Implications of the mandatory transition from national GAAP to IFRS — Empirical evidence from Germany

This paper analyses the differences between German GAAP and IFRS by quantifying the effects of the first-time adoption of IFRS of German companies in their reporting practices. Due to the IAS Regulation EC No.1606/2002, all publicly traded European companies (including those in Germany) are required to prepare their consolidated financial statements in accordance with IFRS for accounting periods beginning on or after January 1, 2005. This paper measures the effect of the transition from German GAAP to IFRS by using indices of comparability that were developed by Gray (1980). Therefore, the impact on equity and net income is quantified by examining the reconciliations of 103 German companies which had to adopt IFRS for their consolidated financial statements in 2005. On average a significant increase in stockholders' equity and in net income could be observed. The increase in stockholders' equity is primarily due to the adoption of IAS 11, IAS 16, IAS 37, IAS 38 and IFRS 3. Concerning net income, the increase especially results from the adoption of IFRS 3.     

Have ‘European’ and US GAAP measures of income and equity converged under IFRS? Evidence from European companies listed in the US

The EU's adoption of IFRS, combined with the SEC's removal of the US GAAP reconciliation requirement for non‐US registrants reporting under IFRS, signifies a major shift towards the acceptance of global standards. Based on 20‐F reconciliations provided by the population of US listed European companies filing IFRS‐based statements with the SEC in 2005, we examine whether ‘European’ and US GAAP measures of income and equity converged under IFRS. We find that during the period immediately preceding IFRS, for our sample companies, European and US GAAP measures are generally comparable in respect of income and equity. However, as an exception to the latter, we find that UK GAAP yielded significantly lower measures of equity than US GAAP For companies adopting IFRS for the first time in 2005, we find a significant gap between IFRS and US GAAP measures of income, thereby, signifying de facto divergence from US GAAP in regard to income determination. Furthermore, we find that, following IFRS adoption, significant differences with US GAAP equity persisted for companies that previously reported using UK GAAP. Our findings, thus, support critics’ claims that standard‐setters, most notably the IASB and FASB, have more work to do to achieve a sufficient degree of convergence between IFRS and US GAAP that will convince the SEC to require US companies to use IFRS.     

German Reporting Practices: An Analysis of Reconciliations from German Commercial Code to IFRS or US GAAP

This paper presents the results of research analyzing reconciliations of net income and stockholders’ equity from reports prepared according to Germany's Commercial Code (HGB) to either International Financial Reporting Standards (IFRS) or US Generally Accepted Accounting Principles (US GAAP). We describe the distribution of the reconciling items and assess their value relevance to firm market values 3 months after the financial statement date. The work helps to identify many issues not apparent from research that focuses only on promulgated accounting standards. Among other things, the research presented in this paper demonstrates that, when reconciling to IFRS or US GAAP, German companies must reverse significant software and film licensing revenue. Other areas of significant difference, not surprisingly, show greater conservatism in reporting under HGB than IFRS or US GAAP, particularly in asset capitalizations and write-offs as well as in accruals of provisions and reserves. The latter category is value relevant to the firms’ market values after controlling for all other categories of reconciling items from HGB to either IFRS or US GAAP, indicating that German markets value these companies’ provisions and accruals under the German reporting system.     

Effects of Adoption of International Financial Reporting Standards in Belgium: The Evidence from BEL-20 Companies

This study examines the adoption of International Financial Reporting Standards (IFRS) by BEL-20 companies in Belgium. The research analyses the application of IFRS in the consolidated financial statements of Belgian publicly traded companies. In Belgium, as in several other continental European countries, a close link exists between accounting and taxation. The study provides insight into IFRS implementation problems based on a survey sent to BEL-20 companies. The survey focused on the impact that IFRS conversion has on companies, their internal organization and accounting and finance strategy. The benefits and challenges of the adoption of IFRS are analysed, as well as the level of understanding and experience with IFRS, perception of the quality of IFRS, and the impact of adoption of IFRS on consolidated equity and net income. Principal differences between IFRS and Belgian generally accepted accounting principles (GAAP), having a major impact on the conversion to IFRS, are identified. This study should be important not only to the European Union (EU) countries but to countries which will join the EU in the future, and to other countries worldwide that are adopting IFRS.     

