N-CSR

                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D. C. 20549

                                   FORM N-CSR

Investment Company Act file number 811-04760

                             SCUDDER ADVISOR FUNDS
                        --------------------------------
               (Exact Name of Registrant as Specified in Charter)


                   One South Street, Baltimore, Maryland 21202
                  --------------------------------------------
               (Address of Principal Executive Offices) (Zip Code)

        Registrant's Telephone Number, including Area Code: (617) 295-2663
                                                            --------------

                               Salvatore Schiavone
                             Two International Place
                           Boston, Massachusetts 02110
                     ---------------------------------------
                     (Name and Address of Agent for Service)

Date of fiscal year end:        10/31

Date of reporting period:       10/31/03



ITEM 1.  REPORT TO STOCKHOLDERS

[Scudder Investments logo]

Scudder International Equity Fund
	Classes A, B, C and Investment
	Annual Report to Shareholders
	October 31, 2003

Contents

<Click Here> Performance Summary

<Click Here> Portfolio Management Review

<Click Here> Portfolio Summary

Scudder International Equity Fund

<Click Here> Financial Statements

<Click Here> Financial Highlights

<Click Here> Notes to Financial Statements

<Click Here> Report of Independent Auditors

<Click Here> Tax Information

<Click Here> Trustees and Officers

International Equity Portfolio

<Click Here> Investment Portfolio

<Click Here> Financial Statements

<Click Here> Financial Highlights

<Click Here> Notes to Financial Statements

<Click Here> Report of Independent Auditors

<Click Here> Investment Products

<Click Here> Account Management Resources

Scudder Investments is part of Deutsche Asset Management, which is the marketing name in the US for the asset management activities of Deutsche Bank AG, Deutsche Investment Management Americas Inc., Deutsche Asset Management Inc., Deutsche Asset Management Investment Services Ltd., Deutsche Bank Trust Company Americas and Scudder Trust Company.

This report must be preceded or accompanied by a prospectus. To obtain a prospectus for any of our funds, refer to the Account Management Resources information provided in the back of this booklet. The prospectus contains more complete information, including a description of the risks of investing in the fund, management fees and expenses. Please read it carefully before you invest or send money.

Fund shares are not FDIC-insured and are not deposits or other obligations of, or guaranteed by, any bank. Fund shares involve investment risk, including possible loss of principal.

Performance Summary October 31, 2003

Average Annual Total Returns* (Unadjusted for Sales Charge)
Scudder International Equity Fund	1-Year	3-Year	5-Year	10-Year
Class A(a)	19.95%	-9.52%	-2.93%	5.66%
Class B(a)	19.07%	-10.23%	-3.67%	4.86%
Class C(a)	19.03%	-10.20%	-3.65%	4.87%
Investment Class+	19.85%	-9.54%	-2.94%	5.65%
MSCI EAFE Index++	27.03%	-6.11%	-.22%	3.23%

Sources: Lipper Inc. and Deutsche Asset Management Inc.

Net Asset Value and Distribution Information
	Class A	Class B	Class C	Investment Class
Net Asset Value: 10/31/03	$ 9.59	$ 9.49	$ 9.32	$ 18.72
10/31/02	$ 8.00	$ 7.97	$ 7.83	$ 15.63
Distribution Information: Twelve Months:
Income Dividends	$ .01	$ -	$ -	$ .01

Investment Class Lipper Rankings* - International Funds Category
Period	Rank		Number of Funds Tracked	Percentile Ranking
1-Year	641	of	835	77
3-Year	424	of	637	67
5-Year	401	of	478	84
10-Year	31	of	119	26

Rankings are historical and do not guarantee future results. Rankings are based on total return with distributions reinvested.

Source: Lipper Inc.

Growth of an Assumed $10,000 Investment^*(b) (Adjusted for Sales Charge)

[] Scudder International Equity Fund - Class A^(c)

[] MSCI EAFE Index⁺⁺

Yearly periods ended October 31

Comparative Results* (Adjusted for Sales Charge)
Scudder International Equity Fund		1-Year	3-Year	5-Year	10-Year
Class A(c)	Growth of $10,000	$11,305	$6,980	$8,123	$16,343
	Average annual total return	13.05%	-11.29%	-4.07%	5.03%
Class B(c)	Growth of $10,000	$11,607	$7,161	$8,251	$16,073
	Average annual total return	16.07%	-10.53%	-3.77%	4.88%
Class C(c)	Growth of $10,000	$11,784	$7,170	$8,219	$15,929
	Average annual total return	17.84%	-10.50%	-3.85%	4.77%
MSCI EAFE Index++	Growth of $10,000	$12,703	$8,276	$9,888	$13,745
	Average annual total return	27.03%	-6.11%	-.22%	3.23%

The growth of $10,000 is cumulative.

Growth of an Assumed $10,000 Investment^*

[] Scudder International Equity Fund - Investment Class

[] MSCI EAFE Index⁺⁺

Yearly periods ended October 31

Comparative Results*
Scudder International Equity Fund		1-Year	3-Year	5-Year	10-Year
Investment Class+	Growth of $10,000	$11,985	$7,401	$8,613	$17,329
	Average annual total return	19.85%	-9.54%	-2.94%	5.65%
MSCI EAFE Index++	Growth of $10,000	$12,703	$8,276	$9,888	$13,745
	Average annual total return	27.03%	-6.11%	-.22%	3.23%

The growth of $10,000 is cumulative.

Notes to Performance Summary

^* Returns and rankings during all periods shown reflect a fee waiver and/or expense reimbursement. Without this waiver/reimbursement, returns and rankings would have been lower.
^a Returns shown for Class A, B and C shares for the periods prior to their inception on June 29, 2001 are derived from the historical performance of Investment Class shares of the International Equity Fund during such periods and have been adjusted to reflect the higher gross total annual operating expenses of each specific class. Any difference in expenses will affect performance.
^b The Fund's growth of an assumed $10,000 investment is adjusted for the maximum sales charge of 5.75%. This results in a net initial investment of $9,425.
^c Returns shown for Class A, B and C shares for the periods prior to their inception on June 29, 2001 are derived from the historical performance of Investment Class shares of the Scudder International Equity Fund during such periods and have been adjusted to reflect the higher gross total annual operating expenses and the current applicable sales charges of each specific class. Returns for Class A reflect the current maximum initial sales charge of 5.75%. Class B share performance is adjusted for the applicable contingent deferred sales charge ("CDSC"), which is 4% within the first year after purchase, declining to 0% after six years. Returns for Class C shares reflect an initial sales charge of 1%. Redemptions on Class C shares within one year of purchase may be subject to a CDSC of 1%. Any difference in expenses will affect performance.
⁺ Investment Class is not subject to sales charges.
⁺⁺ The MSCI EAFE Index is an unmanaged index that tracks international stock performance in the 21 developed markets of Europe, Australasia, and the Far East. Index returns assume reinvestment of dividends and, unlike fund returns, do not reflect any fees or expenses. It is not possible to invest directly into an index.

All performance is historical, assumes reinvestment of all dividends and capital gains, and is not indicative of future results. Investment return and principal value will fluctuate, so an investor's shares, when redeemed, may be worth more or less than when purchased. Performance figures do not reflect the deduction of taxes that a shareholder would pay on fund distributions or the redemption of fund shares. Returns and rankings may differ by share class.

Investments in funds involve risk. Some funds have more risk than others. These include funds that allow exposure to or otherwise concentrate investments in certain sectors, geographic regions, security types, market capitalization or foreign securities (e.g., political or economic instability, which can be accentuated in emerging market countries). Please read this fund's prospectus for specific details regarding its investments and risk profile.

Please call (800) 621-1048 for the Fund's most up-to-date performance. On the Web, go to scudder.com.

Portfolio Management Review

Scudder International Equity Fund: A Team Approach to Investing

Deutsche Asset Management, Inc. ("DeAM, Inc." or the "Advisor"), which is part of Deutsche Asset Management, is the investment advisor for the Scudder International Equity Portfolio in which this fund invests all of its assets. DeAM, Inc. provides a full range of investment advisory services to institutional and retail clients. Deutsche Asset Management Investment Services Ltd. ("DeAMIS") is the sub-advisor to the International Equity Portfolio. DeAMIS is responsible for selecting brokers and dealers and for negotiating brokerage commissions and dealer charges.

Deutsche Asset Management is a global asset management organization that offers a wide range of investing expertise and resources. This well-resourced global investment platform brings together a wide variety of experience and investment insight across industries, regions, asset classes and investing styles.

DeAM, Inc. is an indirect, wholly owned subsidiary of Deutsche Bank AG. Deutsche Bank AG is a major global banking institution that is engaged in a wide range of financial services, including investment management, mutual funds, retail, private and commercial banking, investment banking and insurance.

Portfolio Management Team

Alexander Tedder

Managing Director of Deutsche Asset Management and Lead Manager of the fund.

• Joined Deutsche Asset Management in 1994.

• Head of EAFE Equity Portfolio Selection team.

• Previously, a European analyst (1990-1994) and representative (1992-1994) for Schroders.

• Over 14 years of investment industry experience.

• MA in Economics and Business Administration, Freiburg University.

Clare Gray

CFA, Director of Deutsche Asset Management and and Co-Manager of the fund.

• Joined Deutsche Asset Management in 1993.

• Over ten years of investment industry experience.

• BS, Cornell University.

Marc Slendebroek

Director of Deutsche Asset Management and Co-Manager of the fund.

• Joined Deutsche Asset Management in 1994.

• Portfolio manager of the EAFE Equities: London.

• Previously, an equity analyst at Kleinwort Benson Securities and at Enskilda Securities in London.

• MA, University of Leiden (Netherlands).

In the following interview, Lead Portfolio Manager Alex Tedder discusses Scudder International Equity Fund's strategy and the market environment during the 12-month period ended October 31, 2003.

Q: How would you describe the international equity market environment during the fiscal year?

A:We saw a recovery in global equity markets over the past year - after three years of negative returns, international markets registered strong gains despite the substantial sell-off that occurred in the first calendar quarter of 2003, when the threat of war in Iraq weighed heavily on stock prices. Equity markets bottomed in mid-March but have been on an upward trend since then, driven by expectations of better corporate profits and a global economic recovery. Stocks rose sharply from mid-March to mid-April, and then steadily improved through the end of October, essentially without a break. Amid the volatility of the first half of the reporting period, it paid to be defensively positioned. During the second half of the period - when investors' appetite for risk returned - more-aggressive investors were rewarded.

Currencies also played a significant role in international equity returns this year. Against the US dollar, the euro rallied 17%, the British pound rose 8% and the Japanese yen ran up 10%. For the period under review, the vast majority of international markets in the fund's benchmark - the MSCI EAFE Index - outperformed the United States.¹ While many of these markets performed strongly, in many instances returns for the dollar-based investor were enhanced by currency appreciation.

¹ The Morgan Stanley Capital International (MSCI) EAFE Index is an unmanaged, capitalization- weighted index that tracks international stock performance in the 21 developed stock markets in Europe, Australasia and the Far East. Index returns assume reinvestment of all distributions and do not reflect fees or expenses. It is not possible to invest directly in an index.

Q: What types of stocks performed well in this environment?

A:Broadly speaking, those sectors that performed well were more suited for the improved risk appetite among investors. These include software services, semiconductors, and equipment and transportation. Conversely, the worst-performing sectors included some of the more-defensive industries such as food, beverages and tobacco, household products and energy.

That said, returns of individual companies within the broader industry sectors were often widely divergent. That is because there were other themes that dominated market performance. First, lower-quality stocks performed very well, as investors bid up the shares of companies that were feared to be on the brink of bankruptcy. Second, small and mid-size stocks outperformed their larger peers.

Q: How did the fund perform?

A:For the 12-month period ended October 31, 2003, Class A shares of Scudder International Equity Fund returned 19.95% (unadjusted for sales charges, which if included, would have reduced performance). In comparison, the MSCI EAFE Index produced a total return of 27.03%. (Please see the Performance Summary beginning on page 3 for the standardized performance of all share classes and more complete performance information.)For the 12-month period ended October 31, 2003, Scudder International Equity Fund returned 20.86% (Institutional Class I shares). In comparison, the MSCI EAFE Index produced a total return of 27.03%. (Please the Performance Summary beginning on page 3 for the standardized performance of all share classes and more complete performance information.)

The market themes previously discussed explain why the fund underperformed its benchmark. First, much of the performance in international markets came from what we view as poorer-quality companies - those with a large amount of debt and questionable management. Our view is that this was a short-term anomaly resulting from the fact that the international markets were rebounding from an exceptionally long downturn. We continue to believe that an emphasis on quality will prove to be beneficial over the long term. As a result, we remain focused on high-quality names that in many instances did not do as well as their lower-quality peers.

The second reason for the fund's underperformance is that the portfolio has a large-cap bias, and small- and mid-cap stocks (which are more heavily represented in the benchmark) led the way during the fiscal year.

Q: Can you highlight some examples of contributors and detractors from the fund's performance during the period under review?

A:Select consumer discretionary holdings dampened performance the most. A key detractor was Sony (Japan), which we discussed at length during the semiannual review. As you may recall, the stock fell sharply in April after the announcement of poor first-quarter results. The company also indicated that additional large-scale restructuring is needed, implying that the 2002 restructuring did not work. Based on our view that the company's earnings could decline due to higher research and development costs during 2003, we sold the fund's position.

The financials sector also detracted significantly from performance due to the fund's underweight in the sector and stock selection in names such as Swiss Reinsurance Co. ("Swiss Re"). Swiss Re detracted as revenues remained sluggish within the life insurance business, impacted by falling bond yields and slowing premium growth. Not all financials detracted from performance, though. While some profits were taken and restructuring issues remained, Japanese financials continued to perform well in response to an improved operating environment and expectations of a pickup in Japan's domestic economy.

