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Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195

Contents lists available at ScienceDirect

Advances in Accounting, incorporating Advances in


International Accounting
journal homepage: www.elsevier.com/locate/adiac

IFRS implementation in the European Union and the survival of


accounting families
Arno Forst
Kent State University, Department of Accounting, P.O. Box 5190, Kent, OH 44242-0001, United States

a r t i c l e i n f o a b s t r a c t

Available online 14 April 2014 This study examines eight IFRS implementation choices available to European Union (EU) and European
Economic Area (EEA) member countries under the EU's 2002 IAS Regulation. Great disparities in IFRS implemen-
Keywords: tation exist among the countries covered under the Regulation, including statistically signicant differences in
International Financial Reporting Standards the IFRS elections for nancial and non-nancial rms. Using hierarchical cluster analysis, a classication of EU
IFRS and EEA member countries according to similarities and differences in their IFRS implementation is developed,
IAS
which identies an IFRS antagonistic, an IFRS leaning, and an IFRS integrated group. These groupings may provide
IFRS adoption
accounting system classications
a springboard for future studies on effects of IFRS implementation differences. Following Meek and Thomas
(2004) call to study the continuing relevance of taxonomies of accounting systems in the IFRS era, the study
also provides evidence for a survival of the traditional micro-based vs. macro-uniform, strong vs. weak equity
market, and outsider vs. insider economy classications of accounting systems into the IFRS implementation de-
cisions of EU and EEA member countries. These results suggest that traditional accounting system classications
remain important in the post-IFRS era.
2014 Elsevier Ltd. All rights reserved.

1. Introduction continue to be, implemented among the member states of the EU and
EEA (Nobes, 2008; Sellhorn & Gornik-Tomaszewski, 2006). The present
The European Union's (EU's) passage of Regulation No 1606/2002 study examines cross-country differences in IFRS implementation
of the European Parliament and of the Council of 19 July 2002 on the choices under the IAS Regulation with the goal of making two distinct
application of international accounting standards1 (hereafter: the IAS contributions. First, it introduces a classication of EU and EEA member
Regulation), which requires that publicly traded rms prepare their countries based on differences in IFRS implementation. Second, it exam-
consolidated nancial statements based on International Financial ines the relevance of traditional accounting system classications for the
Reporting Standards (IFRS), has been hailed as a major milestone toward IFRS implementation choices of EU and EEA member states in order to
the convergence of nancial reporting internationally (Armstrong, Barth, provide evidence for the continuing relevance of accounting classica-
Jagolinzer, & Riedl, 2010). Not surprisingly, the IAS Regulation, which tions in the IFRS era.
applies to the twenty-seven member states of the EU,2 as well as to the Differences in accounting attributes internationally are well docu-
three members of the European Economic Area (EEA),3 has attracted mented, for instance, in value relevance (Ali & Hwang, 2000), conserva-
considerable research interest (Byard, Li, & Yu, 2011; Daske, Hail, Leuz, tism (Ball, Kothari, & Robin, 2000), and earnings management (Leuz,
& Verdi, 2008; Zeghal, Chtourou, & Fourati, 2013). One area that has re- Nanda, & Wysocki, 2003). Will these differences disappear as the mem-
ceived limited attention to date is the different ways IFRS have been, and ber states of the EU and EEA adopt a uniform, standardized accounting
framework? One reason why differences in accounting may continue
Tel.: +1 330 672 1113. to exist in the IFRS era, it is argued, is cross-country differences in the
E-mail address: aforst@kent.edu. implementation of IFRS. Soderstrom and Sun (2007), for example, con-
1
Available at http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:243: jecture that accounting quality is not just a function of the accounting
0001:0004:EN:PDF (last accessed August 29, 2013).
2 standard followed, but also of the legal and political environment of
After the most recent expansion of the EU on January 1, 2007, the 27 EU member
countries are Austria, Belgium, Bulgaria, Cyprus, the Czech Republic, Denmark, Estonia, the country in which a rm is domiciled. Accordingly, they surmise,
Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, differences in accounting attributes are likely to persist following the
Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, adoption of IFRS. In a similar vein, Ball (2006) voices concern that
and the United Kingdom. widespread IFRS adoption will mislead investors into believing that
3
Following an agreement with the EU, the three member countries of the EEAIceland,
Liechtenstein and Norwayare obligated to adopt all EU legislation related to the EU sin-
there is more uniformity in practice than actually is the case. Uneven
gle market, but in turn are allowed to participate in the EU's single market without formal implementation of IFRS, for instance, because of differences in IFRS en-
EU membership. forcement regimes, Ball cautions, will cause differences in accounting

http://dx.doi.org/10.1016/j.adiac.2014.03.006
0882-6110/ 2014 Elsevier Ltd. All rights reserved.
188 A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195

