Comparative study of accounting systems in the countries of the Arab Maghreb Union (AMU)[Étude comparative des systèmes comptables dans les pays de l'Union du Maghreb Arabe (UMA)]

This article attempts to identify the main components of the accounting system of each country of the Arab Maghreb Union (AMU) in order to establish a comparison between the accounting systems of these countries. This will enable researchers, professionals and students in the Maghreb to gain a better understanding of theaccountingregulations in forcein neighbouring countries. Indeed, faced with the various political rivalries and economic difficulties affecting certain regions of the Maghreb, it seems that Maghrebians have lost hope in the construction of the ‘Greater Maghreb' and are only concerned with their daily national lives. The intra-Maghreb comparison of accounting systems will enable us to determine whether there are any similarities or differences between thesesystems within the Maghreb, and to what extent they are inspired by the two major standard-setting models in the world, namely the continental European model and the Anglo-Saxon model. Having collected the texts and laws governing each accounting system in the AMU countries and analysed the content of the various components of these systems, our comparative study highlights two fundamental observations.On the one hand, in Tunisia and Algeria, accounting standard-setting is characterised by a hybrid accounting system comprising two components: an Anglo-Saxon component, reflected in the explicit adoption of a conceptual framework based on the IASB's accounting framework, and an explicitFrench-speaking component, reflected in the enactment of legislationestablishing a chart of accounts, accounting rules and models to be followed in thepreparation of financial statements. On the other hand, in Morocco and Mauritania, accounting standards are strongly inspired by the French continental model, but implicitly refer to the objectives and principles of international accounting standards.