In the industrials sector, the security firm Group 4 Falk AS (Denmark) was a major detractor from performance. The company's stock fell in the first half of the reporting period as one of its main competitors issued several profit warnings, hurting the industry as a whole. The stock staged a rally in the second half of the fiscal year when the company reported earnings growth that outpaced its rivals. It was not enough to recoup the losses from the first half, however. (As of October 31, 2003, positions in Group 4 Falk AS were sold.)

The telecommunication services was a strong contributor to performance, particularly Vodafone Group PLC (England), which has been successful on several fronts - including increased revenue and improved margin expansion - and has become a strong market leader. At the beginning of the period, Vodafone launched the "Vodafone live" service backed up by a strong and well-received advertising campaign which has borne fruit. We added to the fund's position in the company during the period, as it continued to meet its sales targets and remained a dominant player in the market.

Within the consumer staples sector, one contributor really stood out: Metro AG. Domiciled in Germany, Metro is a holding company for several retail businesses that focus on a wide range of products, including food and automobiles. Metro is a prime example of the type of recovery story we look for. The company carried enormous debt, but was successful in raising a bond issue to pay it down. This transformation in the balance sheet strength of the company drove the stock price higher. We believe it is a robust food-retailing company with a sustainable business model.

Q: Do you have any final thoughts for investors?

A:While a global economic recovery seems to be fully reflected by international equity market performance, corporations appear to be telling a less coherent story. Many have continued to deliver better-than-expected profit numbers, but the key driver has rarely been top-line - or revenue - growth. Companies will not be able to sustain bottom-line earnings growth solely through cost cutting. Our thesis this year has been, and continues to be, that an international economic recovery must be driven by corporate spending and not by the consumer. In recent economic releases, we have seen that the long-awaited but predicted recovery in capital expenditures is gaining momentum. Consequently, we continue to be focused on those companies that either stand to benefit from improved capital expenditures - such as those in the steel and pulp and paper industries - or those that generate strong free cash flow and can therefore afford to spend their way out of the cycle. On the other hand, we remain cautious on consumer staples and consumer discretionary exposure, except in Japan and Asia.

Our approach is to focus on what we believe are some of the world's best companies. We remain committed to our cornerstone cash-flow return on investment (CFROI) valuation methodology.

The views expressed in this report reflect those of the portfolio managers only through the end of the period of the report as stated on the cover. The managers' views are subject to change at any time based on market and other conditions and should not be construed as a recommendation.

Portfolio Summary October 31, 2003

Geographic Diversification (Excludes Cash Equivalents)	10/31/03	10/31/02
Japan	22%	18%
United Kingdom	19%	26%
Germany	12%	6%
Switzerland	11%	12%
France	6%	13%
Netherlands	4%	6%
Finland	3%	3%
Italy	3%	1%
Spain	2%	3%
Other	18%	12%
	100%	100%

Sector Diversification (Excludes Cash Equivalents)	10/31/03	10/31/02
Financials	27%	17%
Consumer Discretionary	12%	15%
Industrials	11%	10%
Information Technology	11%	6%
Telecommunication Services	9%	8%
Health Care	8%	14%
Energy	7%	13%
Materials	7%	4%
Consumer Staples	5%	9%
Other	3%	4%
	100%	100%

Geographic and sector diversification are based on market value of total investments in the Portfolio and are subject to change.

Ten Largest Equity Holdings at October 31, 2003 (23.1% of Portfolio)
1. Vodafone Group PLC Provider of mobile telecommunication services	United Kingdom	2.8%
2. Total SA Producer of oil and natural gas	France	2.7%
3. HSBC Holdings PLC Provider of international banking and financial services	United Kingdom	2.4%
4. Samsung Electronics Co., Ltd. Manufacturer of electronic parts	Korea	2.4%
5. Nestle SA (Registered) Producer and seller of food products	Switzerland	2.3%
6. Credit Suisse Group Provider of universal banking services	Switzerland	2.3%
7. AstraZeneca PLC Manufacturer of pharmaceutical and agrochemical products	United Kingdom	2.1%
8. Toyota Motor Corp. Manufacturer of diversified automotive products	Japan	2.1%
9. Canon, Inc. Producer of visual image and information equipment	Japan	2.0%
10. Allianz AG (Registered) Provider of multi-line insurance services	Germany	2.0%

Portfolio holdings are subject to change.

For more complete details about the fund's investment portfolio, see page 36. A quarterly Fact Sheet and Portfolio Holdings are available upon request.

Financial Statements

Statement of Assets and Liabilities as of October 31, 2003
Assets
Investment in the International Equity Portfolio, at value	$ 353,010,459
Receivable for Fund shares sold	668,942
Total assets	353,679,401
Liabilities
Payable for Fund shares redeemed	268,151
Other accrued expenses and payables	327,918
Total liabilities	596,069
Net assets, at value	$ 353,083,332
Net Assets
Net assets consist of: Undistributed net investment income	6,127,119
Net unrealized appreciation (depreciation) on investments	46,358,593
Accumulated net realized gain (loss)	(467,590,286)
Paid-in capital	768,187,906
Net assets, at value	$ 353,083,332

The accompanying notes are an integral part of the financial statements.

Statement of Assets and Liabilities as of October 31, 2003 (continued)
Net Asset Value
Class A Net Asset Value and redemption price per share ($4,719,406 / 492,036 shares of capital stock outstanding, $.001 par value, unlimited number of shares authorized)	$ 9.59
Maximum offering price per share (100 / 94.25 of $9.59)	$ 10.18
Class B Net Asset Value, offering and redemption price (subject to contingent deferred sales charge) per share ($537,583 / 56,670 shares of capital stock outstanding, $.001 par value, unlimited number of shares authorized)	$ 9.49
Class C Net Asset Value and redemption price (subject to contingent deferred sales charge) per share ($247,737 / 26,592 shares of capital stock outstanding, $.001 par value, unlimited number of shares authorized)	$ 9.32
Maximum offering price per share (100 / 99.00 of $9.32)	$ 9.41
Investment Class Net Asset Value, offering and redemption price per share ($347,578,606 / 18,569,922 shares of capital stock outstanding, $.001 par value, unlimited number of shares authorized)	$ 18.72

The accompanying notes are an integral part of the financial statements.

Statement of Operations for the year ended October 31, 2003
Investment Income
Total investment income allocated from the International Equity Portfolio: Dividends (net of foreign taxes withheld of $1,211,057)	$ 8,494,527
Interest	13,189
Securities lending income	125,841
Expenses(a)	(2,592,840)
Net investment income (loss) allocated from the International Equity Portfolio	6,040,717
Expenses: Administrator service fee	3,091,213
Distribution and shareholder servicing fee	18,922
Registration fees	59,315
Reports to shareholders	12,110
Legal	14,713
Auditing	20,158
Trustees' fees and expenses	6,878
Other	5,421
Total expenses, before expense reductions	3,228,730
Expense reductions	(344,796)
Total expenses, after expense reductions	2,883,934
Net investment income (loss)	3,156,783
Realized and Unrealized Gain (Loss) on Investment Transactions
Net realized gain (loss) from: Investments (including foreign taxes of $56,748)	(10,008,390)
Futures	(408,738)
Foreign currency related transactions	3,906,006
Net increase from a receivable by an affiliate and net gains (losses) realized on the disposal of investments in violation of restrictions	899,330
	(5,611,792)
Net unrealized appreciation (depreciation) during the period on investment and foreign currency related transactions	64,311,936
Net gain (loss) on investment transactions	58,700,144
Net increase (decrease) in net assets resulting from operations	$ 61,856,927

^a For the year ended October 31, 2003, the Advisor/Administrator waived fees in the amount of $511,100 which was allocated to the Fund on a pro-rated basis.

The accompanying notes are an integral part of the financial statements.

Statement of Changes in Net Assets
Increase (Decrease) in Net Assets	Years Ended October 31,
	2003	2002
Operations: Net investment income (loss)	$ 3,156,783	$ 2,138,268
Net realized gain (loss) on investment transactions	(5,611,792)	(77,376,487)
Net unrealized appreciation (depreciation) on investment transactions during the period	64,311,936	17,853,511
Net increase (decrease) in net assets resulting from operations	61,856,927	(57,384,708)
Distributions to shareholders from: Net investment income: Class A	(3,122)	(12,504)
Class B	-	(578)
Class C	-	(383)
Investment Class	(251,674)	(565,008)
Fund share transactions: Proceeds from shares sold	258,685,558	1,804,176,102
Reinvestment of distributions	200,037	478,124
Cost of shares redeemed	(390,702,208)	(2,148,917,915)
Net increase (decrease) in net assets from Fund share transactions	(131,816,613)	(344,263,689)
Increase (decrease) in net assets	(70,214,482)	(402,226,870)
Net assets at beginning of period	423,297,814	825,524,684
Net assets at end of period (including undistributed and accumulated distributions in excess of net investment income of $6,127,119 and $1,271,159, respectively)	$ 353,083,332	$ 423,297,814

The accompanying notes are an integral part of the financial statements.

Financial Highlights

Class A
Years Ended October 31,	2003	2002	2001a
Selected Per Share Data
Net asset value, beginning of period	$ 8.00	$ 9.28	$ 11.05
Income (loss) from investment operations: Net investment income (loss)	.07b	.03b	(.01)
Net realized and unrealized gain (loss) on investment transactions	1.53	(1.30)	(1.76)
Total from investment operations	1.60	(1.27)	(1.77)
Less distributions from: Net investment income	(.01)	(.01)	-
Total distributions	(.01)	(.01)	-
Net asset value, end of period	$ 9.59	$ 8.00	$ 9.28
Total Return (%)c,d	19.95e	(13.68)	(16.02)**
Ratios to Average Net Assets and Supplemental Data
Net assets, end of period ($ millions)	5	5	9
Ratio of expenses before expense reductions, including expenses allocated from the International Equity Portfolio (%)	1.97	1.94	1.73*
Ratio of expenses after expense reductions, including expenses allocated from the International Equity Portfolio (%)	1.50	1.50	1.50*
Ratio of net investment income (loss) (%)	.87	.34	(.44)*
a For the period June 29, 2001 (commencement of operations of Class A shares) to October 31, 2001. b Based on average shares outstanding during the period. c Total return would have been lower had certain expenses not been reduced. d Total return does not reflect the effect of any sales charges. e In 2003, the Advisor fully reimbursed the Portfolio for currency transactions which did not meet the Portfolio's investment guidelines. Excluding this reimbursement, the total return would have been 19.70% and the impact to the Class was $0.02 per share. * Annualized ** Not annualized

Class B
Years Ended October 31,	2003	2002	2001a
Selected Per Share Data
Net asset value, beginning of period	$ 7.97	$ 9.33	$ 11.13
Income (loss) from investment operations: Net investment income (loss)	.01b	(.04)b	(.04)
Net realized and unrealized gain (loss) on investment transactions	1.51	(1.31)	(1.76)
Total from investment operations	1.52	(1.35)	(1.80)
Less distributions from: Net investment income	-	(.01)	-
Total distributions	-	(.01)	-
Net asset value, end of period	$ 9.49	$ 7.97	$ 9.33
Total Return (%)c,d	19.07e	(14.35)	(16.17)**
Ratios to Average Net Assets and Supplemental Data
Net assets, end of period ($ millions)	.5	.4	.4
Ratio of expenses before expense reductions, including expenses allocated from the International Equity Portfolio (%)	2.72	2.69	2.48*
Ratio of expenses after expense reductions, including expenses allocated from the International Equity Portfolio (%)	2.25	2.25	2.25*
Ratio of net investment income (loss) (%)	.11	(.41)	(1.19)*
a For the period June 29, 2001 (commencement of operations of Class B shares) to October 31, 2001. b Based on average shares outstanding during the period. c Total return would have been lower had certain expenses not been reduced. d Total return does not reflect the effect of any sales charges. e In 2003, the Advisor fully reimbursed the Portfolio for currency transactions which did not meet the Portfolio's investment guidelines. Excluding this reimbursement, the total return would have been 18.70% and the impact to the Class was $0.02 per share. * Annualized ** Not annualized

Class C
Years Ended October 31,	2003	2002	2001a
Selected Per Share Data
Net asset value, beginning of period	$ 7.83	$ 9.15	$ 10.92
Income (loss) from investment operations: Net investment income (loss)	.01b	(.04)b	(.09)
Net realized and unrealized gain (loss) on investment transactions	1.48	(1.27)	(1.68)
Total from investment operations	1.49	(1.31)	(1.77)
Less distributions from: Net investment income	-	(.01)	-
Total distributions	-	(.01)	-
Net asset value, end of period	$ 9.32	$ 7.83	$ 9.15
Total Return (%)c,d	19.03e	(14.20)	(16.21)**
Ratios to Average Net Assets and Supplemental Data
Net assets, end of period ($ millions)	.2	.1	.3
Ratio of expenses before expense reductions, including expenses allocated from the International Equity Portfolio (%)	2.72	2.69	2.48*
Ratio of expenses after expense reductions, including expenses allocated from the International Equity Portfolio (%)	2.25	2.25	2.25*
Ratio of net investment income (loss) (%)	.11	(.41)	(1.19)*
a For the period June 29, 2001 (commencement of operations of Class C shares) to October 31, 2001. b Based on average shares outstanding during the period. c Total return would have been lower had certain expenses not been reduced. d Total return does not reflect the effect of any sales charges. e In 2003, the Advisor fully reimbursed the Portfolio for currency transactions which did not meet the Portfolio's investment guidelines. Excluding this reimbursement, the total return would have been 18.65% and the impact to the Class was $0.02 per share. * Annualized ** Not annualized

