1 オックスフォード レポート Oxford Report 世 界 の 持 続 的 発 展 を 目 指 す 自 見 チーム 日 本 の 経 済 社 会 に 対 するIFRSの 影 響 に 関 する 調 査 研 究 The Impact of IFRS on Wider Stakeholders of Socio-Economy in Japan 2012 年 3 月 30 日 30 th March, 2012 オックスフォード 大 学 トモ スズキ( 教 授 ) Professor Tomo Suzuki University of Oxford This report is intended as a basis for policy discussion only. Whilst every effort has been made to ensure the accuracy and completeness of the material in this report, the author gives no warranty in that regard and accepts no liability for any loss or damage incurred through the use of, or reliance upon, this report or the information contained herein. The opinions expressed here are those of the author and do not necessarily reflect the positions of the Government of Japan or any other institutions. Tomo Suzuki. March 2012 SAID SUBISNESS SCHOOL, The University of Oxford, Oxford, OX1 1HP, United Kingdom.
6 Executive Summary This report addresses the impact of the potential mandatory adoption of International Financial Reporting Standards (IFRS) in Japan. Our findings are drawn from an extensive Oxford University study of IFRS adoption in Asian countries, which is based on wide-ranging evidence from interviews, surveys and other sources. We conclude that the premature and wholesale adoption of IFRS is likely to cause decreased transparency and comparability of financial statements, and fail to achieve the stated goals of IFRS. Furthermore, we suspect that abandoning Japanese accounting standards in favour of IFRS would have undesirable impact on a variety of aspects of the socio-economy which are important for the management of Japan s mature economy. We recommend that Japan continue to be proactive in developing better international accounting standards by actively participating in the standard setting process. The fundamental objective of the UNIAS Project (Unexplored Impact of International Accounting Standards / International Financial Reporting Standards: Phase I: ; University of Oxford) is to evaluate the impact of global standardization of accounting on a variety of stakeholders in Asian countries, primarily China, India and Japan. In this report, which is only a part of the UNIAS Project, we focus our attention exclusively on Japan where a policy discussion is currently taking place to determine an appropriate form of IFRS adoption which would best serve the country s socio-economy as a whole. After a brief review of Japan s modern accounting history, which was developed to serve its broad socio-economy rather than the narrower interests of investors alone, we examine the ways in which International Accounting Standards Board (IASB) came to have a significant impact on Japan s accounting standards setting (Section 1). In the early stage of IFRS introduction in Japan, some empirically-unverifiable theory and rhetoric were (and still are) used to push the idea of global accounting. As the standard hypothetico-statistical method and surveys do not help much in such circumstances, we developed a long-term dialectic interview method instead. We conducted approximately 1,000 units of interviews with a variety of stakeholders including ministers of relevant departments, accounting standards board members, executives of multinational companies and small local businesses, over an extended time period ( ) that included the whole life-span of the IASB. The rationale for this long-term dialectic interview was primarily to discover unexplored and unintended consequences of IFRS, and to promote effective communication between different stakeholders who had little opportunity and means to exchange their views over merits and demerits of adopting IFRS (Section 2). 6
7 We have also conducted a comprehensive review of the literature (637 articles in Japanese and 72 academic papers in English) to guide our interpretations of the interview data. On balance, the literature suggests that the degree of transparency and comparability of financial statements has actually declined after the adoption of IFRS. However, the same set of papers also shows that the statistical correlation between accounting and capital market returns (often misleadingly labelled value-relevance in many academic studies) increased slightly. This result may appear as a paradox (e.g., Brüggeman, Hitz, & Sellhorn, 2012). However, since IFRS have resorted to accounting from the markets, instead of accounting for the markets, this is neither surprising, nor an argument that supports adoption of IFRS. Testimonies from CFOs of the top Japanese firms and sophisticated investors across the world reveal that (1) transparency and comparability are actually damaged due to principles-based fair value accounting which allows management to have more discretion over subjective valuation and accounting choices. However, (2) the label of high quality global standards, having been slapped on IFRS, misleads many, especially un-sophisticated investors who tend to react to the face value of reported income without investigating accounting policies and footnotes. Both factors (1) and (2) can create an artificial reality in a world of short-term investment behaviour, and degrade objective, transparent and comparable accounting data. The result is likely to distort share prices as well as managerial decisions (Section 3). From the viewpoint of production and operation, rather than finance, such potential distortions have already caused serious concerns among top Japanese companies. For example, under the Japanese accounting standards, goodwill is required to be amortized on a regular basis, and also the development costs are to be expensed as they are incurred, whereas IFRS disallows amortization of goodwill and allows capitalization