where the accounting rules would be absolutely identical.) One of the most common is the three-model classification of accounting systems, according to which the following are distinguished:

1. British-American model (Great Britain, 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 to the needs of a wide range of investors, which is due to a highly developed securities market; lack of legislative regulation of accounting, which is regulated by standards developed by professional organizations of accountants; flexibility of the accounting system; 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 and banks, which are the main suppliers of capital; orientation of accounting to the state needs of taxation and macroeconomic regulation; conservatism of accounting practice. And, finally, the main feature of the third model is the orientation of the accounting methodology to a high level of inflation and the needs of state regulation.

The British-American model is exclusive self-regulation of accounting. The state does not formally manage accounting practices. This accounting system is being developed by various professional associations of accountants, flexible accounting standards (they are developed on the basis of accumulated experience, arguments, etc.). This model is based on a system of legislation of general legal orientation (laws common law, what is not forbidden is allowed). Such legislation does not regulate in detail the life of individuals and legal entities, but sets the boundaries of freedom of action. Distributed in the USA, England, Holland, etc. The main body involved in issuing accounting standards is the Financial Accounting Standards Board (FASB). the main objective Council - development and improvement of accounting standards intended for use in the private sector of the economy, auditors and users of financial statements.

The Council is independent. Independence is ensured by the fact that the Council's activities are monitored by the Financial Accounting Foundation. In addition to the Council, the Council for Accounting Standards in public institutions. In parallel with this Council, the government organization the Securities and Exchange Commission (representation and protection of the interests of investors in accordance with the securities law) is engaged in the regulation of accounting practices.

The set of rules governing financial accounting forms the Generally Accepted Accounting Standards (GAAP). These methods proceed from the priority of the needs of external users of financial statements. Used by many private companies. Although for many private companies there is no statutory audit etc., they often adhere to these generally accepted norms.

3. CONTINENTAL MODEL OF EUROPEAN ACCOUNTING

Continental model - legal regulation of accounting, unification of accounting principles and procedures (Germany, France, Spain, etc.). Continental essentially conservative model, formed on the classical principles of accounting, with government regulation, focus on tax accounting requirements and the movement of capital through banking system. Here, accounting standards have the status of state acts. This approach is largely generated by the operation of codes of laws in these countries, an administrative-permissive regime of legal regulation has been established (strictly according to the letter of the law).

Gradually, the countries included in Common Market achieve freedom of movement of goods, work force etc. Secondary legislation is formed by the European Commission. It generates a number of documents. Directives:

1. The fourth directive of the EU was adopted in 1978, and it offers recommendations on the formation of annual accounts of joint-stock public limited companies, LLC. Peculiarity:

4 balance options and 2 income statement options are offered;

Rules for valuation of certain types of property are given;

The balance sheet and income statement are supplemented by a statement of the company's financial position;

2.seventh EU directive. Regulates the preparation of free consolidated reporting.

4.international standards system.

Committee on international standards- body leading the standards development process (1974)

At the moment, there are about 40 standards, cat. Regulate various aspects of accounting and reporting.
A number of standards are aimed at standardizing the accounting of fixed assets, intangible assets, investment activity. They are almost completely covered by the corresponding PBUs.

A whole group of standards is devoted to accounting for the laws of the organization, accounting for revenue.

Analysis of both models reveals the main features modern systems accounting regulation. The goal of accounting regulation is most accurately and fully formulated by the international group of UN experts: providing accessible and comparable information, including non-financial information, providing a true and objective financial position, income and losses in financial statements.

In most countries, accounting regulation is focused on financial reporting (accounting principles, valuation methods, range of information in reporting, etc.).

BIBLIOGRAPHY

Brodel F. Structures of everyday life: possible and impossible. - M., Progress, 1986.

Ivanov Yu.V. Fundamentals of national accounting. M., 2003.

Malkova T.N. Ancient bookkeeping: what was it like? M., Finance and statistics, 1995

Seslavinsky I. ABC of Accounting. - M., Moscow worker, 1962.

Sokolov Ya. V. Luca Pacioli and his time: 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.

Hendriksen E.S., M.F. van Breda. Theory of accounting. – M.: Finance and statistics, 2000.

Tsygankov K.Yu. Essays on the history of accounting: The origin of double-entry bookkeeping: Tutorial for universities. M., 2004.

