Les provisions pour risques et charges en France et en Allemagne à la lumière des évolutions internationales récentes

In financial accounting, provisions are of major importance. On the theoretical level, they reflect fundamental accounting principles on which the financial accounting concept of a country is based (in particular role of the prudence principle and of the matching principle). On the practical level, provisions offer considerable latitude of discretion with regard to measurement. Thus, they offer possibilities for creative accounting" and, in consequence, are of special interest for analysis. The article concentrates on provisions in France and in Germany. The first part of the article describes and discusses the relevant rules for accounting for provisions in the two countries, including tax considerations. The second part analyses the differences, referring in particular to the historic background and to international developments. The third and last part shows the consequences of the findings for the comparative analysis of French and German financial reports. The article will show that, eventhough France and Germany have common roots with regard to financial reporting and in spite of harmonization and internationalization, differences with regard to format, to pension liabilities and to certain provisions for maintenance prevail. In particular the latter may form an obstacle to the comparative analysis of French and German financial reports.