Language as a barrier for accounting harmonization in Europe Tryggve Söderblom (S. 171-172)

1 Introduction

European accounting harmonization has been a popular subject for accounting research for many years and the political unification of Europe has not only increased the general interest for this subject but has also extended the opportunities for research as well as the need. The European Union Fourth Directive for the treaty of the annual accounts of limited companies (78/660/EEC) was an important step in the harmonization process. A report from the implementation of the Fourth Directive executed in 1998 came to the conclusion that the directive had been well implemented by the Member States (European Commission 2000) but a number of research reports and studies shows that it is still a challenge to compare information in annual financial statements from different European countries (e.g. Weetman &, Gray 1991, Van der Tas 1992, Theunisse 1994, Frost 1994, Garrod &, Sieringhaus 1995, Peill 2000, Aisbitt 2001, d`Arcy 2001).

The introduction to the Fourth Directive states that there is a need for coordination and transparency in this area since limited companies often extend their activities outside their own national territory. At the same time, they offer no protection for third parties except for their own net assets. One other major concern besides the protection of creditors is to set a minimum of equivalent legal requirements on the financial information provided by companies competing within the European Union. These aspects of the harmonization interest first of all investors and the capital market but other interested partners will raise different requirements.

One interested partner with different needs is made up by multinational companies with subsidiaries in several European countries. These companies have to collect financial information from their foreign units in order to fulfil the requirements for consolidated financial statements but also for management control purpose. The last decade has experienced a boom in cross-border mergers but it is, however, striking how limited the contribution of research in group internal accounting harmonization has been. The interest of multinational companies is addressed in most cases only in a short note in the introduction to the project (e.g. Peill 2000, 5, Pape 1997, 58, Blake et al. 1998b, 144). A recent exception is Fagerström (2002) who studied the choice of accounting methods in the adjustment process from foreign subsidiaries to Swedish multinational stock-listed companies. The study pointed at several matters which lead to low comparability of information from the foreign units.

1.1 Structure of the article

This article discusses language as a barrier in internal group reporting2 between Sweden and Germany, two countries belonging to the same accounting tradition. This is accomplished by studying two central items in the Fourth Directive, the (concept of) true and fair view3 and the mandatory layout of the accounts. An interpretation is that key concepts in accounting can get different meanings or are translated differently in the accounting context they are used in, even if the accounting tradition is supposed to be the same. It is argued here that the Fourth Directive fails to offer a common basis for group internal accounts.

Finally, the consequences of this failure and a theoretical framework for the subject are discussed. As discussed further in section 4, TFV is controversial and it has been a popular subject for accounting research since decades. The ideas discussed here are derived from an ongoing field study on group reporting from Swedish subsidiaries in Germany, which is the reason why these countries will be considered in detail. Sections 3, 4, and 5 are based on earlier working papers4 (Söderblom 2001, Söderblom 2002).