Assessing the Effect of the Transition to IFRS on Equity: The Case of the FTSE 100

The paper presents the results of an analysis of the reconciliations of equity presented as part of the transition from UK Generally Accepted Accounting Principles (UK GAAP) to International Financial Reporting Standards (IFRS) by the largest UK companies. While the overall effect on equity is not significant, the effect of the change in convention on individual line items could have important consequences for financial analysis and contractual obligations. The level of variability between companies means that this change will demand attention to detail by users of financial statements. The paper provides a benchmark for comparison with companies from other accounting traditions making the transition to IFRS.     

Empirical findings from the reconciliations in the first IFRS compliant reports prepared by Japanese-owned subsidiaries in Australia

In Japan, a Japanese version of International Financial Reporting Standards (J-IFRS or JMIS)² will be adopted from March-ending in 2016, but exactly when the IFRS mandate will start is still unknown. The Australian regulators required not only publicly listed companies but also private and foreign-owned entities to prepare their financial statements to comply with Australian IFRS (A-IFRS) on or after 1 January 2005. Around the time of the transition to A-IFRS, more than 400 local subsidiary companies in Australia operated businesses which were invested in by Japanese multinational corporations. Thus, Australia was in a unique place to explore the IFRS reporting practices for Japanese-owned entities. We examined the reconciliations of the accounting figures made under the prior Australian generally accepted accounting principles (AGAAP) to those made under A-IFRS, and explored explanations for the reconciliations stated in the first A-IFRS compliant annual reports. On average, the net profits reported under AGAAP were 13% higher than those measured by A-IFRS for the Japanese subsidiaries, while the matched sample Australian companies' profits were on average 2% lower under AGAAP than the accounting figures reported under A-IFRS. Moreover, we described the following four accounting standards which were most frequently cited in the explanations of the impacts of the A-IFRS implementation: financial instruments, income taxes, provisions and employee benefits. Firstly, this study found that the reporting practices of the Japanese subsidiaries and Australian matched sample firms were less likely to be similar in the same Australian institutional setting. Secondly, the differences of the institutional factors in the countries of origin somewhat influenced the financial reporting of the Australian subsidiaries. Finally, the strict and wide scope of recognition and disclosure requirements under A-IFRS led to a significant increase in assets and liabilities. The monetary values materially changed under AGAAP compared with those made under A-IFRS, but these reporting entities attempted to comply with the new accounting regulations on time. We expect that information disclosure will increase and become more standardised under A-IFRS, compared with under AGAAP.     

International Variations in Tax Disclosures

Abstract

We examine the tax disclosures of 161 large IFRS-reporting companies in five countries by studying in detail how they carry out two numerical reconciliations mandated by IAS 12. Using a variety of approaches, we conclude that there are systematic differences in IFRS reporting practice between companies from different countries. However, we also find varied reporting practices within certain industries such as the extractive industry. Based on our observations, we question whether the requirements of the present standard are sufficiently explicit and concise to lead to understandable and comparable tax disclosures. We identify a number of elements of IAS 12 that could be improved.     

Firm Size and National Profiles of IFRS Policy Choice

Previous research on the International Financial Reporting Standards (IFRS) policy choices of large listed companies found a very strong association between policy choice and country. Nationally based pre‐IFRS practices largely explain IFRS policy choices. Nevertheless, some of the policy choices appear to be influenced from abroad, perhaps chosen in order to increase comparability. It has been suggested that smaller companies might be less influenced from abroad, and therefore might display even clearer national profiles of IFRS practice. This paper examines the accounting policy choices made within IFRS financial statements by small listed companies in five major countries. We find highly significant differences between the policies of small and large companies. We also find that small companies make more homogeneous choices, within a country, than large companies do. As a result, the previously published national profiles of the IFRS practices of large companies are misleading in the context of smaller ones.     

Auditors' Affirmations of Compliance with IFRS around the World: An Exploratory Study*

It is widely believed that international financial reporting standards (IFRS) have been adopted in many countries, at least for the consolidated reporting of listed companies. However, in nearly all cases, what the rules require is some national or supranational version of IFRS. This might create problems for investor confidence and comparability. We examine what companies and auditors report concerning compliance with IFRS, focusing on the first full year of IFRS reporting by companies in the stock market indices of four major European countries and Australia. We find that, even when companies were complying with IFRS, they were generally not saying so, which seems to miss part of the point of the 35‐year project on international harmonization. In a small number of cases, auditors provided dual reports: on full IFRS in addition to the mandated reference to national GAAP where the latter corresponds with full IFRS. These cases were found only in Germany and the United Kingdom, and mainly related to companies that filed with the Securities and Exchange Commission as foreign private issuers. We propose explanations for the general lack of dual reports and for the exceptions. We call for widespread adoption of dual reporting where a plain report on IFRS is not yet possible.     