quality, which are hidden under the rug of seemingly uniform categorization by Doupnik and Salter (1993), Nobes (1998, 2008), and
standards. While Ball (2006) calls for increased attention to IFRS imple- Leuz (2010). Overall, the results provide evidenceconsistent with
mentation differences, to date no classication of countries according to Nobes (2008) and contrary to Meek and Thomas (2004) conjecture
differences in IFRS implementation has been attempted. that traditional accounting classications continue to be inuential in
The present study develops a taxonomy of EU and EEA countries the IFRS era.
based on similarities in the exercise of their IFRS implementation The following section reviews the pertinent literature and develops
options.4 This research advances the studies by Sellhorn and Gornik- the research questions to be addressed; the third section presents data
Tomaszewski (2006) and Nobes (2008), which have brought to the on EU and EEA member states' exercise of implementation options
fore the idea that the accounting regimes of EU and EEA member states under the IAS Regulation. The empirical analysis and discussion of
in the IFRS era can be, and should be, grouped based on characteristics of results follow in section four. Section ve summarizes the ndings and
their IFRS implementation choices. concludes with suggestions for future research.
I further investigate the relevance of traditional accounting classi-
cations for the IFRS implementation choices of EU and EEA member
states. Meek and Thomas (2004) call for an examination of the continu- 2. Literature review and development of research questions
ing importance of traditional distinctions of accounting systems upon
universal adoption of IFRS. One study addressing this question is A large body of literature has examined cross-country differences in
Nobes (2008). Nobes (2008) presents evidence that EU and EEA social, legal, and macro-economic factors in order to establish interna-
member states' election to require IFRS or domestic GAAP for unconsol- tional accounting families that enable observed differences in accounting
idated (single-entity) accounts is consistent with his prior (Nobes, practices to be explained.5 The earlier research on accounting system
2008) dichotomous classication of accounting systems into Class A classications generally derived groupings of countries from an intuitive
(strong equity, commercially driven) and Class B (weak equity, categorization of national environmental factors identied as the driving
government driven, tax-dominated) systems. forces underlying a given country's accounting system (Mueller, 1968;
This study extends Nobes (2008) research by examining a classica- Seidler, 1967). Among these earlier classication studies, Nobes (1983)
tion of EU and EEA member countries based on eight IFRS implementa- can be credited with introducing the widely used differentiation of
tion choices. Such classication is likely to capture a given country's macro-uniform and micro-based accounting systems, which are based
disposition towards IFRS more reliably than the examination of one in- on a country's legal and economic foundations. In macro-uniform
dividual election only. Moreover, I examine the linking of earlier classi- countries, accounting is subordinated to national economic policies,
cations of accounting regimes to IFRS implementation choices more whereas countries characterized as micro-based have market-oriented
comprehensively by assessing three frequently used accounting classi- economies, in which accounting is independent of government.
cations. In addition to the Nobes (1998, 2008) taxonomy of strong and Later accounting classication studies, such as Nair and Frank (1980),
weak equity countries, this paper also examines the classication of derive classications of countries primarily from comparative statistical
accounting systems into macro-uniform and micro-based systems analyses of nancial reporting rules or practices. For instance, Doupnik
(Doupnik & Salter, 1993; Nobes, 1983), and the three-cluster categori- and Salter (1993) advanceand empirically verifyNobes (1983) conjec-
zation put forward by Leuz et al. (2003) and Leuz (2010). ture by deriving a classication of countries with similar accounting
Signicant differences exist in the IFRS implementation elections of practices using hierarchical cluster analysis. Their detailed nine-cluster
EU and EEA member countries. Not only do differences exist among classication conforms at the most fundamental level to the dichotomous
countries, but also within each country, as all EU and EEA member structure of accounting systems proposed by Nobes (1983). Panel A of
countries make discriminating decisions to require, permit, or not Table 1 presents Doupnik and Salter's (1993) frequently used (Hora,
allow the use of IFRS for certain groups of rms, or certain types of Tondkar, & McEwen, 2003; Nikkinen & Sahlstrm, 2004) categorization
accounts (single-entity or consolidated) only. Most notably, fourteen of countries into micro-based and macro-uniform accounting regimes.
of thirty EU and EEA member countries differentiate between nancial Nobes (1998) reformulates his earlier classication and proposes a
and non-nancial rms with respect to the use of IFRS in one way or categorization of accounting systems based on the strength of the equity
another. These differences are statistically signicant for the treatment market in each country. He argues that the prevalent nancing system
of single-entity and consolidated accounts of private rms. drives the function of accounting and, thereby, denes the properties
Agglomerative hierarchical cluster analysis of IFRS implementation of the accounting system. His updated classication of accounting sys-
elections reveals the existence of three distinct groupings with respect tems into strong equity, commercially driven (Class A), and a weak
to the level of IFRS implementation: IFRS antagonistic, IFRS leaning, equity, government driven, tax dominated (Class B) systems, closely
and IFRS integrated countries. The cluster of IFRS antagonistic countries follows the earlier micro-based versus macro-uniform distinction, with
comprised largely of a core group of Continental European countries UK and US GAAP forming the strong equity group and French, German,
inuenced by German and French accounting practice. A second and Italian GAAP making up the weak equity group. In 2008, Nobes ex-
group, which is IFRS leaning, encompasses chiey UK-inuenced and panded his taxonomy to include all EU member countries not included
Scandinavian countries. Primarily smaller and/or formerly communist in his earlier paper. Panel B of Table 1 displays his categorization.
central and eastern European countries make up a third group of IFRS Leuz et al. (2003), exploring cross-country differences in earnings
integrated countries. Interestingly, several countries defy common management, also emphasize the strength of a given country's equity
expectation, for instance, Italy and Greece, which are members of the market and propose a grouping of countries based on investor protec-
IFRS integrated group. tion, stock-market development, and ownership concentration. Using
Further analyses demonstrate that the empirical categorization k-means cluster analysis with three predetermined clusters, they classi-
of countries into IFRS antagonistic, leaning and integrated countries fy countries into insider and outsider economies with strong and weak
is statistically signicantly associated with the accounting system legal enforcement. Panel C of Table 3 shows this classication as modi-
ed in Leuz (2010). In the context of IFRS, the Leuz et al. (2003) and

4 5
Countries' elections with respect to the single entity accounts of public rms, the sin- The literature on accounting systems classications is voluminous. Emphasis is based
gle entity accounts of private rms, and the consolidate accounts of private rms, are ex- in the following on those studies that are used as reference points in the following empir-
amined separately for nancial and non-nancial rms, thus contributing six ical analyses. Nobes (2011) provides a more complete review of the accounting classica-
implementation choices. In addition, I consider countries' decision to defer, or not defer, tion literature, incorporating much of the older literature. In addition, D'Arcy (2001)
application of IFRS for issuers of debt only, and rms applying other GAAP due to a listing comprehensively covers studies that have based accounting classications on cultural
in a non-EU country. and environmental factors, which have been left out here entirely for brevity.
A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195 189

Table 1
Prior accounting classications.

