【正文】
27 ( 二)基于法律體系的會(huì)計(jì)模式分類 Accounting may also be classified by a nation’s legal system. This view has dominated accounting thinking for the last 25 years or so. 28 (1)Accounting in mon law countries is characterized oriented toward “fair presentation”, transparency and full disclosure, and a separation between financial and tax accounting. Stock markets dominate as a source of finance and financial reporting is aimed at the information needs of outside investors. Accounting standards setting tends to be a privatesector activity with an important role played by the accounting profession. 29 Common law accounting is often called “AngloSaxon”, “BritishAmerican”, or “micro based.” Common law accounting originated in Britain and was exported to such countries and areas as Australia, Canada, Hong Kong, India, Malaysia, Pakistan ,and the United State. 30 (2) Accounting in Code law countries is characterized as legalistic in its orientation, opaque with low disclosure, and an alignment between financial and tax accounting. Banks or governments (“insiders) dominate as a source of finance and financial reporting is aimed at creditor protection. Accounting standard setting tends to be a publicsector activity with relatively less influence by the accounting profession. 31 A mon law legal system emphasizes shareholder rights and offers stronger investor protection than a code law system. Laws protect outside investors are generally well enforced. The oute is that strong capital markets develop in mon law countries and weak ones develop in code law countries. 32 Relative to code law countries, firms in mon law countries raise substantial amounts of capital through public offerings to numerous investors. Because investors are at arm’s length to the firm, there is a demand for accounting information that accurately reflects a firm’s operating performance and financial position. Public disclosure resolves information asymmetry between the firm and investors. 33 By contrast, ownership of firms in code law countries tends to be concentrated in the hands of