LARGE ACCOUNTING FIRMS’ SURVEY REVEALS EMERGENCE OF “TWO STANDARD” SYSTEM IN THE EUROPEAN UNION

Convergence with International Financial Reporting Standards (IFRS) as promulgated by the International Accounting Standards Board (IASB) is receiving great attention. In 2005, all listed companies domiciled in the European Union (EU) will be required to prepare consolidated accounts based on IFRS. Individual EU member states are, however, permitted to decide whether IFRS will be required or allowed for non-listed companies or for listed companies’ individual accounts. Based primarily on data collected by the six largest international accounting firms during their most recent convergence survey, this paper examines each of the 15 EU member states’ convergence plans and their perceived barriers to convergence.The findings indicate that most EU members do not plan to converge national GAAP with IFRS, thereby highlighting the great significance of the large firms’ concerns regarding emergence of a “two-standard” system in the EU. The survey indicates the majority of EU countries will continue to require or allow national GAAP for individual accounts. While Belgium is considering requiring IFRS for all consolidated accounts, other EU countries have decided to allow or are considering allowing non-listed companies to prepare IFRS consolidated accounts.In most EU countries, the link between financial accounting and tax accounting represents a major barrier to convergence. Other frequently cited barriers include disagreement with certain IFRS and the complicated nature of certain IFRS. International requirements for financial instruments are viewed as particularly problematic.     

IFRS Practices and the Persistence of Accounting System Classification

The earliest paper on international classification of accounting systems is one hundred years old. For about fifteen years from the late 1960s, many papers on the subject were published. One feature of several of the classifications was the dichotomous split of countries into Anglo and continental European. This has been extensively debated. This paper prepares a classification based on the accounting policy choices made by the largest listed companies of eight countries in 2008/9. All the companies were using the same reporting rules, International Financial Reporting Standards (IFRS). This classification by IFRS practices shows the same two groups as a classification of national practices drawn up in 1980, despite 30 years of harmonization. None of the classifications above or the more recent ones was based on the actual accounting practices of companies in annual reports. This has several disadvantages, as the paper investigates. This paper's classification is the first to be based on accounting practices, as well as being the first in the IFRS era. The paper also investigates the implications of the persistent differences in practices for assessing the success of the IASB's whole project on improving comparability of financial statements.     

The Impact of IFRS Adoption on Foreign Direct Investments: Insights for Emerging Countries

International Financial Reporting Standards (IFRS) adoption research supports the arguments of an increase in the credibility of corporate financial information. We investigate the association between IFRS adoption and foreign direct investments (FDI) inflows. The aim is to analyse several characteristics of the adoption process specific to European emerging countries. Our results indicate that the countries adopting IFRS are more likely to benefit from a higher increase in FDI inflows than the non-adopters. Additional tests reveal that the impact is driven by the adoption level related both to listed and unlisted companies. IFRS adoption by unlisted companies has a lower impact on FDI inflows, as compared to IFRS adoption by listed companies. Furthermore, difference-in-difference analysis illustrates a higher increase of FDI inflows after adopting IFRS in the case of non-European Union (EU) countries as compared to EU countries.     

Insights from Accounting Practitioners on China's Convergence with IFRS

This study provides insights from accounting practitioners on China's convergence with International Financial Reporting Standards (IFRS). Through a survey of 33 senior financial executives of Chinese listed companies in 2014, the study reports their perceptions on the following issues: first, the degree of convergence between IFRS and Chinese Accounting Standards (CAS); second, the choice between fair value and historical cost accounting, and the usefulness of fair value accounting for Chinese companies’ financial reporting; third, challenges in the process of China's harmonisation with IFRS; and finally, essential capabilities of Chinese accounting professionals in the process of China's harmonisation with IFRS. Multivariate regression was used for further analysis. The survey findings reveal that in general CAS have converged with IFRS, with a few exceptions that reflect the unique Chinese context. Historical cost accounting is the preferred measurement base to fair value accounting. Exercising professional judgement was identified as a challenge for China's full convergence with IFRS. Ownership structure and the expertise of accounting practitioners were found to affect respondents’ judgements on China's convergence with IFRS. This study has policy implications for international accounting standard setters and accounting educators to consider the contextual issues of implementing IFRS in an emerging economy.     