Panel A: Doupnik and Salter (1993) two-cluster solution

Micro-based Macro-uniform

EU and EEA member countries: EU and EEA member countries:


Ireland, Luxembourg, Netherlands, United Kingdom Belgium, Denmark, Finland, France, Germany, Italy, Norway, Portugal, Spain, Sweden
Other countries: Other countries:
Australia, Bermuda, Botswana, Canada, Hong Kong, Israel, Jamaica, Malaysia, Namibia, Argentina, Brazil, Chile, Colombia, Costa Rica, Egypt, Japan, Korea, Liberia, Mexico, Panama,
Netherlands Antilles, New Zealand, Nigeria, Papua New Guinea, Philippines, Singapore, Saudi Arabia, Thailand, United Arab Emirates
South Africa, Sri Lanka, Taiwan, Trinidad United States, Zambia, Zimbabwe

Panel B: Nobes (2008) classication

Class A (strong equity, commercially driven) Class B (weak equity, government driven, tax-dominated)

Cyprus, Denmark, Ireland, Malta, Netherlands, Norway, United Kingdom Austria, Belgium, Czech Republic, Estonia, Finland, France, Germany, Greece, Hungary,
Italy, Latvia, Lithuania, Luxembourg, Poland, Portugal, Slovakia, Slovenia, Spain, Sweden,
Switzerland

Panel C: Leuz (2010) cluster membership of countries

Outsider economies with strong legal enforcement Insider economies with strong legal enforcement Insider economies with weak legal enforcement

EU and EEA member countries: EU and EEA member countries: EU and EEA member countries:
Ireland, United Kingdom Austria, Belgium, Denmark, Finland, France, Germany, Greece, Italy, Portugal
Netherlands, Norway, Spain, Sweden
Other countries: Other countries: Other countries:
Australia, Canada, Hong Kong, Israel, Malaysia, Chile, Japan, Korea (South), Switzerland Argentina, Brazil, Colombia, India, Mexico, Pakistan,
New Zealand, Singapore, South Africa, USA Philippines, Taiwan, Thailand

Leuz (2010) classications have been used, for instance, by Schleicher, have exercised some, but not all, available implementation choices in a
Tahoun, and Walker (2010), who rely on the distinction between insid- similar fashion, should be considered similar or distinct with respect to
er and outsider economies to explain differences in investment cash their implementation of IFRS. The present study attempts to ll this void
ow sensitivity across member states of the EU in the post-IFRS adop- by developing such a classication. Whereas Sellhorn and Gornik-
tion period.6 Tomaszewski (2006) present three classications of EU and EEA coun-
The study closest to proposing an accounting system classication tries based on the exercise of three implementation choices, the present
based on IFRS implementation choices is Sellhorn and Gornik- study uses eight IFRS implementation elections to develop one classi-
Tomaszewski (2006). Sellhorn and Gornik-Tomaszewski provide suc- cation. The question of which EU and EEA countries will group together
cinct qualitative information on EU and EEA member states' implemen- based on similarities and differences in their IFRS implementation
tation choices under the IAS Regulation. They propose that EU member choices is exploratory in nature.
states that exhibit an identical exercise of implementation options
should be classied into groups of like countries. However, they do RQ1: Which groups of EU and EEA member countries can be identied
not provide quantitative analysis of the data which would yield such based on similarities and differences in their IFRS implementa-
hierarchical classication. Instead, they consider each of the three tion choices?
implementation choices they study separately, and therefore three
separate classications are provided. To give an example, Sellhorn While research on accounting classications has played a prominent
and Gornik-Tomaszewski place Cyprus and Slovakia into the same role in international accounting research, it is debatable whether tradi-
category with respect to the accounting for consolidated accounts of tional classications of accounting systems have a future following the
private rms, because both countries require IFRS for this purpose. universal adoption of IFRS. Cairns (1997), for example, argues that the
However, they place Cyprus and Slovakia into different classes with harmonization of accounting standards and practices taking place inter-
respect to the single-entity accounts of public rms, because Cyprus nationally renders historical classications of accounting regimes irrele-
requires, but Slovakia prohibits, IFRS in this context.7 vant. Nobes (2006) poses the hyperbolic question of whether the eld
As a result, the work of Sellhorn and Gornik-Tomaszewski (2006) ul- of international accounting will come to an end altogether upon univer-
timately does not allow one to determine if two given countries, which sal, compulsory use of IFRS. In a similar vein, Meek and Thomas (2004)
call specically to examine the continuing importance of traditional dis-
6
One other notable study is D'Arcy (2001). Using a similar methodological approach as tinctions of accounting systems upon universal adoption of IFRS.
Doupnik and Salter (1993), she analyzes nancial reporting requirements in fourteen Few studies to date have examined the survival of traditional
countries and identies three clusters of countries. Cluster one, the (primarily) accounting classications under IFRS. One example is Nobes (2011),
European group, comprises Austria, Belgium, Denmark, France, Germany, Japan, the
who shows that the IFRS practices of large listed rms from a number
Netherlands, Spain, Sweden, Switzerland, and the United Kingdom. A second, North
American, group is made up of Canada and the United States. International accounting of countries8 can be traced to the dichotomous classication of micro-
standards are also identied as belonging in this group. Australia, nally, is found an out- based and macro-uniform accounting systems (Nobes, 1983). Thus, ev-
sider and constitutes a third cluster of its own. D'Arcy's classication is unique in that she idence exists that differences in accounting practice persist despite de
does not nd support for a unied Anglo-American cluster of countries. Unlike the major-
jure adherence to an identical set of rules (IFRS), and, moreover, that
ity of accounting classications, the United Kingdom is grouped with Continental
European countries informed by German and French accounting practice, and Australia
these differences in practice are informed by earlier accounting systems
holds an outlier position. Nobes (2004) raises the possibility that data coding issues may classications. An alternate way traditional accounting classications
be at the core of D'Arcy's (2001) unusual results. may continue to manifest themselves is in the IFRS implementation
7
The information provided in Sellhorn and Gornik-Tomaszewski (2006) is dated in this choices of countries. Nobes (2008) nds a statistically signicant
respect. Slovakia has changed its position and now permits IFRS for the single-entity ac-
association between EU and EEA member states' decision to require or
counts of public non-nancial rms and requires IFRS for the single-entity accounts of
public nancial rms (see Panels A of Tables 2 and 3). Several countries have changed their
8
IFRS implementation choices, and two additional countries (Bulgaria and Romania) have Nobes (2011) covers Australia, France, Germany, Italy, the Netherlands, Spain,
joined the EU since the publication of their paper. Sweden, and the UK.
190 A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195

Other companies
Publicly traded companies
(private firms)

Consolidated IFRS mandatory for fiscal years Option to require or permit IFRS
financial statements starting on or after 1/1/2005

Single-entity annual Option to require or permit IFRS Option to require or permit IFRS
accounts

Fig. 1. Implementation options under the IAS regulation.