of development costs. Executives of top firms recognise that these IFRS standards provide managers yet another instrument for income smoothing. Adoption of IFRS in Japan is likely to damage its long cherished disciplined management philosophy. The departure from long-established practice of historical cost accounting and conservatism are also among the most serious concerns, which would undermine the foundation of long-term investment and innovation that have been the key strengths of Japanese management. Furthermore, industries such as banks and insurance companies are concerned that the introduction of fair value accounting which would fundamentally and negatively change, their business models. We identified a consensus view among CFOs, who have already adopted IFRS, that the adoption of IFRS had not reduced the cost of capital. In general, many CFOs anticipate increasing costs of regulation, including the audit fees, under the principles based global regulation (Section 4). 7
8 Despite the fact that major stakeholders had significant concerns over the impact of IFRS, the mandatory adoption of IFRS was presumed (between June 2009 and June 2011) to be the established government policy. We explored the mechanism by which this false impression of mandatory adoption was created, and identified some loud, repeated and highly effective rhetoric which was put forward by pro-ifrs businesses and political camps. By now (March, 2012), the major stakeholders, including Financial Services Agency (FSA), Ministry of Economy, Trade and Industry (METI) and Keidanren as well as individual companies, have seen through and demystified this rhetoric of global accounting and found it to be without logical or evidentiary foundations. However, they still need to engage themselves in politics of international accounting standards setting so that international accounting standards would be improved in substance and not in mere rhetoric in the future. To this end, the Report recommends that all stakeholders collaborate to enhance proactive rather than reactive efforts towards international convergence. This may lead to the adoption of a single set of accounting standards in the distant future, but such a course of history depends on several important parameters including evidence (and not just rhetoric) of IFRS leading to higher quality accounting in some clearly understood and measurable fashion; improved governance of IASB and an active, effective, and reasonable participation of advanced as well as emerging economies (Section 5). Please quote as: Suzuki, Tomo (2012) The Impact of IFRS on Wider Stakeholders of Socio-Economy in Japan. On the request of the State Minister Shozaburo Jimi, Financial Services Agency, the Government of Japan. First submitted: 30 th March, 2012 in Tokyo. 217 pages. Professor Tomo Suzuki, Saïd Business School, University of Oxford, OX1 1HP UK.. For details, please contact the Principal Researcher: Professor Tomo Suzuki Head of Accounting Group Saïd Business School University of Oxford Oxford OX1 1HP, UK. 8
20 とえば 佐 藤  は 2002 年 10 月 の 金 融 庁 の 羽 藤 参 事 官 の 発 言 や 2003 年 5 月 の 法 務 省 の 見 解 あるいは 経 団 連 の 意 向 を 引 用 しながら 2000 年 代 半 ばまでは 日 本 でもグ ローバルな 資 金 調 達 を 円 滑 化 するための1つの 措 置 として 相 互 承 認 の 方 針 が 重 視 され てきたことを 明 らかにしている 日 本 ではこうした 相 互 承 認 のため アメリカでの 動 向 を 注 視 しつつ 自 らの 発 言 力 をいかに 高 めるかという 点 に 腐 心 していた しかし EU が 2004 年 10 月 に EU 域 内 に 上 場 する 域 外 企 業 に 対 して IFRS と 同 等 の 国 際 的 な 会 計 基 準 の 採 用 を 求 める 方 針 を 打 ち 出 すと にわかに 日 本 基 準 は EU の 同 等 性 評 価 を 意 識 した 会 計 基 準 の 策 定 を 積 極 的 に 行 うようになった この 結 果 2008 年 10 月 に EU の 同 等 性 評 価 を 受 け 日 本 基 準 は 国 際 的 な 会 計 基 準 と 同 等 であると 認 められるに 至 った にもかかわらず 日 本 ではさらに IFRS とのアドプションの 可 能 性 を 強 く 示 唆 した 動 き が 進 展 していった 後 述 するようにアメリカでの 動 向 が 後 退 したにもかかわらず 日 本 は 米 国 にも 先 行 して 2009 年 6 月 の 企 業 会 計 審 議 会 中 間 報 告 で IFRS のアドプ ションの 可 能 性 が 強 く 示 唆 されるに 至 った( 第 五 節 参 照 ) 米 国 にも 先 行 して とし たのは 以 下 の 理 由 による 米 国 は 2009 年 1 月 これまで IFRS 導 入 を 積 極 的 に 推 進 し てきたコックス SEC 委 員 長 に 代 わり シャピロ SEC 委 員 長 が 就 任 し 急 激 な IFRS 導 入 に 対 する 慎 重 な 姿 勢 を 示 し 始 めた 9 ( 注 にあるように 明 確 に IFRS に 対 する 慎 重 姿 勢 が 見 て 取 れる) これに 対 して 日 本 は 2009 年 6 月 に 至 っても 広 範 囲 のアドプションの 可 能 性 を 含 む 更 なる IFRS 推 進 の 方 針 を 打 出 したと 同 時 に さらなるコンバージェンス が 進 められた 9 上 記 シャピロ 氏 の 上 院 銀 行 委 員 会 での 証 言 は 以 下 の 通 りである Ms. SCHAPIRO: Well, I would proceed with great caution so that we don t have a race to the bottom. I think we all can agree that a single set of accounting standards used around the world would be a very beneficial thing, allowing investors to compare companies around the world. That said, I have some concerns about the road map that has been published by the SEC and is out for comment now and I have some concerns about the IFRS standards generally. They are not as detailed as the U.S. standards. There is a lot left to interpretation. Even if adopted, there would still be a lack of consistency, I believe, around the world in how they are implemented and how they are enforced. The cost to switch from U.S. GAAP to IFRS is going to be extraordinary, and I have seen some estimates that range as high as $30 million for each U.S. company in order to do that. This is a time when I think we have to think carefully about whether imposing those sorts of costs on U.S. industry really makes sense. Perhaps, though, my greatest concern is the independence of the International Accounting Standards Board and the ability to have oversight of their process for setting accounting standards and the amount of rigor that exists in that process today. I will tell you that I will take a big deep breath and look at this entire area again carefully and will not necessarily feel bound by the existing road map that is out for comment. (Shapiro, 2009, pp ). 20
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