International Accounting Models Features of the organization of accounting in budgetary organizations

There are three groups of countries with similar cultural and economic situations and the same approaches to the accounting and reporting system. This allows you to combine national accounting systems, classifying them according to a number of features. Leading scientists from various countries are engaged in the classification of accounting and reporting systems. In our domestic literature, three models of accounting systems are usually distinguished:

· Anglo-American;
· Continental;
South American.

Characteristic features of accounting models

Anglo-American model

· Orientation of the reporting, first of all, on needs of investors and creditors of the enterprise.
Professional regulation of accounting methodology is applied, not state regulation
· Task information support needs of the state represented by the tax authorities is taken out of the framework of the system of financial accounting and preparation of financial statements.
· Real calculus financial result enterprise activities enterprise activities is of particular importance.
· In the leading countries of this model, securities markets are well developed, there is a high professionalism not only of accountants, but also of users of accounting information.

continental model

· Accounting reporting is focused on meeting the needs of tax and other public authorities.
· Accounting is regulated by law, is characterized by considerable conservatism and a high degree of state intervention in accounting practice.
· Orientation of financial statements to the needs of investors is not a priority.
· The accounting practice of one country differs significantly from the accounting practice of another.
The business has close ties with banks

South American model

· In general, accounting is focused on the needs of state and tax authorities.
· Accounting is regulated by law.
· Accounting methods used by enterprises are fairly unified.
· A distinctive feature of these countries is the adjustment of financial statements for inflation.

Anglo-American model

Countries using this accounting model include: Australia, Great Britain, Israel, USA, and other countries.

The basic principles of this model were developed in Great Britain and the USA, with the participation of Holland. The main idea of this model is the orientation of accounting to the information needs of investors and creditors. In countries using this model, securities markets are well developed, through which, to a greater extent, financing of organizations is carried out. They are also distinguished by the high level of the vocational education system. This model is not characterized by strict accounting regulation. It is the most flexible and liberal. The largest number of countries in various parts of the world gravitate towards it. However, in all countries of this model, the influence of the United States and Great Britain is great.

continental model

This model is used in most European countries: Australia, Italy, Denmark, France….. and Japan. Common to this model is the large dependence of organizations on bank lending, which is reflected in the concept of accounting. Orientation to the management needs of creditors (unlike the Anglo-American model) is not a priority for accounting. The continental model is characterized by fairly strict state regulation and is conservative. Relevant regulations regulates the activities of professional accounting organizations and audit rules. The accounting system is aimed at meeting the macroeconomic needs of planning, regulation and taxation. Accounting practices in one country may differ materially from those in another. Chart of accounts can be single or professional. The level of training of professional accountants is quite high, but the professional accounting organizations themselves play a smaller role than in England and the USA.

South American model

This model is used by: Argentina, Brazil, Peru, Chile and other countries in this region. They are united by language. With the exception of Brazil (Portuguese), these are Spanish speaking countries. In addition, these countries have common economic problems First of all, inflation.

The main difference between this model and those described above is the permanent adjustment of the impact of accounting data on inflation rates. Inflation accounting is traditional in Latin American countries, while Argentina, Brazil, Uruguay and Chile have introduced inflation accounting standards and national legislation. In these countries, the official index of the general price level is used as the main adjustment index, on the basis of which data on equity capital and fixed (non-current) assets are recalculated, inventories are revalued at replacement cost. Liabilities in foreign currencies are recalculated at the exchange rate at the end of the reporting year.

In general, accounting is focused on the needs of state and tax planning authorities, and the accounting methods used by enterprises are quite unified.

The distribution of countries and regions according to the above models is shown in the table.

Table number 1. Three Basic Organizational Accounting Models

South American model
Australia Bahamas Barbados Bermuda Botswana Great Britain Venezuela Dominican Republic	Zimbabwe Indonesia Ireland Cayman islands Colombia Malaysia	Netherlands New Zealand Pakistan Papua New Guinea Puerto Rico Singapore Tanzania Trinidad and Tobago
Anglo-American-Dutch model
Philippines	Central America Sri Lanka	South America
continental model
Ivory Coast Bulgaria Burkina Fasso Germany	Luxembourg Norway	Portugal Sierra Leone Switzerland
South American model
Argentina Brazil	Paraguay

It should be noted that the above division is very conditional. For example, accounting regulation in Japan follows the continental model, but at the same time, the influence of the United States is strong, which is an objective consequence of the interpenetration of the capitals of these countries into each other's economy. In addition to those listed, some countries use mixed systems with local characteristics. As a result of the collapse of the socialist camp in the countries that previously belonged to it, transformations are being carried out in the field of accounting, and they perceive one or another model or are guided by international standards.