to permit IFRS for the preparation of single-entity accounts, and his to continue to require domestic GAAP. Each of these implementation
classication of strong and weak equity countries. He concludes that options, thus, represents a choice between IFRS or domestic GAAP.
accounting classications have survived into the IFRS era, and that Article 8 of the IAS Regulation requires that member states report
they are useful for predicting how countries will implement IFRS. their implementation of the existing options under the Regulation to
The current study expands on Nobes (2008) conjecture by relating a the European Commission. Data reported in the following are based
classication, developed here, which captures EU and EEA member on the European Commission's July 2, 2012 IFRS implementation
countries' overall implementation of IFRS, to three traditional account- report.10
ing taxonomies. In addition to Nobes (1998, 2008) taxonomy of strong A large number of countries distinguish between non-nancial and
and weak equity countries, this paper also examines the classication nancial rms in their implementation choices.11 Accordingly, informa-
of accounting systems into macro-uniform and micro-based systems tion with respect to the exercise of implementation options is presented
(Doupnik & Salter, 1993; Nobes, 1983) and the three-cluster categoriza- separately for nancial and non-nancial rms. Table 2 provides data
tion put forward by Leuz et al. (2003) and Leuz (2010). for non-nancial rms; Table 3 displays the same data for nancial
Doupnik and Salter (1993) suggest that their hierarchies of micro- rms. Panels A of Tables 2 and 3 provide information on which EU and
based versus macro-uniform countries could act as a blueprint for the EEA member countries require, permit, or do not allow publicly traded
future harmonization of accounting standards, arguing that harmoniza- rms to prepare single-entity annual accounts in accordance with
tion should be easier within, rather than across, families. In some re- IFRS. Similarly, Panels B and C of Tables 2 and 3 show the use of
spects, this prediction has been proven wrong as European countries, implementation options with respect to the application of IFRS for the
scattered across several branches of the accounting family tree, agreed consolidated annual accounts and single entity annual accounts of
to follow one uniform accounting standard, IFRS. Howeverconsistent private rms.
with Doupnik and Salter's premisefull integration of IFRS, i.e., a com- In addition to implementation options with respect to the scope of
plete substitution of IFRS for domestic GAAP, may be more challenging IFRS, the IAS Regulation also provides for timing options. Specically,
for macro-uniform countries, where accounting practices are closely Article 9 enables member states to defer application of the Regulation
tied to national economic policies, than for micro-based countries, until nancial years starting after January 1, 2007 for issuers of debt
where accounting is more independent of the government. securities only and/or for companies whose securities were admitted
Based on the above conjecture, and the evidence presented by Nobes to public trading in a non-member state and which, for that purpose,
(2008), I expect to nd an association between a comprehensive had previously been using another internationally-accepted standard.
measure of IFRS implementation elections of EU and EEA countries The latter option was introduced as a bridge measure for EU and EEA
and accounting classications pre-dating the proliferation of IFRS, companies that had opted to use US GAAP prior to the passage of the
stated in the null form: IAS Regulation because their shares were cross-listed on a US stock
exchange. Table 4 summarizes the exercise of implementation options
H1: EU and EEA member countries' IFRS implementation choices are under the transitional provisions of Article 9.
not independent from traditional accounting classications. The data in Tables 2 and 3 highlight the variations in approaches to
IFRS implementation among EU and EEA member countries. For in-
3. IFRS implementation in EU and EEA member countries stance, only four countries require, but twenty-ve countries permit,
the use of IFRS for consolidated nancial statements of private, non-
The EU's IAS Regulation requires that the consolidated nancial state- nancial rms (Table 2, Panel B). Most member states, thus, allow
ments of publicly traded companies be prepared in accordance with IFRS private rms to decide whether or not to follow IFRS for their group
for nancial years starting on or after January 1, 2005.9 Article 5 of the accounts, effectively passing down the option to decide to the rm
Regulation, however, enables member states of the EU and EEA to level. This approach grants maximum exibility to use IFRS instead of
expand the scope of the Regulation and also to require or permit IFRS domestic GAAP for private companies that for any reason prefer
for the consolidated accounts of private companies, or for the annual market-oriented IFRS, for instance, in preparation for going public. For
single-entity (non-consolidated) accounts of public and private rms. the consolidated statements of private rms operating in the nancial
Fig. 1 displays the scope of the IAS Regulation and the areas in which sector, the picture is quite different. Many more countries limit choice
countries retain a choice of accounting system. for nancial rms: 14 countries require IFRS for nancial rms
In all areas not directly addressed by the IAS Regulation, member
states maintain full regulatory authority and therefore have the option 10
Available at http://ec.europa.eu/internal_market/accounting/docs/ias/ias-use-of-
to require or to permit IFRS, or, in the negative, not to allow IFRS and
options_en.pdf (last accessed September 12, 2013).
11
Member states that differentiate in their implementation of IFRS in one way or anoth-
9
Specically, the IAS Regulation requires covered rms to follow IAS adopted by the er between non-nancial and nancial rms include Belgium, Denmark, Estonia, Greece,
EU. The EU did not transfer standard setting authority to the IASB. IFRS to be used in Italy, Latvia, Lithuania, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, and Spain. In
the EU must be adopted through an endorsement mechanism. The endorsement criteria addition, some countries differentiate large and small rms (e.g., Bulgaria, Slovakia); rms
require that the accounting standard under consideration (1) not be contrary to the prin- that are required to prepare consolidated statements or not (e.g., Denmark, Portugal); and
ciples set out in the Fourth and Seventh Directive; (2) be conducive to the European public rms that are required to be audited or not (e.g., Finland, Greece). As a result, to allow for
good; and, nally, (3) meet the criteria of understandability, relevance, reliability, and comparisons across countries, the test case for categorizing implementation options in Ta-
comparability required of the nancial information needed for making economic decisions bles 2 and 3 is dened as a large rm, which is required to prepare consolidated state-
and assessing the stewardship of management (IAS Regulation, Recital 9). ments and is audited by a public accounting rm.
A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195 191

Table 2 Table 3
Exercise of IFRS implementation choices for non-nancial rms. Exercise of IFRS implementation choices for nancial rms.

