Álit: tímarit löggiltra endurskoðenda - 01.01.1993, Side 23

Nordic countries have a problem that does not
concem Iceland. Denmark, Finland, Norway and
Sweden all have two-tier accounting professions,
i.e. a structure with authorised public accountants
who have unlimited statutory audit privileges, and
registered, or approved, public accountants with a
lower level of professional education who can audit
only small and medium-sized companies. We are
spending a lot of resources to figure out a way to fit
this structure into the world of the 8th directive.
Mutual recognition
Young colleagues and accountancy students
often ask about the mutual recognition directive.
This is quite natural, since the idea of a Europe
without national borders must appeal to a young
woman or man in the profession. Unfortunately, the
mutual recognition directive is not the panacea
against isolationism that many believe. The
directive, which is a good example of the Cassis de
Dijon" principle, and of “home country control”,
does not open the field for cross-border services.
Also, it covers only activities by individuals, not by
firms - and as we all know intemational
accountancy work is teamwork, carried out by
firms. What the directive does say is that an EEA
state (the host country), in granting licences to carry
out regulated professional work, has to recognize a
licence issued by another EEA state (the home
country) to an individual who wishes to settle down
in the host country and practice in the regulated
area. The host country may, however, apply an
aptitude test or require an adaptation period of a
maximum of three years to guarantee the
applicant’s ability in areas that are not covered by
the examination procedure in the home country. In
our field the typical area for testing would be
national business and tax law. Honestly, 1 do not
believe that this directive will open your borders to
a flood of foreign accountants who want to compete
in the Icelandic market. There is nothing in the
directive to prevent you from giving the aptitude
test in Icelandic, if you are at all worried - that
would probably be an efficient way to convert the
flood into a trickle. It is characteristic of the
development in the E.C. legal environment that the
E.C. Court of Justice last summer took a decision
that may make the future of our intemationally
minded young colleagues look less dark than I have
depicted it now. I am referring to the well-known
Ramrath21 case - well known at least to E.C. law
students. However, Ramrath is still being
interpreted by experts and I would be foolish to
volunteer a personal interpretation before those who
know have had their say.
A Nordic influence?
The European Economic Area is a Europe of 370
million people with a gross national product
exceeding that of the United States. Quite clearly, it
provides ample opportunity to apply the economy
of scale. At the same time, however, it is natural
that we in the Nordic countries ask ourselves what
our position will be in this tremendous market.
Iceland accounts for Iess that 0.1 percent of the
population. It is true that my own country is a little
bigger, but even so it makes up only 2 percent of
Europe, population-wise. Does this mean that our
role in the future Europe is to receive orders and
obey them? My answer is no. First of all, neither
Iceland nor Sweden stands alone when we face the
professions of the large countries. You are probably
aware that the five Nordic institutes of authorised
public accountants cooperate closely in the Nordic
Federation of Accountants, NRF. By the way, NRF
is probably the oldest intemational association of
accountants that is still in existence: it was founded
in 1931. The five institutes have equal voting rights
in NRF (although during the twelve years I have
been involved in the work of NRF no decision has
ever been taken by any other means than
consensus). For a two-year period every decade, the
President of NRF is an Icelander, most recently
Gunnar Sigurðsson. Secondly, the profession’s way
to communicate with the E.C. Commission is our
European federation, Fédération des Experts
Comptables Européens (FEE). The idea of FEE is to
be the one strong voice of the European
accountancy profession. It is interesting to notice
that FEE is the result of a merger between two
professional European organisations, the U.E.C.
(Union Européenne des Experts Comptables
Economiques et Financiers) and the Groupe
d’études des experts comptables de la C.E.E. It is a
reason for pride to the accounting profession that
U.E.C. was founded in 1951, six years before the
Treaty of Rome, and that it was the first European
professional body to offer ntembership on equal
terms to the defeated Germany. The way to gain
influence in FEE is not to represent a large country,
but to demonstrate competence and high
professional standards. And even where formal
voting is concerned it is worth noticing that the
Nordic countries together have 20 votes. This can
be compared to the voting power of the United
Kingdom, 24 votes, the Netherlands, 18 votes, or
Spain, 14 votes. I do not think I exaggerate when I
say that the other members of FEE listen carefully
to the Nordic voice. Now that we all will become
involved in the European issues, by membership of
the Community or by being parties to the agreement
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