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International accounting standards
In
the Commission's list of ten priorities for the next six months
a "legislative follow up to the EU Accounting Strategy Communication"
is shown as the second most important item (p.8 3rd Progress Report).
A 1995 Communication proposed Member
States allow the production of consolidated accounts in accordance
with IAS. There is currently a mixture across Member States of what
is acceptable - IAS, US GAAP (Generally Agreed Accounting Principles)
and national rules based on the EU Directives 4th and 7th Company
Law 78/660/EEC and 83/349/EEC. The Directives do not cover all issues
so that Member States can adopt different approaches on those aspects
where the Directives are silent. This results in de facto different
regimes being in place across the EU.
The issue of accounting standards will
undoubtedly come before the European Parliament before too long.
It is not merely concerned with accounting technicalities but will
help create investment across the EU.
NATURE OF THE ISSUE
The prize to be gained from the international
harmonisation of financial reporting is the lowering of the cost
of capital. In its turn this will enable companies to invest more
so generating increased employment and wider prosperity throughout
Europe.
Capital is employed with reference
to the expected return for a given risk taken. The more information
available about the nature of the risk the better it can be priced.
Where uncertainty exists because of a lack of clarity over risks
then a premium will be built into the price so increasing the cost
of capital to companies which limits their ability to expand their
businesses. The greater the transparency the lower the cost of capital.
In countries with financial reporting
regimes which allow for obfuscation the cost of capital will be
higher. If companies domiciled there wish to raise cheaper funds
internationally they will have to produce financial information
which is internationally acceptable which adds to costs and could
cause delay.
For Europe to create an efficient,
deep and liquid securities market it must be underpinned by financial
reporting of the highest quality with common standards shared by
all.
There are historical reasons for the
disparity in accounting standards. In those countries where the
majority of shareholdings were in the hands of a few entities such
as Government, pension funds and banks, the need for public disclosure
was limited because these entities had direct access to the details
they required.
Where however there was a tradition
of dispersed ownership the need for better information to be made
publicly available was more acute.
However, as wider share ownership has
increased across Europe, for example with privatisations, shareholder
protection has risen up the agenda and changes have been made.
WHAT NEEDS TO BE DONE
The comparability of companies performance
across national boundaries needs to be improved if we are to have
a single capital market.
There are internationally agreed core
standards and the recent debate has centred around whether all countries
should follow US GAAP or adopt IASC (International Accounting Standards
Committee) standards.
Following US standards would have been
to abdicate to an agenda driven by US domestic political imperatives
which would have been a far from attractive option.
Instead the EU proposal is to adopt
IASC standards. These will be approved by a technical process aimed
at producing the highest standards not just what is easily acceptable
to all. The adoption of IASC standards by the EU is however subject
to a two stage validation process.
First the endorsement of technical
standards and second their political acceptability. The stated aim
is however to limit changes to the absolute minimum.
WHERE ARE WE NOW
A Communication was issued in June
this year and the 3rd review of the FSAP anticipates a legislative
proposal that listed companies report financial statements in accordance
with International Accounting Standards will be produced before
the end of this year.
The longer term aim is to have
a directive in place before 2005. The Commission has just adopted
the draft legislative proposal.
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