Panel A: Single entity annual accounts of publicly traded non-nancial rms Panel A: Single entity annual accounts of publicly traded nancial rms

IFRS required Bulgaria, Cyprus, Czech Republic, Estonia, Greece, Iceland, IFRS required Bulgaria, Cyprus, Czech Republic, Estonia, Greece, Iceland,
Italy, Latvia, Lithuania, Malta Italy, Latvia, Lithuania, Malta, Romania, Slovakia
IFRS permitted Denmark, Finland, Ireland, Liechtenstein, Luxembourg, IFRS permitted Denmark, Finland, Ireland, Liechtenstein, Luxembourg,
Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Netherlands, Norway, Poland, Portugal, Slovenia,
United Kingdom United Kingdom
IFRS not allowed Austria, Belgium, France, Germany, Hungary, Romania, IFRS not allowed Austria, Belgium, France, Germany, Hungary, Spain, Sweden
Spain, Sweden
Panel B: Consolidated nancial statements of private nancial rms
Panel B: Consolidated nancial statements of private non-nancial rms
IFRS required Belgium, Bulgaria, Cyprus, Estonia, Greece, Italy, Latvia,
IFRS required Bulgaria, Cyprus, Malta, Slovakia Lithuania, Malta, Poland, Portugal, Romania, Slovakia, Slovenia
IFRS permitted Austria, Belgium, Czech Republic, Denmark, Estonia, Finland, IFRS permitted Austria, Czech Republic, Denmark, Finland, France, Germany,
France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Hungary, Iceland, Ireland, Liechtenstein, Luxembourg,
Latvia, Liechtenstein, Lithuania, Luxembourg, Netherlands, Netherlands, Norway, Spain, Sweden, United Kingdom
Norway, Portugal, Romania, Slovenia, Spain, Sweden, IFRS not allowed None
United Kingdom
IFRS not allowed Poland Panel C: Single entity annual accounts of private nancial rms

IFRS required Bulgaria, Cyprus, Estonia, Greece, Italy, Latvia, Lithuania, Malta,
Panel C: Single entity annual accounts of private non-nancial rms
Romania, Slovakia, Slovenia
IFRS required Bulgaria, Cyprus, Malta IFRS permitted Denmark, Finland, Iceland, Ireland, Liechtenstein, Luxembourg,
IFRS permitted Denmark, Estonia, Finland, Greece, Iceland, Ireland, Italy, Netherlands, Norway, United Kingdom
Liechtenstein, Lithuania, Luxembourg, Netherlands, Norway, IFRS not allowed Austria, Belgium, Czech Republic France, Germany, Hungary,
Slovakia Slovenia, United Kingdom Poland, Portugal, Spain, Sweden
IFRS not allowed Austria, Belgium, Czech Republic France, Germany, Hungary,
Latvia, Poland, Portugal, Romania, Spain, Sweden

among EU and EEA member countries with respect to these two


(Table 3, Panel B) compared to only four countries requiring IFRS for options. As indicated by the largest (smallest) mean values of any of
non-nancial rms (Table 2, Panel B). In about half of the EU and EEA the IFRS implementation choices for the consolidated accounts of pri-
member countries, exibility does not trump comparability when it vate nancial rms (annual accounts of private non-nancial rms),
comes to nancial rms, most likely because of a preference for fair EU and EEA member countries as a group are most (least) likely to
value accounting for nancial rms. require IFRS for these particular contexts.
A test of difference in means between nancial and non-nancial
rms with respect to the accounting for the single entity accounts of
4. Empirical results
public rms is not signicant at conventional levels (t = 1.36, p = .18,
two-tailed). However, a signicant difference in the exercise of imple-
The data reported in Tables 2 through 4 reveal similarities and differ-
mentation options for these two groups of rms exists for the single en-
ences among EU and EEA member states' exercise of available imple-
tity (t = 2.80, p b .01, two-tailed) and consolidated accounts (t =
mentation options under the IAS Regulation. To assess which
3.61, p b .01, two-tailed) of private rms. These statistically signicant
countries exercised their IFRS implementation options in a similar fash-
differences in IFRS implementation between nancial and non-nancial
ion, all implementation choices were coded such that higher (lower)
rms lend credence to the approach of tracking accounting implementa-
numbers indicate higher (lower) levels of IFRS integration into a
tion choices separately for nancial and non-nancial rms.
country's overall accounting system.12 If a given country requires IFRS
Following the empirical approach of Doupnik and Salter (1993) and
in a certain instance, it was scored 1; if the use of IFRS is prohibited,
D'Arcy (2001), I next employ agglomerative hierarchical cluster analysis
this choice was coded 1. If a country elected to permit rms to use
to identify groupings of EU and EEA member countries based on similar-
IFRS at their discretion, this choice was coded as the midpoint, hence
ities and differences in their exercise of IFRS implementation choices.
0. For the two dichotomous variables, deferral of application or not,
The results of this analysis will provide an answer to RQ1. In agglomer-
the choice to defer was coded 1 and 0 for not using this option.13
ative hierarchical cluster analysis, each case (country) initially consti-
Table 5 provides descriptive statistics, means, medians, standard de-
tutes its own, independent cluster. Because the distance between two
viations, and ranges of EU and EEA member states' implementation
cases that are alike will be small, clusters are formed based on distances
choices under the EU's IAS Regulation. The largest (smallest) standard
between cases. Cases that display the smallest distance to each other
deviation exists with respect to the single entity accounts of private
will be merged rst to form a cluster. In each subsequent step, the
nancial rms (consolidated accounts of private non-nancial rms),
next two nearest clusters will be merged until all cases have been com-
indicating the smallest (largest) uniformity of implementation elections
bined in one universal cluster in the nal step. Results are reported
12
based on the between-group linkage measured by the squared
For purposes of robustness, I applied a variety of coding schemes. None of these alter-
native coding schemes resulted in materially different results, as long as choices
Euclidean distance.14 A dendrogram depicting the combination of coun-
expanding (limiting) IFRS were consistently coded as high (low), or vice versa. Further- tries into clusters according to their IFRS implementation decisions is
more, because not all adoption choices may be of equal economic importance, I tested cod- reproduced in Fig. 2.
ing schemes that put higher weights on some items in an ad hoc fashion. Ultimately, I The cluster analysis reveals the existence of three primary groups of
opted for a non-weighted coding scheme for its ease of interpretability and because it is
countries. A cluster of nine countries at the left of the cluster solution is
difcult to establish unequal weights justied across all countries.
13
The deferral options may be considered less important than the other implementation formed by countries that did not implement IFRS into their accounting
choices. Also, member states' ability to defer application of IFRS for certain rms expired in
2007, and thus these elections are only of historical relevance. However, use of the deferral
14
options can be considered an important culture variable, indicating countries' supportive- Various alternate measures have been used to protect against the sensitivity of the
ness of the move toward IFRS. Inclusion, or exclusion, of these two variables in the scoring cluster solution to the choice of method. Alternate distance measures employed include
scheme, however, does not alter the result materially. If the deferral options are excluded, Euclidean distance, cosine, and Minkowski, in addition to dening clusters based on the
only one country is reclassied. Slovenia moves from the IFRS leaning to the IFRS integrat- within-group linkage, furthest neighbors, centroids, and Ward's method. The results also
ed group. remain qualitatively similar by using k-means clustering instead of hierarchical clustering.
192 A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195

Table 4
Deferred application of IAS regulation.