An Assessment of the Impact of IFRS Adoption on Public Sector Audit Fees and Audit Effort – Some Evidence of the Transition Costs on Changes in Reporting Regimes

While many countries have adopted International Financial Reporting Standards (IFRS) for private sector enterprises, New Zealand (NZ), Australia and the United Kingdom adopted IFRS for all sectors, including the public sector. This approach is consistent with the concept of sector‐neutral accounting standards that gained wide acceptance in NZ and Australia in the early 1990s. Although a number of studies have assessed the impact of IFRS adoption in the private sector, and the public sector has provided some evidence as to the effects of IFRS adoption on financial statements, the costs of adopting IFRS have not been examined. One measure of cost is the change in audit fees in an IFRS reporting environment. The authors examine the impact of IFRS adoption in the NZ public sector on audit fees and audit effort. They obtained data regarding audit fees and audit effort in the NZ public sector and compared the pre‐adoption year with the first year of adoption for all segments. Their results indicate a substantial increase in audit fees and audit effort in the first year of IFRS adoption for all segments, with some variation across the segments. Two sectors, local authorities and energy companies, have had significant increases in audit fees and audit effort. These findings provide some empirical evidence regarding the cost of transition to IFRS and are of interest to researchers and regulators in countries that are currently considering transitioning to IFRS or IFRS‐based International Public Sector Accounting Standards standards in reporting for the public sector.     

IFRS framework-based case study: DaimlerChrysler – Adopting IFRS accounting policies

This instructional case applies a framework-based approach to explore the concept of comparability in financial reporting and retrospective application of new accounting policies. The DaimlerChrysler (DC) case provides an opportunity for you to research key financial reporting concepts, analyze accounting policy differences between U.S. GAAP and IFRS, determine adjustments necessary to convert financial statements from U.S. GAAP to IFRS, and compute and discuss key ratio impacts following financial statement conversion. This case demonstrates that transitioning to IFRS is more than an accounting issue; it provides opportunities for financial restructuring (e.g., Daimler’s amendments to pension plans and its 2007 sale of Chrysler). It also illustrates the importance of professional judgment when initially adopting IFRS accounting policies. Also, despite FASB and IASB convergence efforts, you learn that most of the key differences between U.S. GAAP and IFRS identified in DC’s reconciliations continue today. This case helps you to: (1) develop skills to interpret and apply the requirements on first-time adoption of IFRS to a real-world setting; (2) research key differences between U.S. GAAP and IFRS and their effects on the financial statements and ratios; and (3) understand significant impacts of the transition to IFRS on businesses and financial statements. Completing the case develops your critical thinking and research/technological skills.     

Are international accounting standards more credit relevant than domestic standards?

We examine whether the credit relevance of financial statements, defined as the ability of accounting numbers to explain credit ratings, is higher after firms are required to report under International Financial Reporting Standards (IFRS). We find an improvement in credit relevance for firms in 17 countries after mandatory IFRS reporting is introduced in 2005; this increase is higher than that reported for a matched sample of US firms. The increase in credit relevance is particularly pronounced for higher risk speculative-grade issuers, where accounting information is predicted to be more important; and for IFRS adopters with large first-time reconciliations, where the impact of IFRS is expected to be greater. These tests provide reassurance that the overall enhancement in estimated credit relevance is driven by accounting changes related to IFRS adoption. Our results suggest that credit rating analysts’ views of economic fundamentals are more closely aligned with IFRS numbers, and that analysts anticipate at least some of the effects of the IFRS transition.     

