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: the orientation of the business to a 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 market participants. valuable papers. 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.

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.

For example, the control system accounting and auditing 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 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 is exerted by tax legislation, which practically prohibits the use of 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 economic activity organizations that can make their 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 Exchange Commission - 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 needs state taxes and planning bodies, and the accounting methods used at 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. However, there are General requirements to the organization of accounting, described by the system of "generally accepted accounting principles" (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.

Applied in the UK; Australia; Canada; Cyprus; the Netherlands; USA. It is characterized by the orientation of accounting to the needs of investors and creditors of the enterprise. This model is possible in countries with a highly developed securities market, with a high professional level of accountants, with a large number of large corporations. This model is very flexible, it is not regulated government bodies, but the standards developed by professional organizations of accountants.

Continental

She's being used European countries with a developed market economy: Australia; Greece; Egypt; Italy; France; Germany; Switzerland; Sweden; Japan etc. It is characterized by the following elements:

– detailed legal regulation of accounting and reporting

– orientation of accounting and reporting to the interests of tax authorities

- high reliance on bank lending

This model is distinguished by strict regulation of accounting at the state level.

Latin American

Argentina; Brazil; Peru; Chile and others

Accounting and reporting of these countries is focused on the requirements of state planning. State bodies influence the unification of company reporting. The relative economic backwardness of these countries makes tax demands prevail.

Pursuant to the Accounting Reform Program in accordance with International Financial Reporting Standards, approved by Decree of the Government of the Russian Federation of March 6, 1998 No. 283, and Order of the Government of the Russian Federation of March 21, 1998. No. 382-P in Russia is underway Full time job to improve the system of legal and methodological regulation of accounting, based on the maintenance of a four-level system of regulatory documents.

WITH regulatory framework closely related The concept of accounting in the period of transition to market economy of Russia, approved by the Accounting Methodological Council under the Ministry of Finance of Russia and the Presidential Council of the Institute of Professional Accountants in December 1997, in which the principles for constructing Russian system accounting in the next ten to fifteen years.

The goal of the reform:bring the national system in line with the requirements of a market economy and IFRS.

Reform objectives:

1. Build a system of accounting and reporting standards.

2. To ensure the interconnection of the accounting system in Russia with IFRS.

3. To provide methodological assistance to organizations in the transformation of their accounting.

To achieve these goals, you need:

– to improve the legislation of the Russian Federation on accounting;

– to form a system of national standards;

- train highly professional accountants;

– actively work in international organizations, learn from their experience.

At the current stage, the following trends in the transformation of the accounting process are observed.

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Introduction

To date, there are more than a hundred national accounting models in the world. 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 economic development. individual country by issuing and implementing relevant normative 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 term paper- 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, Committee on International Standards financial reporting, individual economists have been studying the features, analyzing and grouping 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. The purpose of financial reporting, its qualitative characteristics, fundamental principles and concepts, specific accounting methods and techniques will depend on which group of reporting consumers is the main supplier of capital. 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 of the stock market and there is a fierce competition for additional sources investments, 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: all 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 securities on the stock exchanges of different countries, attracting foreign capital to the country, and 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 at the moment is 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 tax base, which allows us to consider it an instrument of the state's fiscal economic policy. The relationship between financial, managerial and tax accounting in different countries 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 legislatures authorities.

Political stability in the country and legislative protection of the interests of owners also affect the content of accounting, since the risk of unexpected loss of capital is a determining factor for investors when choosing a method and country for investing free funds. While ensuring proper protection of the rights of investors, the number of transactions on stock market increases sharply, there is an influx of foreign capital into the country, 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.

Conversely, 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 institutions, 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 to a dramatic 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 this country. Canadian companies are actively involved 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.

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. A higher level of production development requires the formulation of more complex accounting problems that can be solved by highly qualified accounting personnel. Therefore, if the level of 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

V 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, with corporations often separating equity holders from operational management. In the United States, business accounting policy (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, Central American countries, 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.