Chose to defer effective date of the IAS Regulation until 2007 Chose not to defer effective date of the IAS Regulation until 2007

Companies that only issue debt securities Austria, Belgium, Denmark, Finland, France, Germany, Hungary, Bulgaria, Cyprus, Czech Republic, Estonia, Greece, Italy, Latvia,
Iceland, Ireland, Luxembourg, Norway, Poland, Romania, Liechtenstein, Lithuania, Malta, Netherlands, Portugal, Slovakia,
Slovenia, Spain, Sweden United Kingdom
Companies admitted to public trading in a Austria, Belgium, France, Germany, Iceland, Luxembourg, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland,
non-member state and following other Norway, Romania Greece, Hungary, Ireland, Italy, Latvia, Liechtenstein, Lithuania,
internationally accepted standard for Malta, Netherlands, Poland, Portugal, Slovakia, Slovenia, Spain,
that purpose Sweden, United Kingdom

Table 5
Descriptive statistics of IFRS implementation option exercises.

Variable Mean Median St. dev. Min. Max. t-stats

Single entity annual accounts of publicly traded non-nancial rms 0.07 0.00 0.785 1.00 1.00
Single entity annual accounts of publicly traded nancial rms 0.17 0.00 0.791 1.00 1.00 t = 1.36
p = .18
Consolidated nancial statements of private non-nancial rms 0.1 0.00 0.403 1.00 1.00
Consolidated nancial statements of private nancial rms 0.47 0.00 0.507 0.00 1.00 t = 3.61
p b .01
Single entity annual accounts of private non-nancial rms 0.30 0.00 0.651 1.00 1.00
Single entity annual accounts of private nancial rms 0.03 0.00 0.850 1.00 1.00 t = 2.80
p b .01
Deferral for companies that only issue debt securities 0.53 1.00 0.507 0.00 1.00
Deferral for companies trading outside of the EU and EEA 0.27 0.00 0.450 0.00 1.00

Reported are the mean, median, standard deviation and range of IFRS implementation option exercises under the EU's IAS Regulation. Elections to require (permit, prohibit) IFRS in a certain
context are coded 1 (0, 1). Decisions to defer (not defer) the application of IFRS for specic groups of rms are coded 1 (0). t-statistics are for the difference in means (two-sided tests).

systems much, if at all, beyond the required scope of the IAS Regulation, countries identied as micro-based fall in the IFRS leaning group. Of
and can be considered IFRS antagonistic. Conversely, ten countries the ten macro-based countries, one is classied as IFRS integrated
grouped at the right side of the cluster solution display the highest (Italy) and three as IFRS leaning (Denmark, Finland, and Sweden). The
levels of IFRS implementation and can be labeled as IFRS integrated. In remaining countries (Belgium, France, Germany, Norway, Portugal,
between these two, a middle cluster of eleven countries emerges, com- and Spain) fall into the IFRS antagonistic group. Panel A of Table 7 dis-
prised of countries that may be named IFRS leaning. These countries plays a cross tabulation of the cluster results with Doupnik and Salter's
have expanded the scope of IFRS to some degree. classication.
Table 6 displays the cluster memberships of EU and EEA member A chi-square test of independence reveals that there is a statistically
states and the mean IFRS implementation for each group.15 The mean signicant relationship between the macro-uniform and micro-based dis-
IFRS implementation for antagonistic (leaning, integrated) countries is tinction and IFRS implementation at the p b 0.10 level, X2 (2) =5.600,
4.50 (0.55, 4.55). These values indicate that IFRS antagonistic coun- p = 0.061.16 Results of a Fisher's exact test are similar and conrm a
tries tend to make implementation choice generally in the direction of signicant relationship between the two categorizations, p = 0.105.17
not allowing IFRS (negative scores), whereas the on average high All but four countries (Bulgaria, Romania, Iceland, and Liechtenstein)
positive score of IFRS integrated countries indicates IFRS elections overlap with Nobes (2008) categorization of Class A and Class B
more consistent with requiring IFRS. Results of t-tests reported in accounting systems (Table 1, Panel B). Table 7, Panel B, shows a cross-
Table 6 indicate that differences in IFRS implementation between tabulation of the IFRS implementation clusters and Nobes (2008) classi-
clusters are statistically signicant. cations of countries into Class A (strong equity) and Class B (weak
The group of IFRS integrated countries, which have greatly expanded equity). Class A countries are predominantly IFRS leaning, while Class B
the use of IFRS beyond the limited mandate of the IAS Regulation, con- countries are spread out across all three implementation groups, with a
sists primarily of smaller and formerly communist European countries. dominance of IFRS antagonistic countries. A chi-square test again reveals
The inclusion of Italy and Greece in this group may appear surprising, a statistically signicant relationship between Nobes' taxonomy of coun-
but is based on these countries' legislative responses to the IAS Regula- tries and a classication of countries based on IFRS implementation at
tion. Countries informed by Anglo-American accounting practice (UK the p b 0.05 level, X2 (2) = 7.081, p = 0.029. A supplemental Fisher's
and Ireland) are not at the forefront of IFRS adoption, but included in exact test also conrms a signicant relationship, p = 0.022.
the IFRS leaning group. Scandinavian countries are also prominent in Finally, fteen EU and EEA countries are also included in the classi-
this group of countries. Finally, the group of IFRS antagonistic countries, cation by Leuz et al. (2003) and Leuz (2010), which is based on the
which did not expand the use of IFRS much beyond the scope of the IAS importance of the stock market for corporate nancing and the quality
Regulation, is compromised largely of countries inuenced by German of legal enforcement in each country (Table 1, Panel C). Table 7, Panel
and French accounting practice.
Fourteen of the countries included in this analysis are also found in
16
The chi-square test assumes that the expected value for each cell is ve or higher, an
the study by Doupnik and Salter (1993), who classify ten of these coun-
assumption that cannot be met given the small overlap of only 14 countries. An argument
tries as macro-uniform and four as micro-based (Table 1, Panel A). All can be made not to report chi-square tests if their results may not be valid because of small
sample size and low cell counts. However, reliance on these test statisticsdespite such
validity concernsis consistent with prior research (Nobes, 2008). The reporting of chi-
15
While this study does not use IFRS implementation scores for each countries, such square tests thus assures comparability. To address validity concerns, I introduce a meth-
scores can be easily derived. A country that requires IFRS for all contexts, and also has odological advance over Nobes (2008) and corroborate the reliability of the results by ad-
not chosen to defer the application of IFRS, will display a high score of 6, whereas a country ditionally conducting Fisher's exact test. Fisher's exact test is neither sensitive to small
prohibiting IFRS for all contexts, and also opting to defer the mandatory application of IFRS sample sizes nor to uneven or small cell counts.
17
to the maximum extent, will receive a low score of 8. Fisher's exact test does not provide a test statistic, but computes the p-value directly.
A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195 193