Convergence with IFRS in an expanding Europe: progress and obstacles identified by large accounting firms’ survey

The International Accounting Standards Board (IASB) acquired greater legitimacy and stature when the European Union (EU) decided to require all listed companies to prepare consolidated accounts based on International Financial Reporting Standards (IFRS) beginning in 2005. This study examines the progress and perceived impediments to convergence in 17 European countries directly affected by the EU's decision. These include: (1) the 10 new EU member countries, (2) EU candidate countries, (3) European Economic Area (EEA) countries, and (4) Switzerland. We utilize data collected by the six largest international accounting firms during their 2002 convergence survey. Additionally, we analyze subsequent events and studies.While all surveyed countries will either require or effectively allow listed companies to prepare consolidated financial statements in accordance with IFRS by 2005, few are expected to require IFRS for non-listed companies. This suggests the development of a “two-standard” system. The two most significant impediments to convergence identified by the survey appear to be the complicated nature of particular IFRS (including financial instruments) and the tax-orientation of many national accounting systems. Other barriers to convergence include underdeveloped national capital markets, insufficient guidance on first-time application of IFRS, and limited experience with certain types of transactions (e.g. pensions).     

China's Convergence with IFRS: Analysis of Dual-listed Companies

This study investigates China's convergence towards International Financial Reporting Standards (IFRS) using generally accepted accounting principles (GAAP) differences data disclosed in AH-share companies’ annual reports from 2006 to 2017. We firstly find that 92% of AH-share companies disclosed GAAP differences in 2006, immediately prior to implementation of converged Chinese accounting standards (CAS). This ratio decreased to 88% in 2007, 58% in 2010, and 38% in 2011, respectively. After 2011, less than one third of AH companies disclosed GAAP differences. Secondly, an increasing number of AH companies (35%) have published CAS-based financial statements in Hong Kong from 2014. Thirdly, except for the first few years after 2007, the disclosed GAAP differences have dropped to a very low level; since 2010 the net profit and net assets GAAP differences ratios have been below 0.5%. Fourthly, reduction of the disclosed GAAP differences appears to be the result of efforts by Chinese standard setters and regulators, work related to the International Accounting Standards Board, or changes in China's special socio-economic environment. Distinct from word-by-word comparison between CAS and IFRS, this research shows that China has achieved its original goal, namely an enterprise applying CAS should produce financial statements that are the same as those of an enterprise that applies IFRS. Our findings provide insights regarding China's institutional evolution in terms of the country's IFRS convergence effort, which are useful for further empirical study.     

Examining dual accounting systems in Europe

After adoption of International Financial Reporting Standards (IFRS) for consolidated financial statements by European-listed companies, a number of European countries still require the use of local standards in the preparation of legal entity financial statements. This study investigates whether this requirement can be explained by a low demand for high-quality financial reporting and an orientation of accounting toward the fulfilment of regulatory needs in these countries. Specifically, using accounting quality as an indicator of the focus of accounting on capital providers' needs, we compare accounting quality between countries permitting and prohibiting the use of IFRS in individual financial statements. Consistent with our expectations, we find that countries requiring the use of local standards in the preparation of legal entity financial statements exhibit a significantly lower level of accounting quality, both prior to and after IFRS adoption. We interpret these results as evidence that these countries have local standards more oriented toward the satisfaction of regulatory needs, rather than investors' needs. Furthermore, since differences in accounting quality persist after the implementation of IFRS, results suggest that firms in these countries face a lower demand for high-quality financial reporting.     

Stock option compensation: impact of expense recognition on performance indicators of non-domestic companies listed in the U.S.

The IFRS 2, Share-based Payment, requires that companies recognize the fair value of employee stock options as an expense. To ascertain the impact recognition will have on companies domiciled in countries subject to accounting standards issued by the IASB’s liaison standard setting partners, this research examines the pro forma stock option disclosures provided in Form 20-F by Australian, British, Canadian, French, German, Japanese, and Irish companies.The findings indicate the average impact of expense recognition on diluted EPS will be approximately 40% and will be material at a 5% level for the majority of the companies. The impact varies significantly by country. On average the annual expense recognized will be approximately 15% of beginning stockholders equity. For the majority of the companies, the charge will represent less than 1% of beginning equity. Again the impact varies significantly by country.The findings indicate that absent requirements that stock compensation expense be recognized, a material upward bias will be reflected in performance indicators of many non-U.S. companies and cross-border comparability will be impaired. Since our analysis is based solely on data for the year 2000 for companies domiciled in seven countries, future research will be needed to ascertain the impact of expense recognition on a broader range of companies reporting under IFRS 2.