The different accounting regulatory environments in the U.S. and France.

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FN 408  INTERNATIONAL FINANCIAL ANALYSIS

Introduction of the two companies

Carrefour is the world’s second largest food retailer, and operates over 9,000 stores in 30 countries. Hypermarkets, supermarkets and hard discount stores are three major forms of business in Carrefour. In 2001, consolidated sales of Carrefour were € 69.5 billion (51% from international business), and net income from recurring operation was € 1.2 billion. Till the end of 2001, Carrefour had a total employee of 383,000 worldwide.

Safeway Inc. is one of the largest food and drug retailers in North America. Till the end of 2001, this company operated 1,773 stores in the United States and western Canada. The total sales of 2001 were $34.3 billion. Safeway has extensive network of distribution, manufacturing and food processing facilities in order to support its stores.

Although Carrefour’s turnover is approximate double of Safeway’s, they both engage in food retail industry. Therefore Carrefour and Safeway Inc. is a matched pair of large quoted companies.

The different accounting regulatory environments in the U.S. and France

Legal systems

U.S.

The federal law of the United States generally is modeled on English common law. “A common law rule seeks to provide an answer to specific case rather than to formulate a general rule for the future”. (Nobes C and Parker R, 2002) This naturally influences commercial law, which traditionally does not regulate the behaviour of companies and how they should prepare their financial statements. To a large extent, accounting within such a context does not depend upon law. Instead, accountants themselves establish rules for accounting practice, which may be written down as recommendations or standards.

France

France has a codified law system, in which rules relate with justice and morality. They become doctrine. The accounting laws and decrees of the French state apply to all business enterprises, not just to companies. The keeping of accounting records and taxation report to owners and creditors as well. They include not only a Commercial Code but also a national accounting plan.

Accounting standards

U.S.

In the United States, accounting is regulated by the Financial Accounting Standards Board (FASB), which is a private sector body. However its standards are supported by the Securities and Exchange Commission (SEC), which is a governmental agency. Another private sector body, the American Institute of Certified Public Accountants (AICPA), is responsible for setting auditing standards. ‘Generally accepted accounting principles (GAAP) are the sum total of all financial accounting standards, rules, and regulations that must be observed in the preparation of financial reports’ (Choi F, Frost C and Meek G, 1999)

France

National uniform accounting system is advocate in France. The Plan Comptable General is general standards of accounts. The Conseil National de la Comptabilite (CNC) is attached to the Ministry of Finance. It is major responsible for keeping the Plan current and approving adaptations for specialized. The Commission des Operations de Bourse (COB) is equivalent to the SEC in US, but has important limited influence. The Order des Experts-Comptables et des Comptables Agrees (OECCA) is devoted to professional practice issues of accountants, and under the jurisdiction of the Ministry of Industry and Finance. The Compagnie Nationale des Commissaires aux Comptes (CNCC) is the professional association of independent public auditors, and under the jurisdiction of the Ministry of Justice.

Stock exchanges

U.S.

Zysman (1983) has formalized the type of financial system of the United States as capital market systems. In the U.S. shares of companies are held by millions of private shareholders and institutional investors. This kind of system is benefit to put pressure for disclosure, audit and ‘fair’ information, because of a widespread ownership of companies by shareholder who do not have access to internal information.

France

In Zysman’s (1983) point of view, the financial system of France belongs to the credit based governmental systems. Capitals of most French companies are provided by banks, governments or founding families. The banks or the state will appoint directors and thus be able to obtain information and affect decisions. Meanwhile the need for published information is less clear. This also applies audit, because this is designed to check up on the managers in cases where the owners are outsides. However the auditing profession in France is not as large as in U.S.

Classification study between the U.S. and France

Muller (1967) classified the accounting system of the United States as an independent discipline. This sort of system is highly independent from governments or economic theories. In this type of system, theory is not so respected, but in emergencies or used ex post to justify practical results. ‘General accepted accounting principles’ are typical expressions. Nobes (1984) classified the US accounting system as micro-based, business practice, pragmatic, British origin. Through Nobes’ classification, the US accounting system is independent, individual basis, practical basis, and came from British model.

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France was classified as uniform accounting by Muller (1967). In such system, accounting has been used as a tool of the administrative control of business by governments. Measuring performance, allocating funds, assessing the size of industries and resources, controlling prices, collecting taxation, manipulating sectors of business are using accounting as a tool. Standardization of definitions, measurements and presentation are involved in this system. Nobes also got similar classification for France. By Nobes (1984) the French accounting system was classified as Macro-uniform, government, and tax-based, legal system. The French accounting system is doctrinal, and influenced by government a lot.

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