Fig. 2. Hierarchical classication of IFRS implementation choices.

C, displays a cross-tabulation with Leuz's (2010) classication. Both However, IFRS implementation choices also display remarkable
overlapping countries in the outsider/strong category (Ireland and the departures from these earlier categorizations, however. For instance,
United Kingdom) fall in the IFRS leaning category. Insider economies the Latin block, comprised of Italy, Greece, Portugal, and Spain, identi-
with strong legal enforcement are fairly evenly split between the IFRS ed in Nobes (2008), is split evenly between Italy and Greece in the IFRS
leaning/antagonistic categories and insider economies with weak legal integrated, and Portugal and Spain in the IFRS antagonistic cluster. None
enforcement between the IFRS integrated and IFRS antagonistic clus- of the strong equity countries identied by Nobes or Leuz are leading
ters. A chi-square test conrms again a statistically signicant associa- in IFRS implementation. Apart from Italy and Greece, the countries com-
tion between a taxonomy of countries based on IFRS implementation prising the IFRS integrated group (Cyprus, Malta, Bulgaria, Slovakia,
choices and Leuz's classication based on the development of equity Estonia, Latvia, and Lithuania) are all smaller, primarily formerly
markets and legal enforcement, X2 (4) = 12.429, p = 0.014. Fisher's communist countries. None of these countries can be said to have
exact test conrms this result, p = 0.016. strong, developed equity markets, yet they are leading in the imple-
Taken as a whole, these results provide solid evidence in support of mentation of market-oriented IFRS. Ramanna and Sletten (2009) and
H1. IFRS implementation choices and traditional accounting system Judge, Li, and Pinsker (2010), indeed, provide evidence that less power-
classications are not independent. These ndings corroborate Nobes ful countries are more likely to adopt IFRS. In the case of the former
(2008) conjecture that previous accounting classications can be used communist countries, the lack of a well-developed and entrenched
to predict and explain IFRS implementation decisions. The macro- domestic accounting system, combined with the cost of such a system's
economic, political, and legal factors which gave rise to earlier classica- development, and the desire to attract foreign capital (Daske et al.,
tions of accounting systems survive into the IFRS era by informing 2008), may also have played a role in their being at the forefront
countries' IFRS implementation choices. Specically, in areas not cov- of IFRS implementation. Consistent with these studies, observed
ered by the IAS Regulation, macro-uniform (weak-equity, insider- deviations in the association between IFRS implementation and prior
economy) countries largely require domestic GAAP and therefore tend accounting system classications indicate that EU and EEA member
to fall in the IFRS antagonistic group. Micro-based (strong-equity, states' IFRS implementation choices are based on a complex set of
outsider-economy) countries by contrast, are more open to IFRS and factors, not entirely captured by the drivers underlying the accounting
have a propensity to allow rms either to use domestic GAAP or IFRS systems classications of Doupnik and Salter (1993), Nobes (2008),
whenever the application of IFRS is not mandatory. and Leuz (2010).

Table 6
Cluster membership of EU and EEA member countries.

IFRS antagonistic group (Cluster 1) IFRS leaning group (Cluster 2) IFRS integrated group (Cluster 3)

Austria, Belgium, France, Germany, Hungary, Czech Republic, Denmark, Finland, Iceland, Ireland, Liechtenstein, Bulgaria, Cyprus, Estonia, Greece, Italy,
Poland, Portugal, Romania, Spain, Sweden Luxembourg, Netherlands, Norway, Slovenia, United Kingdom Latvia, Lithuania, Malta, Slovakia
Mean score = 4.50 = 0.55 = 4.55
t-tests of differences C1 vs. C2 C2 vs. C3 C1 vs. C3
between clusters t = 6.84, p b 0.001 t = 11.06, p b 0.001 t = 13.79, p b 0.001

Reported are groupings of EU and EEA member countries derived from a hierarchical cluster analysis of eight IFRS implementation choices under the EU's IAS Regulation. t-statistics are for
differences in country mean exercise of implementation options between country groupings (two-sided tests).
194 A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195

Table 7
Cross-tabulation of IFRS implementation groups with other classications.