Investment Class
Years Ended October 31,	2003	2002	2001	2000	1999a	1999b
Selected Per Share Data
Net asset value, beginning of period	$ 15.63	$ 18.14	$ 25.55	$ 25.33	$ 24.22	$ 20.68
Income (loss) from investment operations:
Net investment income (loss)	.14c	.06c	.08	(.02)	(.02)	.04
Net realized and unrealized gain (loss) on investment transactions	2.96	(2.56)	(7.28)	.24	1.13	3.56
Total from investment operations	3.10	(2.50)	(7.20)	.22	1.11	3.60
Less distributions from: Net investment income	(.01)	(.01)	-	-	-	(.06)
Net realized gains	-	-	(.21)	-	-	-
Total distributions	(.01)	(.01)	(.21)	-	-	(.06)
Net asset value, end of period	$ 18.72	$ 15.63	$ 18.14	$ 25.55	$ 25.33	$ 24.22
Total Return (%)d	19.85e	(13.78)	(28.38)	.83	4.63**	17.35
Ratios to Average Net Assets and Supplemental Data
Net assets, end of period ($ millions)	347	418	815	2,128	1,914	1,851
Ratio of expenses before expense reductions, including expenses allocated from the International Equity Portfolio (%)	1.72	1.69	1.68	1.67	1.70*	1.66
Ratio of expenses after expense reductions, including expenses allocated from the International Equity Portfolio (%)	1.50	1.50	1.50	1.50	1.50*	1.50
Ratio of net investment income (loss) (%)	.86	.34	.24	(.07)	(.93)*	.19
a On September 8, 1999, the Board of Trustees approved the change of the fiscal year end from September 30 to October 31. b For the year ended September 30. c Based on average shares outstanding during the period. d Total return would have been lower had certain expenses not been reduced. e In 2003, the Advisor fully reimbursed the Portfolio for currency transactions which did not meet the Portfolio's investment guidelines. Excluding this reimbursement, the total return would have been 19.53% and the impact to the Class was $0.05 per share. * Annualized ** Not annualized

Notes to Financial Statements

A. Significant Accounting Policies

International Equity Fund ("Scudder International Equity Fund" or the "Fund") is a diversified series of the Scudder Advisor Funds (the "Trust"), formerly BT Investment Funds, which is registered under the Investment Company Act of 1940, as amended (the "1940 Act"), as an open-end management investment company organized as a Massachusetts business trust.

The Fund seeks to achieve its investment objective by investing substantially all of its assets in the Scudder International Equity Portfolio (the "Portfolio"), a diversified, open-end management investment company advised by Deutsche Asset Management, Inc. ("DeAM, Inc."). On October 31, 2003, the Fund owned approximately 75% of the International Equity Portfolio. The financial statements of the Portfolio, including the Investment Portfolio, are contained elsewhere in this report and should be read in conjunction with the Fund's financial statements.

The Fund offers multiple classes of shares which provide investors with different purchase options. Class A shares are offered to investors subject to an initial sales charge. Class B shares are offered without an initial sales charge but are subject to higher ongoing expenses than Class A shares and a contingent deferred sales charge payable upon certain redemptions. Class B shares automatically convert to Class A shares six years after issuance. Class C shares are offered to investors subject to an initial sales charge and are subject to higher ongoing expenses than Class A shares and a contingent deferred sales charge payable upon certain redemptions within one year of purchase. Prior to February 3, 2003, Class C shares were offered without an initial sales charge. Class C shares do not convert into another class. Certain detailed information for the Class A, B, C is provided separately and is available upon request.Certain detailed information for the Class A, B, C and I shares and Class AARP and S shares is provided separately and is available upon request.Investment Class shares are not subject to initial or contingent deferred sales charges.

Investment income, realized and unrealized gains and losses, and certain fund-level expenses and expense reductions, if any, are borne pro rata on the basis of relative net assets by the holders of all classes of shares, except that each class bears certain expenses unique to that class such as distribution fees, service fees and certain other class-specific expenses. Differences in class-level expenses may result in payment of different per share dividends by class. All shares of the Fund have equal rights with respect to voting subject to class-specific arrangements.

The Fund's financial statements are prepared in accordance with accounting principles generally accepted in the United States of America which require the use of management estimates. Actual results could differ from those estimates. The policies described below are followed consistently by the Fund in the preparation of its financial statements.

Security Valuation. The Fund determines the valuation of its investment in the Portfolio by multiplying its proportionate ownership of the Portfolio by the total value of the Portfolio's net assets.

The Portfolio's policies for determining the value of its net assets are discussed in the Portfolio's Financial Statements, which accompany this report.

Federal Income Taxes. The Fund's policy is to comply with the requirements of the Internal Revenue Code, as amended, which are applicable to regulated investment companies, and to distribute all of its taxable income to its shareholders. Accordingly, the Fund paid no federal income taxes and no federal income tax provision was required.

At October 31, 2003, the Fund had a net tax basis capital loss carryforward of approximately $467,590,000 which may be applied against any realized net taxable capital gains of each succeeding year until fully utilized or until October 31, 2007 ($1,135,000), October 31, 2008 ($2,535,000), October 31, 2009 ($328,322,000), October 31, 2010 ($108,362,000) and October 31, 2011 ($27,236,000), the respective expiration dates, whichever occurs first.

Distribution of Income and Gains. Distributions of net investment income, if any, are made annually. Net realized gains from investment transactions, in excess of available capital loss carryforwards, would be taxable to the Fund if not distributed, and, therefore, will be distributed to shareholders at least annually.

The timing and characterization of certain income and capital gains distributions are determined annually in accordance with federal tax regulations which may differ from accounting principles generally accepted in the United States of America. As a result, net investment income (loss) and net realized gain (loss) on investment transactions for a reporting period may differ significantly from distributions during such period. Accordingly, the Fund may periodically make reclassifications among certain of its capital accounts without impacting the net asset value of the Fund.

The net unrealized appreciation/depreciation of the Fund's investment in the Portfolio consists of an allocated portion of the Portfolio's appreciation/depreciation. Please refer to the Portfolio's financial statements for a breakdown of the appreciation/depreciation from investments.

At October 31, 2003, the Fund's components of distributable earnings (accumulated losses) on a tax-basis were as follows:

Undistributed ordinary income*	$ 6,330,959
Undistributed net long-term capital gains	$ -
Capital loss carryforwards	$ (467,590,000)

In addition, during the year ended October 31, 2003 and October 31, 2002, the tax character of distributions paid to shareholders by the Fund is summarized as follows:

	2003	2002
Distributions from ordinary income*	$ 254,796	$ 578,473

* For tax purposes short-term capital gains distributions are considered ordinary income distributions.

Other. The Fund receives a daily allocation of the Portfolio's income, expenses and net realized and unrealized gains and losses in proportion to its investment in the Portfolio. Expenses of the Trust arising in connection with a specific Fund are allocated to that Fund. Other Trust expenses which cannot be directly attributed to a Fund are apportioned among the Funds in the Trust.

B. Related Parties

Scudder Investments is part of Deutsche Asset Management, which is the marketing name in the US for the asset management activities of Deutsche Bank AG. Deutsche Asset Management, Inc. (the "Advisor") is the Advisor for the Portfolio and Investment Company Capital Corporation ("ICCC" or the "Administrator") is the Administrator for the Fund, both wholly owned subsidiaries of Deutsche Bank AG.

For the year ended October 31, 2003, the Advisor and Administrator contractually agreed to waive their fees and reimburse expenses of the Fund to the extent necessary to maintain the annualized expenses of each class as follows: Class A shares 1.50%, Class B Shares 2.25%, Class C shares 2.25% and Investment Class 1.50% including expenses allocated from the Portfolio.

Administrator Service Fee. For its services as Administrator, ICCC receives a fee (the "Administrator Service Fee") of 0.85% of the Fund's average daily net assets, computed and accrued daily and payable monthly. For the year ended October 31, 2003, the Administrator Service Fee was as follows:

Administrator Service Fee	Total Aggregated	Administrator Service Fee waived by ICCC	Unpaid at October 31, 2003
Class A	$ 44,498	$ 17,720	$ 2,068
Class B	3,655	1,474	307
Class C	1,305	524	288
Investment Class	3,041,755	325,078	207,319
	$ 3,091,213	$ 344,796	$ 209,982

Distribution Agreement. Under the Distribution Agreement, in accordance with Rule 12b-1 under the 1940 Act, Scudder Distributors, Inc. ("SDI"), an affiliate of the Advisor, receives a fee ("Distribution Fee") of 0.25% of average daily net assets of Class A shares and 0.75% of average daily net assets of Class B and C shares. Pursuant to the agreement, SDI enters into related selling group agreements with various firms at various rates for sales of Class B and C shares. For the year ended October 31, 2003, the Distribution Fee was as follows:

Distribution Fee	Total Aggregated	Unpaid at October 31, 2003
Class A	$ 13,088	$ -
Class B	3,224	276
Class C	1,152	125
	$ 17,464	$ 401

In addition, SDI provides information and administrative services ("Shareholder Servicing Fee") to Class B and C shareholders at an annual rate of up to 0.25% of average daily net assets for each class. SDI in turn has various agreements with financial services firms that provide these services and pays these fees based upon the assets of shareholder accounts the firms service. For the year ended October 31, 2003, the Shareholder Servicing Fee was as follows:

Shareholder Servicing Fee	Total Aggregated	Unpaid at October 31, 2003	Effective Rate
Class B	$ 1,074	$ -	.25%
Class C	384	-	.25%
	$ 1,458	$ -

Underwriting Agreement and Contingent Deferred Sales Charge. SDI is the principal underwriter for Class A, B and C shares. Underwriting commissions paid in connection with the distribution of Class A shares for the year ended October 31, 2003 aggregated $518. There were no underwriting commissions paid in connection with the distribution of Class C shares for the year ended October 31, 2003.

In addition, SDI receives any contingent deferred sales charge ("CDSC") from Class B share redemptions occurring within six years of purchase and Class C share redemptions occurring within one year of purchase. There is no such charge upon redemption of any share appreciation or reinvested dividends. The CDSC is based on declining rates ranging from 4% to 1% for Class B and 1% for Class C, of the value of the shares redeemed. For the year ended October 31, 2003, the CDSC for Class B and C shares aggregated $3,546 and none, respectively. A deferred sales charge of up to 1% is assessed on certain redemptions of Class A. For the year ended October 31, 2003, SDI received $95.

Trustees' Fees and Expenses. As compensation for his or her services, each Independent Trustee receives an aggregate annual fee, plus a fee for each meeting attended (plus reimbursement for reasonable out-of-pocket expenses incurred in connection with his or her attendance at board and committee meetings) from each Fund in the Fund Complex for which he or she serves. In addition, the Chairmen of the Fund Complex's Audit Committee and Executive Committee receive an annual fee for their services. Payment of such fees and expenses is allocated among all such Funds described above in direct proportion to their relative net assets.

C. Share Transactions

The following table summarizes share and dollar activity in the Fund:

	Year Ended October 31, 2003		Year Ended October 31, 2002
	Shares	Dollars	Shares	Dollars
Shares sold
Class A	1,244,038	$ 10,043,658	14,947,222	$ 134,579,740
Class B	25,004	213,177	21,110	189,453
Class C	17,472	140,848	3,459	28,048
Investment Class	15,130,738	248,287,875	95,544,886	1,669,378,861
		$ 258,685,558		$ 1,804,176,102
Shares issued to shareholders in reinvestment of distributions
Class A	289	$ 2,311	1,212	$ 11,608
Class B	-	-	59	571
Class C	-	-	41	383
Investment Class	12,650	197,726	24,843	465,562
		$ 200,037		$ 478,124
Shares redeemed
Class A	(1,408,109)	$ (11,752,456)	(15,315,568)	$ (138,828,144)
Class B	(18,725)	(157,803)	(13,643)	(123,939)
Class C	(6,917)	(53,963)	(23,859)	(218,186)
Investment Class	(23,282,779)	(378,737,986)	(113,799,709)	(2,009,747,646)
		$ (390,702,208)		$ (2,148,917,915)
Net increase (decrease)
Class A	(163,782)	$ (1,706,487)	(367,134)	$ (4,236,796)
Class B	6,279	55,374	7,526	66,085
Class C	10,555	86,885	(20,359)	(189,755)
Investment Class	(8,139,391)	(130,252,385)	(18,229,980)	(339,903,223)
		$ (131,816,613)		$ (344,263,689)

D. Payments Made by Affiliates

For the year ended October 31, 2003, the Advisor has agreed to reimburse the Portfolio $1,197,030 for currency transactions which did not meet the Portfolio's investment guidelines. The Fund's allocated portion of the reimbursement was $899,330, based on the proportion of the Fund's investment in the Portfolio.

Report of Independent Auditors

To the Trustees of the Scudder Advisor Funds and Shareholders of International Equity Fund:

In our opinion, the accompanying statement of assets and liabilities and the related statements of operations and of changes in net assets and the financial highlights present fairly, in all material respects, the financial position of International Equity Fund Institutional (the "Fund") at October 31, 2003, and the results of its operations, the changes in its net assets and the financial highlights for each of the periods indicated therein, in conformity with accounting principles generally accepted in the United States of America. These financial statements and financial highlights (hereafter referred to as "financial statements") are the responsibility of the Fund's management; our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits of these financial statements in accordance with auditing standards generally accepted in the United States of America, which require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

Boston, Massachusetts
December 30, 2003 PricewaterhouseCoopers LLP

Tax Information (Unaudited)

The Fund paid foreign taxes of $1,211,057 and earned $5,700,993 of foreign source income during the year ended October 31, 2003. Pursuant to section 853 of the Internal Revenue Code, the Fund designates $0.07 per share as foreign taxes paid and $0.30 per share as income earned from foreign sources for the year ended October 31, 2003.

