Une illustration des difficultés de l'harmonisation internationale : la comptabilisation des marques en France, en Allemagne et selon les règles de l'IASC

It is often stressed that the process of IASC standard setting and its output are very much influenced by the Anglo-American accounting approach. This is considered to be one of the major reasons for the obvious reluctance of countries to adopt the international accounting standards. The importance given to the two accounting characteristics of " reliability " and " relevance " and their mutual relationship is one of the dominant reasons for the differences between the Continental- European and the Anglo-American accounting philosophy. An area where this competing relationship between relevance and reliability becomes highly obvious is in accounting for intangible assets, and namely for brands. It is then highly interesting to study whether the treatment developed by the IASC differs from the accounting practice in Continental European countries and to consider if it could be adopted easily by enterprises in those countries. That is the main objective of this article, which compares the positions adopted in IAS 38 concerning brands and the related practices in France and Germany. Despite the existence of numerous points of convergence, the article shows some major differences between two countries supposed to follow relatively similar rules. It tends then to draw our attention on the difficulty of international harmonization.