Comparison of German and French accounting law: a systemic approach.

Summary The IASB is seeking accounting standards that are both accepted and theoretically sound. This internal consistency of accounting standards sought by the IASB aims to establish a set of accounting principles and rules that are free of logical contradictions in the sense of normative accounting theories. The question of consistency and the measurement of consistency in an accounting system is the subject of much discussion in the international literature. The purpose of this thesis is to present an in-depth study of the Anglo-Saxon concept of "consistency". Through a systematic comparison of accounting in Germany and France, the systemic thinking behind an accounting system is identified as an essential influencing factor for the development of a national understanding of accounting and the concept of "consistency". In particular, it will be shown that German and French accounting law are not typical examples of a European accounting model and that the systemic thinking inherent in an accounting system fundamentally influences the harmonization of national accounting with IFRS.