For Federal Income tax purposes, the Fund designates $7,000,000 or the maximum amount allowable under tax law, as qualified dividend income.

Please consult a tax advisor if you have questions about federal or state income tax laws, or on how to prepare your tax returns. If you have specific questions about your account, please call 1-800-621-1048.

Trustees and Officers

The following individuals hold the same position with the Fund and the International Equity Portfolio.

Independent Trustees
Name, Date of Birth, Position with the Fund and Length of Time Served1,2	Business Experience and Directorships During the Past 5 Years	Number of Funds in the Fund Complex Overseen
Richard R. Burt 2/3/47 Trustee since 2002	Chairman, Diligence LLC (international information-collection and risk-management firm) (September 2000 to present); Chairman, IEP Advisors, Inc. (July 1998 to present); Chairman of the Board, Weirton Steel Corporation3 (April 1996 to present); Member of the Board, Hollinger International, Inc.3 (publishing) (1995 to present), HCL Technologies Limited (information technology) (April 1999 to present), UBS Mutual Funds (formerly known as Brinson and Mitchell Hutchins families of funds) (registered investment companies) (September 1995 to present); and Member, Textron Inc.3 International Advisory Council (July 1996 to present). Formerly, Partner, McKinsey & Company (consulting) (1991-1994) and US Chief Negotiator in Strategic Arms Reduction Talks (START) with former Soviet Union and US Ambassador to the Federal Republic of Germany (1985-1991); Member of the Board, Homestake Mining3 (mining and exploration) (1998-February 2001), Archer Daniels Midland Company3 (agribusiness operations) (October 1996-June 2001) and Anchor Gaming (gaming software and equipment) (March 1999-December 2001).	68
S. Leland Dill 3/28/30 Trustee since 1986	Trustee, Phoenix Zweig Series Trust (since September 1989), Phoenix Euclid Market Neutral Funds (since May 1998) (registered investment companies); Retired (since 1986). Formerly, Partner, KPMG Peat Marwick (June 1956-June 1986); Director, Vintners International Company Inc. (wine vintner) (June 1989-May 1992), Coutts (USA) International (January 1992-March 2000), Coutts Trust Holdings Ltd., Coutts Group (private bank) (March 1991-March 1999); General Partner, Pemco (investment company) (June 1979-June 1986).	66
Martin J. Gruber 7/15/37 Trustee since 1999	Nomura Professor of Finance, Leonard N. Stern School of Business, New York University (since September 1964); Trustee, CREF (pension fund) (since January 2000); Director, Japan Equity Fund, Inc. (since January 1992), Thai Capital Fund, Inc. (since January 2000) and Singapore Fund, Inc. (since January 2000) (registered investment companies). Formerly, Trustee, TIAA (pension fund) (January 1996-January 2000); Director, S.G. Cowen Mutual Funds (January 1985-January 2001).	66
Joseph R. Hardiman 5/27/37 Trustee since 2002	Private Equity Investor (January 1997 to present); Director, Soundview Technology Group Inc. (investment banking) (July 1998 to present), Corvis Corporation3 (optical networking equipment) (July 2000 to present), Brown Investment Advisory & Trust Company (investment advisor) (February 2001 to present), The Nevis Fund (registered investment company) (July 1999 to present), and ISI Family of Funds (registered investment companies) (March 1998 to present). Formerly, Director, Circon Corp.3 (medical instruments) (November 1998-January 1999); President and Chief Executive Officer, The National Association of Securities Dealers, Inc. and The NASDAQ Stock Market, Inc. (1987-1997); Chief Operating Officer of Alex. Brown & Sons Incorporated (now Deutsche Bank Securities Inc.) (1985-1987); General Partner, Alex. Brown & Sons Incorporated (now Deutsche Bank Securities Inc.) (1976-1985).	66
Richard J. Herring 2/18/46 Trustee since 1999	Jacob Safra Professor of International Banking and Professor, Finance Department, The Wharton School, University of Pennsylvania (since July 1972); Director, Lauder Institute of International Management Studies (since July 2000); Co-Director, Wharton Financial Institutions Center (since July 2000). Formerly, Vice Dean and Director, Wharton Undergraduate Division (July 1995-June 2000).	66
Graham E. Jones 1/31/33 Trustee since 2002	Senior Vice President, BGK Realty, Inc. (commercial real estate) (since 1995); Trustee, 8 open-end mutual funds managed by Weiss, Peck & Greer (since 1985) and Trustee of 18 open-end mutual funds managed by Sun Capital Advisers, Inc. (since 1998).	66
Rebecca W. Rimel 4/10/51 Trustee since 2002	President and Chief Executive Officer, The Pew Charitable Trusts (charitable foundation) (1994 to present); Executive Vice President, The Glenmede Trust Company (investment trust and wealth management) (1983 to present). Formerly, Executive Director, The Pew Charitable Trusts (1988-1994); Director, ISI Family of Funds (registered investment companies) (1997-1999) and Director, The Glenmede Trust Company (investment trust and wealth management) (1994-2002).	66
Philip Saunders, Jr. 10/11/35 Trustee since 1986	Principal, Philip Saunders Associates (economic and financial consulting) (since November 1988). Formerly, Director, Financial Industry Consulting, Wolf & Company (consulting) (1987-1988); President, John Hancock Home Mortgage Corporation (1984-1986); Senior Vice President of Treasury and Financial Services, John Hancock Mutual Life Insurance Company, Inc. (1982-1986).	66
William N. Searcy 9/03/46 Trustee since 2002	Pension & Savings Trust Officer, Sprint Corporation3 (telecommunications) (since November 1989); Trustee of 22 open-end mutual funds managed by Sun Capital Advisers, Inc. (since October 1998).	66
Robert H. Wadsworth 1/29/40 Trustee since 2002	President, Robert H. Wadsworth Associates, Inc. (consulting firm) (May 1982 to present). Formerly, President and Trustee, Trust for Investment Managers (registered investment company) (April 1999-June 2002); President, Investment Company Administration, L.L.C. (January 1992*-July 2001); President, Treasurer and Director, First Fund Distributors, Inc. (June 1990-January 2002); Vice President, Professionally Managed Portfolios (May 1991-January 2002) and Advisors Series Trust (October 1996-January 2002) (registered investment companies); President, Guinness Flight Investment Funds, Inc. (registered investment company) (June 1994-November1998). * Inception date of the corporation which was the predecessor to the L.L.C.	69

Interested Trustee
Name, Date of Birth, Position with the Fund and Length of Time Served1,2	Business Experience and Directorships During the Past 5 Years	Number of Funds in the Fund Complex Overseen
Richard T. Hale4 7/17/45 Chairman since 2002 and Trustee since 1999	Managing Director, Deutsche Investment Management Americas Inc. (2003-present); Managing Director, Deutsche Bank Securities Inc. (formerly Deutsche Banc Alex. Brown Inc.) and Deutsche Asset Management (1999 to present); Director and President, Investment Company Capital Corp. (registered investment advisor) (1996 to present); Director, Deutsche Global Funds, Ltd. (2000 to present), CABEI Fund (2000 to present), North American Income Fund (2000 to present) (registered investment companies); Director, Scudder Global Opportunities Fund (since 2003); Director/Officer Deutsche/Scudder Mutual Funds (various dates); President, Montgomery Street Income Securities, Inc. (2002 to present) (registered investment companies); Vice President, Deutsche Asset Management, Inc. (2000 to present). Formerly, Director, ISI Family of Funds (registered investment companies; 4 funds overseen) (1992-1999).	201

Officers
Name, Date of Birth, Position with the Fund and Length of Time Served1,2	Business Experience and Directorships During the Past 5 Years
Richard T. Hale4 7/17/45 Chief Executive Officer since 2003	See information presented under Interested Trustee.
Brenda Lyons5 2/21/63 President, 2003-present	Managing Director, Deutsche Asset Management
Daniel O. Hirsch 3/27/54 Vice President since 2000 and Secretary since 1999	Managing Director, Deutsche Asset Management (2002-present) and Director, Deutsche Global Funds Ltd. (2002-present). Formerly, Director, Deutsche Asset Management (1999-2002); Principal, BT Alex. Brown Incorporated (now Deutsche Bank Securities Inc.) (1998-1999); Assistant General Counsel, United States Securities and Exchange Commission (1993-1998).
Kenneth Murphy5 10/13/63 Vice President and Anti-Money Laundering Compliance Officer since 2002	Vice President, Deutsche Asset Management (September 2000-present); Vice President, Scudder Distributors, Inc. (December 2002-present). Formerly, Director, John Hancock Signature Services (1992-2000); Senior Manager, Prudential Mutual Fund Services (1987-1992).
Charles A. Rizzo5 8/5/57 Treasurer and Chief Financial Officer since 2002	Director, Deutsche Asset Management (April 2000 to present); Formerly, Vice President and Department Head, BT Alex. Brown Incorporated (now Deutsche Bank Securities Inc.) (1998-1999); Senior Manager, Coopers & Lybrand L.L.P. (now PricewaterhouseCoopers LLP) (1993-1998).
Salvatore Schiavone5 11/03/65 Assistant Treasurer since 2003	Director, Deutsche Asset Management.
Lucinda H. Stebbins5 11/19/45 Assistant Treasurer since 2003	Director, Deutsche Asset Management.
Kathleen Sullivan D'Eramo5 1/25/57 Assistant Treasurer since 2003	Director, Deutsche Asset Management.
John Millette5 8/23/62 Assistant Secretary since 2003	Director, Deutsche Asset Management.
Caroline Pearson5 4/01/62 Assistant Secretary since 2002	Managing Director, Deutsche Asset Management.
Bruce A. Rosenblum 9/14/60 Assistant Secretary since 2002	Director, Deutsche Asset Management.

¹ Unless otherwise indicated, the mailing address of each Trustee and Officer with respect to fund operations is One South Street, Baltimore, MD 21202.
² Length of time served represents the date that each Trustee or Officer first began serving in that position with Scudder Advisor Funds of which this fund is a series.
³ A publicly held company with securities registered pursuant to Section 12 of the Securities Exchange Act of 1934.
⁴ Mr. Hale is a Trustee who is an "interested person" within the meaning of Section 2(a)(19) of the 1940 Act. Mr. Hale is Vice President of Deutsche Asset Management, Inc. and a Managing Director of Deutsche Asset Management, the US asset management unit of Deutsche Bank AG and its affiliates.
⁵ Address: Two International Place, Boston, Massachusetts.

The fund's Statement of Additional Information includes additional information about the fund's Trustees. To receive your free copy of the Statement of Additional Information, call toll-free: 1-800-621-1048.

(The following financial statements of the International Equity Portfolio should be read in conjunction with the Fund's financial statements.)