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 ensures the transparency of the annual reporting of companies, its comparability and the adaptation of accounting to the requirements 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 information necessary for monitoring the implementation of 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. Goes into practice new organization economic cooperation between 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 its financial base will be weakened. 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 a joint venture between the bank and the borrower, resembling direct investment in the classical financial interpretation.

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.

Accounting organization system in Russian Federation is wholly and completely under the auspices of state authorities; professional organizations play the role of advisory research groups. A new chart of accounts for the financial and economic activities of organizations has already been developed and implemented, accounting regulations (PBU) are being 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 hand, 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 possible that under the influence accounting organizations countries that defend 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 countries.

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, one should, leaving all the valuable national features of 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 these 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

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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. Basic accounting and analysis models in foreign countries: KnoRus , 2006.

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1. Characteristics of existing accounting models

There are many accounting models in the world. Their differences are caused by both historical, political, economic and geographical conditions in which enterprises of different countries operate.

Thus, in countries with a large number of investors and creditors, whose composition is quite diverse, and the owners of companies are increasingly separated from operational management, financial and accounting information is the most important source of data on the welfare of the company. In these countries (Great Britain, USA), financial statements are aimed at the information needs of investors, creditors and are highly analytical. In other countries (Switzerland, Germany, Japan), financial policy is determined by a small number of very large banks that satisfy a significant part of business needs. The information necessary to justify additional financial investments is formed in the process of direct contacts between interested parties. In this case, reporting is aimed at protecting the interests of creditor banks. The financial statements here are less detailed and are prepared taking into account the principles of conservatism in asset valuation. In countries where governments play a decisive role in the management of national resources (France, Sweden), accounting is oriented towards the needs of state planning bodies. Firms are forced to follow strict accounting and reporting standards.

The accounting system of a country may depend on its international socio-economic relations. Accounting technologies are exported and imported. Thus, the United States has a significant influence on Canadian accounting practices, due to geographic proximity and close economic ties. Also, American accounting standards are widely used in Japan, which is explained by the expansion of Japanese capital to America. Great Britain (metropolis) has a significant influence on the development of the theory and practice of accounting in its former colonies. Among them are Australia, New Zealand, Malaysia, India, etc.

There is an approach according to which all countries, depending on the type of legislation and the degree of its influence on the practice of accounting, are divided into two groups:

having an extensive code of laws

with legislation of general legal orientation

In the first case, the laws are strictly deterministic in nature, representing, in fact, a series of prescriptions - "You must." Accounting standards are elevated to the rank of state laws, while accounting procedures are detailed and fairly strictly regulated. The main task of accounting in these countries is the calculation of state taxes and control over their full payment. Among these countries are Argentina, France, Germany (in accordance with Article 71 of the Constitution of the Russian Federation, accounting rules are established by the state).

The second group of countries is limited to a code of laws common law, which is a series of restrictions - "You should not." Laws of this type, as it were, indicate the limits within which the enterprise operates. Accounting standards in these countries are not regulated by the state, but are determined by professional organizations of accountants. These standards are more flexible and subject to various innovations.

Taking into account all the conditions affecting the accounting system in different countries, 4 accounting models are distinguished.

British-American – is based on meeting the information needs of small and medium-sized investors in highly developed stock markets. It is characterized by the maximum degree and quality of information disclosure, as well as a relatively low degree of government intervention. This model is used by Great Britain, the USA, the Netherlands.

continental model Banks are the main investors. This model is followed by most European countries - France, Germany, Denmark, etc., as well as Japan. The business of these countries is closely connected with banks, which satisfy the basic financial needs of companies. Accounting is regulated by law and is highly conservative.

South American model – clearly focused on the needs of the state, primarily tax. The countries of this model are characterized by greater uniformity and less complexity of reporting, as well as developed mechanisms for accounting for inflation. Used in the countries of the southern continent of America - Argentina, Brazil, Chile, Uruguay, etc.

Islamic model - is used by countries such as Turkey, Iran, Pakistan, etc. They build their legislative systems under the influence of theological ideas. So, since usury is prohibited in the Koran, accounting documentation cannot show the mechanism of financial non-operating profit. At the same time, the resources and debts of companies are recorded at market prices.