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Auditing in Britain and Germany compared: professions, knowledge and the state

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  • Holger Vieten

Abstract

In an attempt to move away from dichotomous expositions of state-run Germany and self-regulated Britain this paper seeks to analyse the regulation of auditing in terms of a state-profession axis (Hopwood, 1988: 559) that shifts over time. Stereotypical beliefs of Britain and Germany representing diametrically opposite systems of regulation can be contradicted in the light of increasing state involvement in Britain and the recognition that the German system is not adequately characterized by rigid and exhaustive codification, but relies to a significant degree on professional expertise. However, differences do exist, especially in the nature of regulation, which takes an informal shape in Britain, and in the production and diffusion of knowledge where academics and preparers are much more involved in Germany. The case of auditor independence illustrates some of the similarities and differences exposed by an analysis that aims to interpret regulatory systems in their national and historical context rather than producing simplistic general models.

Suggested Citation

  • Holger Vieten, 1995. "Auditing in Britain and Germany compared: professions, knowledge and the state," European Accounting Review, Taylor & Francis Journals, vol. 4(3), pages 485-514.
    • Handle: RePEc:taf:euract:v:4:y:1995:i:3:p:485-514
    DOI: 10.1080/09638189500000029
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    References listed on IDEAS

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    1. Michael Moran, 1991. "The Politics of the Financial Services Revolution," Palgrave Macmillan Books, Palgrave Macmillan, number 978-0-230-37789-9, December.
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    1. Ojo, Marianne, 2008. "The role of the external auditor in bank regulation and supervision: A comparative analysis," MPRA Paper 15747, University Library of Munich, Germany, revised Jun 2009.
    2. Löhlein, Lukas & Müßig, Anke, 2020. "At the boundaries of institutional theorizing: Individual entrepreneurship in episodes of regulatory change," Accounting, Organizations and Society, Elsevier, vol. 83(C).
    3. Gietzmann, M. B. & Quick, R., 1998. "Capping auditor liability: The German experience," Accounting, Organizations and Society, Elsevier, vol. 23(1), pages 81-103, January.
    4. Lisa Evans & Christopher Nobes, 1998. "Harmonization of the structure of audit firms: incorporation in the UK and Germany," European Accounting Review, Taylor & Francis Journals, vol. 7(1), pages 125-148.
    5. Maria Antonia Garcia Benau & Emiliano Ruiz Barbadillo & Christopher Humphrey & Walid Al Husaini, 1999. "Success in failure? Reflections on the changing Spanish audit environment," European Accounting Review, Taylor & Francis Journals, vol. 8(4), pages 701-730.
    6. Vlad‐Andrei Porumb & Abe De Jong & Carel Huijgen & Teye Marra & Jan Van Dalen, 2021. "The Effect of Auditor Style on Reporting Quality: Evidence from Germany," Abacus, Accounting Foundation, University of Sydney, vol. 57(1), pages 1-26, March.
    7. Constantinos V. Caramanis, 1997. "The enigma of the Greek auditing profession: some preliminary results concerning the impact of liberalization on auditor behaviour," European Accounting Review, Taylor & Francis Journals, vol. 6(1), pages 85-108, May.
    8. Ojo, Marianne, 2007. "The role of the external auditor in bank regulation and supervision: A comparative analysis between the UK, Germany, Italy and the US," MPRA Paper 32614, University Library of Munich, Germany, revised Jan 2008.
    9. McLeay, Stuart & Ordelheide, Dieter & Young, Steven, 2000. "Constituent lobbying and its impact on the development of financial reporting regulations: evidence from Germany," Accounting, Organizations and Society, Elsevier, vol. 25(1), pages 79-98, January.
    10. Antonelli, Valerio & D'Alessio, Raffaele & Lauri, Lucia & Marcello, Raffaele, 2024. "Professional bodies and professional closure strategies: The field of auditing for small and medium-sized enterprises in Italy☆," CRITICAL PERSPECTIVES ON ACCOUNTING, Elsevier, vol. 99(C).
    11. Ojo/Roedl, Marianne, 2008. "The role of the external auditor in bank regulation and supervision: A comparative analysis between the UK, Germany, Italy and the US (Third Edition: Financial Crises, Enron and Northern Rock)," MPRA Paper 36284, University Library of Munich, Germany, revised Jun 2009.

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