Investment Portfolio as of October 31, 2003

	Shares	Value ($)
Common Stocks 99.1%
Australia 2.0%
Australia & New Zealand Banking Group Ltd.	277,480	3,504,570
Australia & New Zealand Banking Group Ltd. (Rights)*	37,033	113,253
Foster's Group Ltd.	758,100	2,458,248
Westpac Banking Corp., Ltd.	293,179	3,359,606
(Cost $8,075,049)		9,435,677
Brazil 1.3%
Companhia Vale do Rio Doce (ADR) (Cost $3,983,531)	134,700	6,162,525
China 0.0%
PICC Property & Casualty Co., Ltd. "H"* (Cost $90,843)	388,000	90,843
Denmark 1.7%
A P Moller - Maersk A/S "B" (Cost $7,196,765)	1,000	7,850,435
Finland 1.6%
Nokia Oyj	217,528	3,694,523
Stora Enso Oyj "R"	265,780	3,614,940
(Cost $5,775,290)		7,309,463
France 6.4%
BNP Paribas SA	59,181	3,109,666
Compagnie de Saint-Gobain*	87,751	3,701,962
Credit Agricole SA*	170,800	3,627,600
Credit Agricole SA (Rights)*	170,800	39,711
Dassault Systemes SA	88,000	3,733,950
Schneider Electric SA	53,476	3,130,051
Total SA	79,592	12,370,687
(Cost $22,537,708)		29,713,627
Germany 11.4%
Allianz AG (Registered)*	84,620	9,071,751
Altana AG	44,400	2,798,049
BASF AG	47,800	2,192,694
Bayerische Motoren Werke AG	27,513	1,101,844
Deutsche Telekom AG (Registered)*	419,279	6,604,431
E.ON AG	150,309	7,597,444
Metro AG	126,400	5,169,350
Muenchener Rueckversicherungs-Gesellschaft AG (Registered)	51,900	6,189,640
Muenchener Rueckversicherungs-Gesellschaft AG (Rights)*	42,900	354,585
SAP AG	17,910	2,605,670
Siemens AG	130,740	8,815,145
(Cost $42,304,133)		52,500,603
Greece 1.2%
Alpha Bank AE	115,400	2,629,389
Public Power Corp.	126,800	2,726,993
(Cost $5,320,793)		5,356,382
Hong Kong 1.3%
BOC Hong Kong (Holdings) Ltd.	2,005,522	3,473,514
Hutchison Whampoa Ltd.	359,562	2,778,078
(Cost $5,291,124)		6,251,592
Hungary 1.1%
OTP Bank (Cost $4,542,835)	433,200	5,307,116
India 0.0%
NIIT Ltd. (Cost $2,968)	50	193
Ireland 0.7%
Bank of Ireland (Cost $3,114,994)	280,160	3,481,584
Italy 1.9%
Eni SpA	423,474	6,724,662
UniCredito Italiano SpA	423,916	2,089,482
(Cost $5,851,927)		8,814,144
Japan 21.7%
Bridgestone Corp.	209,000	2,737,618
Canon, Inc.	193,000	9,339,701
Dai Nippon Printing Co., Ltd.	327,283	5,055,047
Daiwa House Industry Co., Ltd.	326,000	3,516,951
FANUC Ltd.	61,500	3,697,776
Honda Motor Co., Ltd.	15	592
Ito-Yokado Co., Ltd.	67,000	2,462,182
KDDI Corp.	673	3,654,714
Kirin Brewery Co., Ltd.	450,000	3,598,035
Konica Minolta Holdings, Inc.*	93,900	1,234,234
Mitsubishi Corp.	656,000	6,808,532
Mitsui Fudosan Co., Ltd.	428,000	3,982,753
Mizuho Financial Group, Inc.*	1,317	3,222,568
Nippon Steel Corp.	2,355,664	4,842,680
Nissan Motor Co., Ltd.	754,353	8,453,749
Nomura Holdings, Inc.	449,905	7,726,572
Nomura Research, Inc.	26,300	2,643,517
NTT DoCoMo, Inc.	3,912	8,469,150
Ricoh Co., Ltd.	124,000	2,351,753
Takeda Chemical Industries, Ltd.	60,800	2,151,380
Toyota Motor Corp.	339,300	9,660,336
UFJ Holdings, Inc.*	1,157	4,946,468
(Cost $84,028,697)		100,556,308
Korea 3.2%
LG Electronics, Inc.	46,600	2,413,671
POSCO	12,300	1,434,221
Samsung Electronics Co., Ltd.	28,000	11,119,561
(Cost $8,682,359)		14,967,453
Mexico 1.2%
Grupo Financiero BBVA Bancomer SA de CV "B"*	3,394,590	2,881,244
Telefonos de Mexico SA de CV (ADR)	76,730	2,466,869
(Cost $4,870,141)		5,348,113
Netherlands 4.2%
ASML Holding NV*	165,800	2,877,646
ING Groep NV	241,265	5,009,205
Koninklijke (Royal) Philips Electronics NV	177,770	4,792,391
Koninklijke Ahold NV*	207,800	1,758,611
Reed Elsevier NV	136,230	1,517,159
TPG NV	155,615	3,355,740
(Cost $16,329,121)		19,310,752
New Zealand 0.0%
Telecom Corp. of New Zealand Ltd. (Cost $3)	1	3
Russia 1.7%
LUKOIL (ADR)	64,670	5,257,671
YUKOS (ADR)	56,071	2,590,480
(Cost $7,408,864)		7,848,151
South Africa 0.8%
Harmony Gold Mining Co., Ltd. (ADR) (Cost $3,284,384)	230,400	3,483,648
Spain 2.1%
Antena 3 Television SA*	1	23
Banco Popular Espanol SA	76,908	3,999,110
Telefonica SA*	446,273	5,551,076
(Cost $6,464,261)		9,550,209
Sweden 1.1%
Telefonaktiebolaget LM Ericsson "B"* (Cost $2,968,919)	3,005,222	5,162,255
Switzerland 11.3%
ABB Ltd.*	887,600	5,217,853
Credit Suisse Group	302,430	10,655,882
Nestle SA (Registered)	48,639	10,708,702
Novartis AG (Registered)	177,372	6,760,950
Roche Holding AG	96,560	7,990,325
Swiss Re (Registered)	70,171	4,416,724
Syngenta AG	24,667	1,321,694
UBS AG (Registered)	87,853	5,394,800
(Cost $44,632,933)		52,466,930
Taiwan 2.7%
Chunghwa Telecom Co., Ltd. (ADR)	166,210	2,572,931
Hon Hai Precision Industry Co., Ltd.	691,000	3,091,450
MediaTek, Inc.	249,000	2,565,121
Mega Financial Holding Co., Ltd.	6,816,000	4,212,980
(Cost $11,267,329)		12,442,482
United Kingdom 18.5%
Anglo American PLC	198,500	4,062,343
AstraZeneca PLC	209,504	9,840,726
BAA PLC	336,218	2,658,738
BHP Billiton PLC	486,680	3,821,718
British Sky Broadcasting Group PLC*	286,052	3,106,660
GlaxoSmithKline PLC	166,942	3,575,145
Granada PLC	2,608,892	5,190,840
HSBC Holdings PLC	750,075	11,264,624
Intercontinental Hotels Group PLC	223,600	2,029,043
Kingfisher PLC	55,580	268,283
Lloyds TSB Group PLC	378,200	2,626,509
Reuters Group PLC	303,200	1,321,017
Royal Bank of Scotland Group PLC	282,692	7,574,681
Scottish & Southern Energy PLC	213,528	2,222,993
Shell Transport & Trading Co., PLC	1,228,209	7,669,884
Smith & Nephew PLC	685,700	5,448,546
Vodafone Group PLC	6,216,821	13,055,164
(Cost $69,463,918)		85,736,914
Total Common Stocks (Cost $373,488,889)		459,147,402
Preferred Stock 0.9%
Germany
Henkel KGaA (Cost $3,095,602)	53,435	3,930,218
Total Investment Portfolio - 100.0% (Cost $376,584,491) (a)		463,077,620

* Non-income producing security.
(a) The cost for federal income tax purposes was $389,864,345. At October 31, 2003, net unrealized appreciation for all securities based on tax cost was $73,213,275. This consisted of aggregate gross unrealized appreciation for all securities in which there was an excess of value over tax cost of $77,665,120 and aggregate gross unrealized depreciation for all securities in which there was an excess of tax cost over value of $4,451,845.

The accompanying notes are an integral part of the financial statements.

Financial Statements

Statement of Assets and Liabilities as of October 31, 2003
Assets
Investments in securities, at value (cost $376,584,491)	$ 463,077,620
Cash	8,842,192
Foreign currency, at value (cost $3,219,839)	3,216,431
Receivable for investments sold	38,349
Dividends receivable	810,642
Receivable for securities lending income	572
Foreign taxes recoverable	700,120
Unrealized appreciation on forward foreign currency exchange contracts	2,490,508
Due from Advisor	1,197,030
Total assets	480,373,464
Liabilities
Payable for securities purchased	7,562,418
Net payable on closed forward foreign currency exchange contracts	312,246
Unrealized depreciation on forward foreign currency exchange contracts	2,378,489
Accrued foreign taxes payable	75,533
Accrued investment advisory fee	74,771
Other accrued expenses and payables	104,872
Total liabilities	10,508,329
Net assets, at value	$ 469,865,135

The accompanying notes are an integral part of the financial statements.

Statement of Operations for the year ended October 31, 2003
Investment Income
Income: Dividends (net of foreign taxes withheld of $1,830,144)	$ 12,946,125
Interest	22,017
Securities lending income	195,015
Total Income	13,163,157
Expenses: Investment advisory fee	3,547,449
Administrator service fees	818,645
Auditing	57,793
Legal fees	13,119
Trustees' fees and expenses	20,117
Other	101,996
Total expenses, before expense reductions	4,559,119
Expense reductions	(681,466)
Total expenses, after expense reductions	3,877,653
Net investment income (loss)	9,285,504
Realized and Unrealized Gain (Loss) on Investment Transactions
Net realized gain (loss) from: Investments (including foreign taxes of $75,533)	(19,674,759)
Futures	(585,343)
Foreign currency related transactions	5,926,209
Net increase from a receivable by an affiliate and net gains (losses) realized on the disposal of investments in violation of restrictions	1,197,030
	(13,136,863)
Net unrealized appreciation (depreciation) during the period on:
Investments	100,826,440
Foreign currency related transactions	(1,629,263)
	99,197,177
Net gain (loss) on investment transactions	86,060,314
Net increase (decrease) in net assets resulting from operations	$ 95,345,818

The accompanying notes are an integral part of the financial statements.

Statement of Changes in Net Assets
Increase (Decrease) in Net Assets	Years Ended October 31,
	2003	2002
Operations: Net investment income (loss)	$ 9,285,504	$ 11,705,753
Net realized gain (loss) on investment transactions	(13,136,863)	(124,108,774)
Net unrealized appreciation (depreciation) on investment transactions during the period	99,197,177	34,555,807
Net increase (decrease) in net assets resulting from operations	95,345,818	(77,847,214)
Capital transactions in shares of beneficial interest: Proceeds from capital invested	327,205,044	2,244,844,525
Value of capital withdrawn	(619,989,987)	(2,831,084,834)
Net increase (decrease) in net assets from capital transactions in shares of beneficial interest	(292,784,943)	(586,240,309)
Increase (decrease) in net assets	(197,439,125)	(664,087,523)
Net assets at beginning of period	667,304,260	1,331,391,783
Net assets at end of period	$ 469,865,135	$ 667,304,260

The accompanying notes are an integral part of the financial statements.

Financial Highlights

Years Ended October 31,	2003	2002	2001	2000	1999a	1999b
Ratios to Average Net Assets and Supplemental Data
Net assets, end of period ($ millions)	470	667	1,331	2,961	3,017	2,898
Ratio of expenses before expense reductions (%)	.84	.80	.80	.80	.83*	.80
Ratio of expenses after expense reductions (%)	.70	.70	.70	.70	.70*	.70
Ratio of net investment income (loss) (%)	1.72	1.14	1.05	.74	(.13)*	1.00
Portfolio turnover rate (%)	123	179	137	140	5	106
Total Investment Return (%)c,d	20.65e	(13.03)	-	-	-	-
a On September 8, 1999, the Board of Trustees approved the change of the fiscal year end from September 30 to October 31. b For the year ended September 30. c Total return would have been lower had certain expenses not been reduced. d Total investment return for the Portfolio was derived from the performance of the Investment Class of Scudder International Equity Fund. e In 2003, the Advisor fully reimbursed the Portfolio for currency transactions which did not meet the Portfolio's investment guidelines. Excluding this reimbursement, the total return would have been 20.33%. * Annualized

Notes to Financial Statements

A. Significant Accounting Policies

Scudder International Equity Portfolio (the "Portfolio") is registered under the Investment Company Act of 1940, as amended (the "1940 Act"), as a diversified open-end management investment company organized as a New York business trust.

The Portfolio's financial statements are prepared in accordance with accounting principles generally accepted in the United States of America which require the use of management estimates. Actual results could differ from those estimates. The policies described below are followed consistently by the Portfolio in the preparation of its financial statements.

Security Valuation. Investments are stated at value determined as of the close of regular trading on the New York Stock Exchange on each day the exchange is open for trading. Equity securities are valued at the most recent sale price reported on the exchange (US or foreign) or over-the-counter market on which the security is traded most extensively. Securities for which no sales are reported are valued at the calculated mean between the most recent bid and asked quotations on the relevant market or, if a mean cannot be determined, at the most recent bid quotation.

Money market instruments purchased with an original or remaining maturity of sixty days or less, maturing at par, are valued at amortized cost. Investments in any open-end investment companies are valued at their net asset value each business day.

Securities and other assets for which market quotations are not readily available or for which the above valuation procedures are deemed not to reflect fair value are valued in a manner that is intended to reflect their fair value as determined in accordance with procedures approved by the Trustees.

Foreign Currency Translations. The books and records of the Portfolio are maintained in US dollars. Investment securities and other assets and liabilities denominated in a foreign currency are translated into US dollars at the prevailing exchange rates at period end. Purchases and sales of investment securities, income and expenses are translated into US dollars at the prevailing exchange rates on the respective dates of the transactions.

Net realized and unrealized gains and losses on foreign currency transactions represent net gains and losses between trade and settlement dates on securities transactions, the disposition of forward foreign currency exchange contracts and foreign currencies, and the difference between the amount of net investment income accrued and the US dollar amount actually received. That portion of both realized and unrealized gains and losses on investments that results from fluctuations in foreign currency exchange rates is not separately disclosed but is included with net realized and unrealized gains and losses on investment securities.

Futures Contracts. A futures contract is an agreement between a buyer or seller and an established futures exchange or its clearinghouse in which the buyer or seller agrees to take or make a delivery of a specific amount of a financial instrument at a specified price on a specific date (settlement date). The Portfolio may enter into futures contracts as a hedge against anticipated interest rate, currency or equity market changes, and for duration management, risk management and return enhancement purposes.

Upon entering into a futures contract, the Portfolio is required to deposit with a financial intermediary an amount ("initial margin") equal to a certain percentage of the face value indicated in the futures contract. Subsequent payments ("variation margin") are made or received by the Portfolio dependent upon the daily fluctuations in the value of the underlying security and are recorded for financial reporting purposes as unrealized gains or losses by the Portfolio. When entering into a closing transaction, the Portfolio will realize a gain or loss equal to the difference between the value of the futures contract to sell and the futures contract to buy. Futures contracts are valued at the most recent settlement price.

Certain risks may arise upon entering into futures contracts, including the risk that an illiquid secondary market will limit the Portfolio's ability to close out a futures contract prior to the settlement date and that a change in the value of a futures contract may not correlate exactly with the changes in the value of the securities or currencies hedged. When utilizing futures contracts to hedge, the Portfolio gives up the opportunity to profit from favorable price movements in the hedged positions during the term of the contract.

Forward Foreign Currency Exchange Contracts. A forward foreign currency exchange contract ("forward currency contract") is a commitment to purchase or sell a foreign currency at the settlement date at a negotiated rate. The Portfolio may enter into forward currency contracts in order to hedge its exposure to changes in foreign currency exchange rates on its foreign currency denominated portfolio holdings and to facilitate transactions in foreign currency denominated securities. The Fund may also engage in forward currency contracts for non-hedging purposes.

