Les critères de reconnaissance des actifs et des passifs en droit comptable allemand : une analyse par référence au système français

Within the European Union the assigned goal of the fourth directive was to facilitate the comparison of individual financial statements from the member states. However, any attempt to compare France and Germany in this respect would give a false picture as fundamental differences persist despite European standardization. The interpretation and use that is made of the principle of caution is probably one of the most significant sources of disharmony between French and German annual accounts. The elements of this conservatism were studied in three previous articles that dealt successively with the preponderance of the commercial balance sheet over the tax; balance sheet, the specificities of the appropriation of profit, and the particularities of some kinds of accruals. However, this extreme interpretation of the principle of caution is not limited to these particular cases ; its effects can be felt on German accounting law as a whole in which the concepts of assets and liabilities ate very different from those that prevail in France. The goal of this fourth study is to bring these principles to light by emphasizing intangibles that are obviously highly sensitive components owing to their uncertain valuation.