Panel A: IFRS implementation groups versus Doupnik and Salter (1993) classication

Antagonistic group Leaning group Integrated group Total:

Macro-uniform Belgium, France, Germany, Norway, Denmark, Finland, Sweden Italy 10


Portugal, Spain
Micro-based None Ireland, Luxembourg, Netherlands, None 4
United Kingdom
Total: 6 7 1 14

Panel B: IFRS implementation groups versus Nobes (2008) classication

Antagonistic group Leaning group Integrated group Total:

Strong equity, commercially driven None Denmark, Ireland, Netherlands, Norway, Cyprus, Malta 7
United Kingdom
Weak equity, government driven, Austria, Belgium, France, Germany, Hungary, Czech Republic, Finland, Luxembourg, Estonia, Greece, Italy, Latvia, 19
tax-dominated Poland, Portugal, Spain, Sweden Slovenia Lithuania, Slovakia
Total: 9 9 8 26

Panel C: IFRS implementation groups versus Leuz (2010) classication

Antagonistic group Leaning group Integrated group Total:

Outsider/strong None Ireland, United Kingdom None 2


Insider/strong Austria, Belgium, France, Germany, Denmark, Finland, Netherlands, Norway None 10
Spain, Sweden
Insider/weak Portugal None Greece, Italy 3
Total: 7 6 2 15

5. Summary and conclusion Using hierarchical cluster analysis, I derive a classication of EU and
EEA member countries reecting the depth of IFRS implementation in
The primary contribution of this research lies in the development of each country's overall accounting system. The analysis reveals the exis-
a classication of the accounting systems of EU and EEA member coun- tence of an IFRS antagonistic, an IFRS leaning, and an IFRS integrated
tries, based on differences and communalities in IFRS implementation group of countries. Differences in IFRS implementation, Ball (2006) ar-
choices. Pronounced variation exists in the level of IFRS implementation gues, constitute a possible source for persistent cross-country variation
across member states of the EU and EEA. The study highlights statistical- in accounting quality, because uneven implementation of a uniform
ly signicant differences in the application of IFRS for nancial and accounting standard buries accounting inconsistencies at a deeper,
non-nancial rms. The qualitative data on the IFRS implementation less transparent level than more readily observable differences in stan-
elections presented here may be of interest to practitioners or re- dards. By providing a taxonomy of EU and EEA member countries based
searchers who may have assumed a more uniform adoption process. on a comprehensive review and analysis of cross-country differences in
The story of IFRS implementation in most member countries of the EU IFRS implementation, this study paves the way for future work assessing
and EEA is that of supplementation of domestic GAAP with IFRS for the relevance of cross-country differences in IFRS implementation on
specic uses. The implication for the ongoing debate concerning the various attributes of accounting.
adoption of IFRS in the U.S. is that framing the adoption question in Meek and Thomas (2004) and Nobes (2006, 2008) suggest examin-
terms of a substitution of accounting systems may be misspecied. ing whether universal adoption of IFRS has rendered traditional distinc-
Presumably the most meaningful area for future research on the ef- tions of accounting systems irrelevant. This study provides evidence
fects of IFRS implementation differences may be the differences in IFRS that three traditional taxonomies of accounting systemswhich distin-
implementation in the top and bottom left quadrants of Fig. 1. For the guish between macro-uniform and micro-based countries (Doupnik &
consolidated nancial statements of public rms, all member states of Salter, 1993; Nobes, 1983), strong equity, commercially driven, and
the EU and EEA must utilize IFRS. However, for the single-entity annual weak equity, government driven, accounting systems (Nobes, 1998,
accounts, IFRS or domestic GAAP may be applicable depending on each 2008), and insider and outsider economies (Leuz, 2010; Leuz et al.,
country's implementation choice reported in Panels A of Tables 2 and 3. 2003)continue to be important in the IFRS-era. Chi-square and
Some countries require IFRS for the preparation of single-entity ac- Fisher's exact tests reveal that the IFRS implementation elections of EU
counts; as a result no difference between the applicable accounting and EEA member countries are not independent of these accounting
standard for the preparation of single-entity and consolidated state- classications. A majority of EU and EEA member countries thus appear
ments exists. However, if domestic GAAP is permitted, or even required, to utilize their implementation options under the IAS Regulation consis-
for single-entity accounts, the potential for different outcomes is tent with the economic factors and accounting traditions which gave
present. While technically independent, it is likely that in countries rise to widely-used accounting classications identied in prior work.
requiring domestic GAAP for the preparation of single-entity accounts, Clearly, the adoption of IFRS throughout the EU and EEA did not
but IFRS for group accounts, any judgment involved in the preparation result in a breakdown of traditional accounting families. Much to
of consolidated statements under IFRS may be exercised in accordance the contrary, consistent with Nobes (2008), the evidence suggests
with domestic GAAP for reasons of convenience (Nobes, 2006) or to that traditional accounting classications permeate countries' IFRS
avoid cognitive dissonance.18 implementation decisions. Traditional accounting classications have
therefore not become obsolete, but remain useful to explain and predict
IFRS implementation. The limited overlap of countries with the catego-
18
Evidence for this conjecture is provided by Macas and Muio (2011), who nd that rizations by Doupnik and Salter (1993) and Leuz (2010), however, must
the explanatory power of earnings and equity book value for stock prices, as well as the
ability of earnings to explain cash ows, is lower for rms domiciled in countries which re-
be noted as a practical limitation to assessing fully the survival of these
quire the preparation of single-entity annual accounts using domestic GAAP, as compared accounting classications in the IFRS era. Moreover, the current study
to rms domiciled in countries where IFRS is acceptable for single-entity annual accounts. only provides a snapshot of the implementation decisions in force at
A. Forst / Advances in Accounting, incorporating Advances in International Accounting 30 (2014) 187195 195

the time of this writing. As EU and EEA member countries revise and/or Judge, W., Li, S., & Pinsker, R. (2010). National adoption of international accounting stan-
dards: An institutional perspective. Corporate Governance: An International Review,
expand their use of IFRS, researchers in the future may wish to reassess 18(3), 161174.
whether or not traditional accounting classications continue to be Leuz, C. (2010). Different approaches to corporate reporting regulation: How jurisdictions
relevant in the IFRS era. differ and why. Accounting and Business Research, 40(3), 229256.
Leuz, C., Nanda, D., & Wysocki, P. (2003). Earnings management and investor protection:
An international comparison. Journal of Financial Economics, 69, 505527.
Macas, M., & Muio, F. (2011). Examining dual accounting systems in Europe.
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Meek, G. K., & Thomas, W. B. (2004). A review of markets-based international accounting
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I especially thank the associate editor, Robert Larson, and two anon- Mueller, G. G. (1968). Accounting principles generally accepted in the United States ver-
ymous referees for their helpful comments and suggestions. For their sus those generally accepted elsewhere. International Journal of Accounting, 3(1),
comments on an earlier draft of this paper, I am also grateful to the 91103.
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