Forward currency contracts are valued at the prevailing forward exchange rate of the underlying currencies and unrealized gain (loss) is recorded daily. Sales and purchases of forward currency contracts having the same settlement date and broker are offset and any gain (loss) is realized on the date of offset; otherwise, gain (loss) is realized on settlement date. Realized and unrealized gains and losses which represent the difference between the value of a forward currency contract to buy and a forward currency contract to sell are included in net realized and unrealized gain (loss) from foreign currency related transactions.

Certain risks may arise upon entering into forward currency contracts from the potential inability of counterparties to meet the terms of their contracts. Additionally, when utilizing forward currency contracts to hedge, the Portfolio gives up the opportunity to profit from favorable exchange rate movements during the term of the contract.

Federal Income Taxes. The Portfolio is considered a partnership under the Internal Revenue Code. Therefore, no federal income tax provision is necessary.

Gains realized upon disposition of Indian securities held by the Fund are subject to capital gains tax in India, payable prior to repatriation of sale proceeds. The tax is computed on net realized gains; any realized losses in excess of gains may be carried forward eight years to offset future gains. In addition, the Fund accrues a deferred tax liability for net unrealized gains in excess of available carryforwards on Indian securities.

Other. Investment transactions are accounted for on a trade date plus one basis for daily net asset value calculations. However, for financial reporting purposes, investment transactions are reported on trade date. Interest income is recorded on the accrual basis. Dividend income is recorded on the ex-dividend date net of foreign withholding taxes. Certain dividends from foreign securities may be recorded subsequent to the ex-dividend date as soon as the Portfolio is informed of such dividends. Realized gains and losses from investment transactions are recorded on an identified cost basis.

The Portfolio makes a daily allocation of its income, expenses and realized and unrealized gains and losses from securities, futures and foreign currency transactions to its investors in proportion to their investment in the Portfolio.

B. Purchases and Sales of Securities

During the year ended October 31, 2003, purchases and sales of investment securities (excluding short-term investments) aggregated $654,253,807 and $920,799,145, respectively.

C. Related Parties

Scudder Investments is part of Deutsche Asset Management, which is the marketing name in the US for the asset management activities of Deutsche Bank AG. Deutsche Asset Management, Inc. ("DeAM, Inc." or the "Advisor") is the Advisor for the Portfolio and Investment Company Capital Corporation ("ICCC" or the "Administrator") is the Administrator for the Portfolio, both wholly owned subsidiaries of Deutsche Bank AG.

Investment Advisory Agreement. Under the Investment Advisory Agreement, the Advisor directs the investments of the Portfolio in accordance with its investment objectives, policies and restrictions. The investment advisory fee payable under the Investment Advisory Agreement is equal to an annual rate of 0.65% of the Portfolio's average daily net assets, computed and accrued daily and payable monthly. Deutsche Asset Management Investment Services Ltd. ("DeAMIS"), an affiliate of the Advisor, serves as subadvisor with respect to the investment and reinvestment of assets in the Portfolio and is paid by the Advisor for its services. The Advisor waives a portion of its advisory fee equivalent to the advisory fees charged by any affiliated money market funds on assets invested in those money market funds.

Administrator Service Fee. For its services as Administrator, ICCC receives a fee (the "Administrator Service Fee") of 0.15% of the Portfolio's average daily net assets, computed and accrued daily and payable monthly. For the year ended October 31, 2003, the Administrator Service Fee aggregated $818,645, of which $61,064 is unpaid at October 31, 2003.

For the year ended October 31, 2003, the Advisor and Administrator agreed to waive their fees and reimburse expenses to the Portfolio to the extent necessary to maintain the annualized expenses of the Portfolio at 0.70%. The amount of the waiver and whether the Advisor and/or Administrator waive its fees may vary at any time without notice to the shareholders.

Accordingly, for the year ended October 31, 2003, the Advisor did not impose a portion of its advisory fee pursuant to the Investment Advisory Agreement aggregating $3,547,449 and the amount imposed aggregated $2,865,983, which was equivalent to an annual effective rate of 0.53% of the Portfolio's average net assets.

Deutsche Bank Trust Company Americas (formerly Bankers Trust Company), an affiliate of the Portfolio's Advisor and Administrator, served as the Portfolio's custodian. Effective July 18, 2003, State Street Bank and Trust Company became the Portfolio's custodian.

Trustees' Fees and Expenses. As compensation for his or her services, each Independent Trustee receives an aggregate annual fee, plus a fee for each meeting attended (plus reimbursement for reasonable out-of-pocket expenses incurred in connection with his or her attendance at board and committee meetings) from each Fund in the Fund Complex for which he or she serves. In addition, the Chairmen of the Fund Complex's Audit Committee and Executive Committee receive an annual fee for their services. Payment of such fees and expenses is allocated among all such Funds described above in direct proportion to their relative net assets.

D. Forward Foreign Currency Commitments

The Portfolio had the following open forward foreign currency exchange contracts at October 31, 2003:

	Contracts to Deliver	In Exchange For		Settlement Date	Unrealized Appreciation
USD	1,433,484	AUD	2,056,000	1/29/04	8,487
USD	5,386,440	AUD	7,762,000	1/29/04	57,424
USD	8,148,704	AUD	11,699,000	1/29/04	56,366
USD	4,740,659	AUD	6,784,000	1/29/04	17,286
AUD	1,237,000	USD	871,467	1/29/04	3,899
CHF	125,669,000	USD	95,633,414	1/29/04	1,466,736
EUR	748,000	USD	870,373	1/29/04	4,121
EUR	8,639,000	USD	10,149,961	1/29/04	145,213
EUR	781,000	USD	914,434	1/29/04	9,965
EUR	22,127,000	USD	25,780,168	1/29/04	155,089
EUR	20,995,000	USD	24,499,066	1/29/04	184,946
EUR	9,800,000	USD	11,355,750	1/29/04	6,458
USD	5,098,956	GBP	3,039,000	1/29/04	20,036
USD	8,332,649	GBP	5,007,000	1/29/04	101,306
USD	5,572,390	GBP	3,350,000	1/29/04	70,460
GBP	682,000	USD	1,149,716	1/29/04	932
USD	11,507,753	GBP	6,847,000	1/29/04	25,559
JPY	53,798,000	USD	493,877	1/29/04	3,843
USD	578,158	NZD	979,000	1/29/04	15,387
USD	563,776	NZD	948,000	1/29/04	10,975
USD	765,905	NZD	1,278,000	1/29/04	8,917
USD	28,601,506	NZD	47,348,000	1/29/04	104,511
USD	4,665,430	NZD	7,700,000	1/29/04	2,905
NZD	771,000	USD	468,051	1/29/04	611
SEK	3,546,000	EUR	389,807	1/29/04	6,548
USD	9,176,369	SGD	15,960,000	1/29/04	2,528
					2,490,508

	Contracts to Deliver	In Exchange For		Settlement Date	Unrealized Depreciation
AUD	886,000	USD	615,726	1/29/04	(5,669)
AUD	904,000	USD	629,464	1/29/04	(4,554)
AUD	798,000	USD	558,859	1/29/04	(816)
USD	5,355,851	EUR	4,593,000	1/29/04	(36,740)
USD	48,135,056	EUR	41,014,000	1/29/04	(637,123)
USD	54,366,830	EUR	46,393,622	1/29/04	(638,795)
SEK	3,546,000	EUR	389,807	1/29/04	(7,507)
USD	2,308,988	EUR	1,974,000	1/29/04	(22,916)
USD	38,942,035	GBP	23,111,000	1/29/04	(13,107)
GBP	23,475,000	USD	39,482,603	1/29/04	(59,459)
GBP	571,000	USD	960,936	1/29/04	(875)
USD	4,269,193	GBP	2,526,000	1/29/04	(14,315)
USD	2,596,295	GBP	1,534,000	1/29/04	(12,375)
GBP	860,000	USD	1,444,800	1/29/04	(3,812)
USD	5,607,335	JPY	606,694,000	1/29/04	(81,095)
USD	9,407,721	JPY	1,016,682,950	1/29/04	(146,984)
USD	8,467,369	JPY	915,746,000	1/29/04	(126,045)
USD	2,766,260	JPY	297,893,000	1/29/04	(52,820)
USD	1,680,265	JPY	183,653,000	1/29/04	(7,411)
USD	9,303,095	NOK	65,531,000	1/29/04	(91,043)
NZD	43,842,000	USD	26,444,618	1/29/04	(135,792)
NZD	956,000	USD	578,963	1/29/04	(638)
NZD	568,000	USD	342,845	1/29/04	(1,521)
USD	9,099,321	SEK	70,406,000	1/29/04	(117,051)
SGD	15,960,000	USD	9,158,098	1/29/04	(20,800)
SGD	11,562,000	USD	6,641,011	1/29/04	(8,514)
SGD	19,790,000	USD	11,329,936	1/29/04	(51,666)
USD	26,998,327	SGD	46,807,000	1/29/04	(78,737)
SGD	512,000	USD	294,151	1/29/04	(309)
					(2,378,489)

Currency Abbreviation
SEK	Swedish Krona	EUR	Euro	CHF	Swiss Franc
SGD	Singapore Dollar	JPY	Japanese Yen	NOK	Norwegian Krona
GBP	British Pound	AUD	Australian Dollar	NZD	New Zealand Dollar
USD	United States Dollar

E. Securities Lending

The Portfolio may lend securities to financial institutions. The Portfolio retains beneficial ownership of the securities it has loaned and continues to receive interest and dividends paid by the securities and to participate in any changes in their market value. The Portfolio requires the borrowers of the securities to maintain collateral with the Portfolio in the form of cash and/or government securities equal to 102 percent of the value of domestic securities on loan and 105 percent of the value of international securities on loan. The Portfolio may invest the cash collateral in an affiliated money market fund. The Portfolio receives compensation for lending its securities either in the form of fees or by earning interest on invested cash collateral. The fees earned for lending securities may be shared with an affiliate regardless of whether or not the cash collateral is invested in an affiliated money market fund. Either the Portfolio or the borrower may terminate the loan. The portfolio is subject to all investment risks associated with the value of any cash collateral received, including, but not limited to, interest rate, credit and liquidity risk associated with such investments. There were no securities out on loan at October 31, 2003.

F. Line of Credit

The Portfolio and several other affiliated funds (the "Participants") shared in a $200 million revolving credit facility administered by a syndicate of banks for temporary or emergency purposes, including the meeting of redemption requests that otherwise might require the untimely disposition of securities. The Participants were charged an annual commitment fee which was allocated pro rata based upon net assets among each of the Participants. Interest was calculated at the Federal Funds Rate plus 0.625 percent. During the period the Portfolio had no borrowings on the line of credit.

Effective April 11, 2003, the Portfolio entered into a new revolving credit facility with JP Morgan Chase Bank that provides $1.25 billion of credit coverage. The new revolving credit facility covers the funds and portfolios advised or administered by DeAM, Inc. or its affiliates. Interest is calculated at the Federal Funds Rate plus 0.5 percent. The Portfolio may borrow up to a maximum of 33 percent of its net assets under the agreement.

G. Payments Made by Affiliates

For the year ended October 31, 2003, the Advisor has agreed to reimburse the Portfolio $1,197,030 for currency transactions incurred which did not meet the Portfolio's investment guidelines.

Report of Independent Auditors

To the Trustees and Holders of Beneficial Interest of International Equity Portfolio:

In our opinion, the accompanying statement of assets and liabilities, including the investment portfolio, and the related statements of operations and of changes in net assets and the financial highlights present fairly, in all material respects, the financial position of the International Equity Portfolio (the "Portfolio") at October 31, 2003, and the results of its operations, the changes in its net assets and the financial highlights for each of the periods presented, in conformity with accounting principles generally accepted in the United States of America. These financial statements and financial highlights (hereafter referred to as "financial statements") are the responsibility of the Portfolio's management; our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits of these financial statements in accordance with auditing standards generally accepted in the United States of America, which require that we plan and perform the audits to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits, which included confirmation of securities at October 31, 2003 by correspondence with the custodian and brokers, provide a reasonable basis for our opinion.

Boston, Massachusetts
December 30, 2003 PricewaterhouseCoopers LLP

Investment Products

Scudder Funds

Growth Funds

Scudder 21st Century Growth Fund

Scudder Aggressive Growth Fund

Scudder Blue Chip Fund

Scudder Capital Growth Fund

Scudder Development Fund

Scudder Dynamic Growth Fund

Scudder Flag Investors
Communications Fund

Scudder Gold & Precious Metals Fund

Scudder Global Biotechnology Fund

Scudder Growth Fund

Scudder Health Care Fund

Scudder Large Company Growth Fund

Scudder Micro Cap Fund

Scudder Mid Cap Fund

Scudder Small Cap Fund

Scudder Strategic Growth Fund

Scudder Technology Fund

Scudder Technology Innovation Fund

Scudder Top 50 US Fund

Value Funds

Scudder Contrarian Fund

Scudder-Dreman Financial Services Fund

Scudder-Dreman High Return Equity Fund

Scudder-Dreman Small Cap Value Fund

Scudder Flag Investors Equity
Partners Fund

Scudder Growth and Income Fund

Scudder Large Company Value Fund

Scudder-RREEF Real Estate Securities Fund

Scudder Small Company Stock Fund

Scudder Small Company Value Fund

Scudder Tax Advantaged Dividend Fund

Multicategory/Asset Allocation Funds

Scudder Balanced Fund

Scudder Flag Investors Value Builder Fund

Scudder Focus Value+Growth Fund

Scudder Lifecycle Mid Range Fund

Scudder Lifecycle Long Range Fund

Scudder Lifecycle Short Range Fund

Scudder Pathway Conservative Portfolio

Scudder Pathway Growth Portfolio

Scudder Pathway Moderate Portfolio

Scudder Target 2013 Fund

Scudder Total Return Fund

International/Global Funds

Scudder Emerging Markets Growth Fund

Scudder Emerging Markets Income Fund

Scudder European Equity Fund

Scudder Global Fund

Scudder Global Bond Fund

Scudder Global Discovery Fund

Scudder Greater Europe Growth Fund

Scudder International Fund

Scudder International Equity Fund

Scudder International Select Equity Fund

Scudder Japanese Equity Fund

Scudder Latin America Fund

Scudder New Europe Fund

Scudder Pacific Opportunities Fund

Income Funds

Scudder Cash Reserves Fund

Scudder Fixed Income Fund

Scudder GNMA Fund

Scudder High Income Plus Fund (formerly Deutsche High Yield Bond Fund)

Scudder High Income Fund

Scudder High Income Opportunity Fund

Scudder Income Fund

Scudder PreservationPlus Fund

Scudder PreservationPlus Income Fund

Scudder Short Duration Fund (formerly Scudder Short-Term Fixed Income Fund)

Scudder Short-Term Bond Fund

Scudder Strategic Income Fund

Scudder US Government Securities Fund

Scudder Funds (continued)

Tax-Free Income Funds

Scudder California Tax-Free Income Fund

Scudder Florida Tax-Free Income Fund

Scudder High Yield Tax-Free Fund

Scudder Intermediate Tax/AMT Free Fund (formerly Scudder Medium Term Tax-Free Fund)

Scudder Managed Municipal Bond Fund

Scudder Massachusetts Tax-Free Fund

Scudder Municipal Bond Fund

Scudder New York Tax-Free Income Fund

Scudder Short-Term Municipal Bond Fund

Index-Related Funds

Scudder EAFE ^® Equity Index Fund

Scudder Equity 500 Index Fund

Scudder S&P 500 Index Fund

Scudder S&P 500 Stock Fund

Scudder Select 500 Fund

Scudder US Bond Index Fund

Money Market
A large number of money market funds are available through Scudder Investments.

Retirement Programs and Education Accounts

Retirement Programs

Traditional IRA

Roth IRA

SEP-IRA

Inherited IRA

Keogh Plan

401(k), 403(b) Plans

Variable Annuities

Education Accounts

Coverdell Education Savings Account

UGMA/UTMA

IRA for Minors

Closed-End Funds

The Brazil Fund, Inc.

The Korea Fund, Inc.

Montgomery Street Income Securities, Inc.

Scudder Global High Income Fund, Inc.

Scudder New Asia Fund, Inc.

Scudder High Income Trust

Scudder Intermediate Government Trust

Scudder Multi-Market Income Trust

Scudder Municipal Income Trust

Scudder RREEF Real Estate Fund, Inc.

Scudder RREEF Real Estate Fund II, Inc.

Scudder Strategic Income Trust

Scudder Strategic Municipal Income Trust

The Central Europe and Russia Fund, Inc. (formerly The Central European Equity Fund, Inc.)

The Germany Fund, Inc.

The New Germany Fund, Inc.

Not all funds are available in all share classes.

Scudder open-end funds are offered by prospectus only. For more complete information on any fund or variable annuity registered in your state, including information about a fund's objectives, strategies, risks, advisory fees, distribution charges, and other expenses, please order a free prospectus. Read the prospectus before investing in any fund to ensure the fund is appropriate for your goals and risk tolerance.

A money market mutual fund investment is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although a money market mutual fund seeks to preserve the value of your investment at $1 per share, it is possible to lose money by investing in such a fund.

The products described should not be considered a solicitation to buy or an offer to sell a security to any person in any jurisdiction where such offer, solicitation, purchase, or sale would be unlawful under the securities laws of such jurisdiction.

Account Management Resources

For shareholders of Classes A, B, C and Investment

Automated Information Lines	ScudderACCESS (800) 972-3060 Personalized account information, information on other Scudder funds and services via touchtone telephone and for Classes A, B, and C only, the ability to exchange or redeem shares.
Web Site	scudder.com View your account transactions and balances, trade shares, monitor your asset allocation, and change your address, 24 hours a day. Obtain prospectuses and applications, blank forms, interactive worksheets, news about Scudder funds, subscription to fund updates by e-mail, retirement planning information, and more.
For More Information	(800) 621-1048 To speak with a Scudder service representative.
Written Correspondence	Scudder Investments PO Box 219356 Kansas City, MO 64121-9356
Proxy Voting	A description of the fund's policies and procedures for voting proxies for portfolio securities can be found on our Web site - scudder.com (type "proxy voting" in the search field) - or on the SEC's Web site - www.sec.gov. To obtain a written copy without charge, call us toll free at (800) 621-1048.
Principal Underwriter	If you have questions, comments or complaints, contact: Scudder Distributors, Inc. 222 South Riverside Plaza Chicago, IL 60606-5808 (800) 621-1148

	Class A	Class B	Class C	Investment Class
Nasdaq Symbol	DBAIX	DBBIX	DBCIX	BTEQX
CUSIP Number	81111R 502	81111R 601	81111R 700	81111R 809
Fund Number	420	620	720	820

Notes

ITEM 2.         CODE OF ETHICS.

As of the end of the period, October 31, 2003, the Scudder International Equity
Fund has adopted a code of ethics, as defined in Item 2 of Form N-CSR, that
applies to its President and Treasurer and its Chief Financial Officer. A copy
of the code of ethics is filed as an exhibit to this Form N-CSR.

ITEM 3.         AUDIT COMMITTEE FINANCIAL EXPERT.

The Fund's Board of Directors/Trustees has determined that the Fund has at least
one "audit committee financial expert" serving on its audit committee: Mr. S.
Leland Dill. This audit committee member is "independent," meaning that he is
not an "interested person" of the Fund (as that term is defined in Section
2(a)(19) of the Investment Company Act of 1940) and he does not accept any
consulting, advisory, or other compensatory fee from the Fund (except in the
capacity as a Board or committee member).

An "audit committee financial expert" is not an "expert" for any purpose,
including for purposes of Section 11 of the Securities Act of 1933, as a result
of being designated as an "audit committee financial expert." Further, the
designation of a person as an "audit committee financial expert" does not mean
that the person has any greater duties, obligations, or liability than those
imposed on the person without the "audit committee financial expert"
designation. Similarly, the designation of a person as an "audit committee
financial expert" does not affect the duties, obligations, or liability of any
other member of the audit committee or board of directors.

ITEM 4.         PRINCIPAL ACCOUNTANT FEES AND SERVICES.

                        Not currently applicable.

ITEM 5.         [RESERVED]

ITEM 6.         [RESERVED]

ITEM 7.         DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR
                CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

ITEM 8.         [RESERVED]

ITEM 9.         CONTROLS AND PROCEDURES.


(a) The Chief Executive and Financial Officers concluded that the Registrant's
Disclosure Controls and Procedures are effective based on the evaluation of the
Disclosure Controls and Procedures as of a date within 90 days of the filing
date of this report.

(b)During the filing period of the report, management identified issues relating
to the overall fund expense payment and accrual process. Management discussed
these matters with the Registrant's Audit Committee and auditors, instituted
additional procedures to enhance its internal controls and will continue to
develop additional controls and redesign work flow to strengthen the overall
control environment associated with the processing and recording of fund
expenses.

ITEM 10.        EXHIBITS.

(a)(1)   Code of Ethics  pursuant to Item 2 of Form N-CSR is filed and  attached
         hereto as EX-99.CODE ETH.

(a)(2)   Certification  pursuant to Rule 30a-2(a) under the  Investment  Company
         Act of 1940 (17 CFR  270.30a-2(a))  is filed  and  attached  hereto  as
         Exhibit 99.CERT.

(b)      Certification  pursuant to Rule 30a-2(b) under the  Investment  Company
         Act of 1940 (17 CFR  270.30a-2(b))  is furnished and attached hereto as
         Exhibit 99.906CERT.




Form N-CSR Item F

                                   SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, the registrant has duly caused this report to be
signed on its behalf by the undersigned, thereunto duly authorized.

Registrant:                         Scudder International Equity Fund


By:                                 /s/Richard T. Hale
                                    -----------------------------
                                    Richard T. Hale
                                    Chief Executive Officer

Date:                               December 22, 2003
                                    -----------------------------


Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, this report has been signed below by the
following persons on behalf of the registrant and in the capacities and on the
dates indicated.

Registrant:                          Scudder International Equity Fund


By:                                 /s/Richard T. Hale
                                    -----------------------------
                                    Richard T. Hale
                                    Chief Executive Officer

Date:                               December 22, 2003
                                    -----------------------------



By:                                 /s/Charles A. Rizzo
                                    -----------------------------
                                    Charles A. Rizzo
                                    Chief Executive Officer

Date:                               December 22, 2003
                                    -----------------------------

EX-99.CODE ETH

                               Scudder/DeAM Funds

       Principal Executive and Principal Financial Officer Code of Ethics

               For the Registered Management Investment Companies

                              Listed on Appendix A




                                                                 Effective Date
                                                                 [July 15, 2003]





Table of Contents                                                    Page Number

   I.       Overview..........................................................3


   II.      Purposes of the Officer Code......................................3


   III.     Responsibilities of Covered Officers..............................4

      A.    Honest and Ethical Conduct........................................4
      B.    Conflicts of Interest.............................................4
      C.    Use of Personal Fund Shareholder Information......................6
      D.    Public Communications.............................................6
      E.    Compliance with Applicable Laws, Rules and Regulations............6

   IV.      Violation Reporting...............................................7

      A.    Overview..........................................................7
      B.    How to Report.....................................................7
      C.    Process for Violation Reporting to the Fund Board.................7
      D.    Sanctions for Code Violations.....................................7

   V.       Waivers from the Officer Code.....................................7


   VI.      Amendments to the Code............................................8


   VII.     Acknowledgement and Certification of Adherence to
            the Officer Code..................................................8


   IX.      Recordkeeping.....................................................8


   X.       Confidentiality...................................................9


   Appendices................................................................10

      Appendix A:  List of Officers Covered under the Code, by Board.........10
      Appendix B:  Officer Code Acknowledgement and Certification Form.......11
      Appendix C:  Definitions...............................................13



I.       Overview

         This Principal  Executive Officer and Principal  Financial Officer Code
         of Ethics  ("Officer  Code") sets forth the  policies,  practices,  and
         values  expected  to be  exhibited  in the  conduct  of  the  Principal
         Executive  Officers and Principal  Financial Officers of the investment
         companies ("Funds") they serve ("Covered Officers").  A list of Covered
         Officers and Funds is included on Appendix A.

         The Boards of the Funds  listed on Appendix A have elected to implement
         the Officer Code,  pursuant to Section 406 of the Sarbanes-Oxley Act of
         2002 and the SEC's rules thereunder,  to promote and demonstrate honest
         and ethical conduct in their Covered Officers.

         Deutsche Asset  Management,  Inc. or its affiliates  ("DeAM") serves as
         the  investment  adviser to each Fund.  All Covered  Officers  are also
         employees of DeAM or an affiliate. Thus, in addition to adhering to the
         Officer  Code,  these  individuals  must comply with DeAM  policies and
         procedures,  such as the DeAM Code of Ethics governing personal trading
         activities,  as adopted  pursuant  to Rule 17j-1  under the  Investment
         Company Act of 1940.1 In addition,  such  individuals  also must comply
         with other applicable Fund policies and procedures.

         The DeAM Compliance Officer, who shall not be a Covered Officer and who
         shall serve as such  subject to the  approval  of the Fund's  Board (or
         committee  thereof),  is primarily  responsible  for  implementing  and
         enforcing  this Code.  The  Compliance  Officer  has the  authority  to
         interpret  this  Officer  Code  and  its  applicability  to  particular
         circumstances.  Any questions about the Officer Code should be directed
         to the DeAM Compliance Officer.

         The DeAM Compliance  Officer and his or her contact  information can be
         found in Appendix A.

II.      Purposes of the Officer Code

         The purposes of the Officer Code are to deter wrongdoing and to:

         o        promote  honest and ethical  conduct among  Covered  Officers,
                  including the ethical handling of actual or apparent conflicts
                  of interest between personal and professional relationships;

         o        promote  full,  fair,  accurate,   timely  and  understandable
                  disclosures  in reports and documents that the Funds file with
                  or submit to the SEC (and in other public  communications from
                  the  Funds)  and  that  are  within  the   Covered   Officer's
                  responsibilities;

         o        promote   compliance   with   applicable   laws,   rules   and
                  regulations;

         o        encourage the prompt  internal  reporting of violations of the
                  Officer Code to the DeAM Compliance Officer; and

         o        establish accountability for adherence to the Officer Code.

         Any  questions  about the  Officer  Code  should be  referred to DeAM's
         Compliance Officer.

- --------

1 The obligations imposed by the Officer Code are separate from, and in addition
to, any obligations imposed under codes of ethics adopted pursuant to Rule 17j-1
under  the  Investment  Company  Act of  1940,  and any  other  code of  conduct
applicable to Covered Officers in whatever capacity they serve. The Officer Code
does not  incorporate any of those other codes and,  accordingly,  violations of
those codes will not  necessarily  be considered  violations of the Officer Code
and waivers granted under those codes would not necessarily  require a waiver to
be  granted  under  this  Code.  Sanctions  imposed  under  those  codes  may be
considered in determining appropriate sanctions for any violation of this Code.


                                                                               3


III.     Responsibilities of Covered Officers

         A.       Honest and Ethical Conduct

         It is the duty of every Covered  Officer to encourage  and  demonstrate
         honest and ethical conduct,  as well as adhere to and require adherence
         to the Officer Code and any other  applicable  policies and  procedures
         designed to promote this behavior.  Covered  Officers must at all times
         conduct  themselves with integrity and  distinction,  putting first the
         interests of the Fund(s) they serve.  Covered  Officers  must be honest
         and candid  while  maintaining  confidentiality  of  information  where
         required by law, DeAM policy or Fund policy.

         Covered   Officers  also  must,  at  all  times,  act  in  good  faith,
         responsibly  and with  due  care,  competence  and  diligence,  without
         misrepresenting  or being  misleading  about material facts or allowing
         their  independent  judgment to be subordinated.  Covered Officers also
         should maintain skills appropriate and necessary for the performance of
         their duties for the Fund(s).  Covered  Officers also must  responsibly
         use and control all Fund assets and resources entrusted to them.

         Covered  Officers may not  retaliate  against  others for, or otherwise
         discourage  the  reporting  of,  actual or apparent  violations  of the
         Officer Code or applicable laws or regulations. Covered Officers should
         create an  environment  that  encourages  the exchange of  information,
         including concerns of the type that this Code is designed to address.

         B.       Conflicts of Interest

         A  "conflict  of  interest"  occurs when a Covered  Officer's  personal
         interests  interfere with the interests of the Fund for which he or she
         serves as an officer.  Covered  Officers may not  improperly  use their
         position with a Fund for personal or private gain to themselves,  their
         family,  or any other person.  Similarly,  Covered Officers may not use
         their  personal  influence  or  personal   relationships  to  influence
         decisions  or other Fund  business or  operational  matters  where they
         would  benefit  personally  at the  Fund's  expense  or to  the  Fund's
         detriment.  Covered Officers may not cause the Fund to take action,  or
         refrain from taking action,  for their  personal  benefit at the Fund's
         expense or to the Fund's  detriment.  Some  examples  of  conflicts  of
         interest  follow  (this  is not an  all-inclusive  list):  being in the
         position of  supervising,  reviewing or having any influence on the job
         evaluation,  pay or benefit of any  immediate  family  member who is an
         employee of a Fund service provider or is otherwise associated with the
         Fund; or having an ownership  interest in, or having any  consulting or
         employment relationship with, any Fund service provider other than DeAM
         or its affiliates.

         Certain  conflicts  of  interest  covered by this Code arise out of the
         relationships  between  Covered  Officers and the Fund that already are
         subject to conflict of interest  provisions in the  Investment  Company
         Act and the Investment Advisers Act. For example,  Covered Officers may
         not individually  engage in certain  transactions (such as the purchase
         or sale of securities or other property) with the Fund because of their
         status as  "affiliated  persons"  of the Fund.  Covered  Officers  must
         comply with applicable laws and regulations.  Therefore, any violations
         of  existing  statutory  and  regulatory   prohibitions  on  individual
         behavior could be considered a violation of this Code.

         As  to  conflicts  arising  from,  or  as  a  result  of  the  advisory
         relationship (or any other relationships) between the Fund and DeAM, of
         which the  Covered  Officers  are also  officers  or  employees,  it is
         recognized by the Board that, subject to DeAM's fiduciary duties to the
         Fund,  the Covered  Officers  will in the normal course of their duties
         (whether formally for the Fund or for DeAM, or for both) be involved in
         establishing  policies  and  implementing  decisions  which  will  have
         different  effects on


                                                                               4


         DeAM and the Fund. The Board  recognizes that the  participation of the
         Covered  Officers  in  such  activities  is  inherent  in the  contract
         relationship  between  the Fund and DeAM,  and is  consistent  with the
         expectation of the Board of the performance by the Covered  Officers of
         their duties as officers of the Fund.

         Covered  Officers  should  avoid  actual  conflicts  of  interest,  and
         appearances  of conflicts of  interest,  between the Covered  Officer's
         duties  to the  Fund and his or her  personal  interests  beyond  those
         contemplated  or anticipated  by applicable  regulatory  schemes.  If a
         Covered  Officer  suspects or knows of a conflict or an  appearance  of
         one, the Covered Officer must immediately report the matter to the DeAM
         Compliance  Officer.  If a Covered Officer, in lieu of reporting such a
         matter to the DeAM Compliance  Officer,  may report the matter directly
         to the Fund's Board (or committee  thereof),  as appropriate  (e.g., if
         the  conflict  involves  the DeAM  Compliance  Officer  or the  Covered
         Officer reasonably  believes it would be futile to report the matter to
         the DeAM Compliance Officer).

         When  actual,  apparent or  suspected  conflicts  of interest  arise in
         connection with a Covered  Officer,  DeAM personnel aware of the matter
         should promptly contact the DeAM Compliance  Officer.  There will be no
         reprisal or retaliation against the person reporting the matter.

         Upon receipt of a report of a possible  conflict,  the DeAM  Compliance
         Officer will take steps to determine  whether a conflict exists.  In so
         doing,  the DeAM  Compliance  Officer  may take any  actions  he or she
         determines to be appropriate in his or her sole  discretion and may use
         all  reasonable  resources,   including  retaining  or  engaging  legal
         counsel,  accounting firms or other consultants,  subject to applicable
         law.2 The costs  associated with such actions may be borne by the Fund,
         if appropriate,  after consultation with the Fund's Board (or committee
         thereof).  Otherwise,  such  costs  will be  borne  by  DeAM  or  other
         appropriate Fund service provider.

         After full review of a report of a possible  conflict of interest,  the
         DeAM  Compliance  Officer may determine  that no conflict or reasonable
         appearance  of a conflict  exists.  If,  however,  the DeAM  Compliance
         Officer  determines  that an actual  conflict  exists,  the  Compliance
         Officer will resolve the conflict  solely in the interests of the Fund,
         and will report the conflict and its resolution to the Fund's Board (or
         committee thereof).  If the DeAM Compliance Officer determines that the
         appearance of a conflict exists,  the DeAM Compliance Officer will take
         appropriate  steps to remedy such  appearance.  In lieu of  determining
         whether  a  conflict  exists  and/or  resolving  a  conflict,  the DeAM
         Compliance Officer instead may refer the matter to the Fund's Board (or
         committee  thereof),  as  appropriate.  However,  the  DeAM  Compliance
         Officer  must  refer the  matter  to the  Fund's  Board  (or  committee
         thereof) if the DeAM  Compliance  Officer is  directly  involved in the
         conflict or under similar appropriate circumstances.

         After  responding to a report of a possible  conflict of interest,  the
         DeAM  Compliance  Officer  will  discuss  the  matter  with the  person
         reporting it (and with the Covered  Officer at issue, if different) for
         purposes  of  educating   those  involved  on  conflicts  of  interests
         (including how to detect and avoid them, if appropriate).

         Appropriate   resolution   of  conflicts   may  restrict  the  personal
         activities of the Covered  Officer and/or his family,  friends or other
         persons.

         Solely because a conflict is disclosed to the DeAM  Compliance  Officer
         (and/or the Board or  Committee  thereof)  and/or  resolved by the DeAM
         Compliance  Officer does not mean that the  conflict or its  resolution
         constitutes a waiver from the Code's requirements.


- --------

2 For  example,  retaining  a Fund's  independent  accounting  firm may  require
pre-approval by the Fund's audit  committee.

                                                                               5


         Any  questions  about  conflicts  of  interests,  including  whether  a
         particular  situation  might be a  conflict  or an  appearance  of one,
         should be directed to the DeAM Compliance Officer.

         C.       Use of Personal Fund Shareholder Information

         A Covered Officer may not use or disclose  personal  information  about
         Fund  shareholders,  except in the performance of his or her duties for
         the Fund. Each Covered Officer also must abide by the Funds' and DeAM's
         privacy policies under SEC Regulation S-P.

         D.       Public Communications

         In connection with his or her  responsibilities for or involvement with
         a  Fund's  public   communications  and  disclosure   documents  (e.g.,
         shareholder reports,  registration  statements,  press releases),  each
         Covered  Officer must  provide  information  to Fund service  providers
         (within the DeAM  organization  or  otherwise)  and to the Fund's Board
         (and  any  committees  thereof),   independent   auditors,   government
         regulators and  self-regulatory  organizations that is fair,  accurate,
         complete, objective, relevant, timely and understandable.

         Further,  within the scope of their  duties,  Covered  Officers  having
         direct or supervisory authority over Fund disclosure documents or other
         public Fund communications will, to the extent appropriate within their
         area of responsibility, endeavor to ensure full, fair, timely, accurate
         and  understandable  disclosure  in  Fund  disclosure  documents.  Such
         Covered Officers will oversee, or appoint others to oversee,  processes
         for the timely and accurate  creation and review of all public  reports
         and regulatory filings. Within the scope of his or her responsibilities
         as a Covered  Officer,  each  Covered  Officer  also  will  familiarize
         himself or herself with the disclosure  requirements  applicable to the
         Fund,  as well as the business and  financial  operations  of the Fund.
         Each Covered  Officer  also will adhere to, and will promote  adherence
         to, applicable disclosure controls, processes and procedures, including
         DeAM's Disclosure Controls and Procedures,  which govern the process by
         which Fund disclosure documents are created and reviewed.

         To the extent that Covered  Officers  participate  in the creation of a
         Fund's  books or records,  they must do so in a way that  promotes  the
         accuracy, fairness and timeliness of those records.

         E.       Compliance with Applicable Laws, Rules and Regulations

         In connection with his or her duties and within the scope of his or her
         responsibilities as a Covered Officer, each Covered Officer must comply
         with governmental  laws, rules and regulations,  accounting  standards,
         and  Fund   policies/procedures   that   apply  to  his  or  her  role,
         responsibilities  and duties  with  respect  to the Funds  ("Applicable
         Laws").  These  requirements  do not  impose on  Covered  Officers  any
         additional  substantive duties.  Additionally,  Covered Officers should
         promote compliance with Applicable Laws.

         If a Covered  Officer  knows of any material  violations  of Applicable
         Laws or suspects that such a violation may have  occurred,  the Covered
         Officer  is  expected  to  promptly  report  the  matter  to  the  DeAM
         Compliance Officer.



                                                                               6


IV.      Violation Reporting

         A.       Overview

         Each  Covered  Officer  must  promptly  report  to the DeAM  Compliance
         Officer,   and  promote  the  reporting  of,  any  known  or  suspected
         violations of the Officer Code.  Failure to report a violation may be a
         violation of the Officer Code.

         Examples of violations of the Officer Code include, but are not limited
         to, the following:

         o        Unethical or dishonest behavior

         o        Obvious lack of adherence to policies  surrounding  review and
                  approval of public communications and regulatory filings

         o        Failure to report  violations  of the Officer  Code

         o        Known or obvious deviations from Applicable Laws

         o        Failure to  acknowledge  and certify  adherence to the Officer
                  Code

         The  DeAM  Compliance  Officer  has the  authority  to take any and all
         action he or she considers appropriate in his or her sole discretion to
         investigate  known or suspected Code violations,  including  consulting
         with  the  Fund's  Board,  the  independent  Board  members,   a  Board
         committee,  the Fund's legal counsel and/or counsel to the  independent
         Board members. The Compliance Officer also has the authority to use all
         reasonable resources to investigate violations,  including retaining or
         engaging legal counsel, accounting firms or other consultants,  subject
         to applicable law.3 The costs associated with such actions may be borne
         by the Fund, if appropriate,  after  consultation with the Fund's Board
         (or committee thereof). Otherwise, such costs will be borne by DeAM.

         B.       How to Report

         Any known or suspected  violations of the Officer Code must be promptly
         reported to the DeAM Compliance Officer.

         C.       Process for Violation Reporting to the Fund Board

         The DeAM Compliance  Officer will promptly report any violations of the
         Code to the Fund's Board (or committee thereof).

         D.       Sanctions for Code Violations

         Violations of the Code will be taken seriously. In response to reported
         or otherwise known  violations,  DeAM and the relevant Fund's Board may
         impose sanctions  within the scope of their  respective  authority over
         the Covered Officer at issue.  Sanctions  imposed by DeAM could include
         termination  of employment.  Sanctions  imposed by a Fund's Board could
         include termination of association with the Fund.

V.       Waivers from the Officer Code

         A  Covered  Officer  may  request  a waiver  from the  Officer  Code by
         transmitting  a written  request  for a waiver  to the DeAM  Compliance
         Officer.4  The request must include the  rationale  for the request and
         must explain how the waiver would be in furtherance of the standards of
         conduct  described in and underlying  purposes of the Officer Code. The
         DeAM  Compliance  Officer will present this  information  to the Fund's
         Board (or committee  thereof).  The Board (or committee)

- --------

3 For  example,  retaining  a Fund's  independent  accounting  firm may  require
pre-approval by the Fund's audit committee.

4 Of course,  it is not a waiver of the  Officer  Code if the  Fund's  Board (or
committee thereof)  determines that a matter is not a deviation from the Officer
Code's requirements or is otherwise not covered by the Code.

                                                                               7


         will determine  whether to grant the requested waiver. If the Board (or
         committee)  grants the requested  waiver,  the DeAM Compliance  Officer
         thereafter  will  monitor  the  activities  subject to the  waiver,  as
         appropriate, and will promptly report to the Fund's Board (or committee
         thereof) regarding such activities, as appropriate.

         The DeAM Compliance Officer will coordinate and facilitate any required
         public disclosures of any waivers granted or any implicit waivers.

VI.      Amendments to the Code

         The DeAM  Compliance  Officer will review the Officer Code from time to
         time for its continued  appropriateness and will propose any amendments
         to the  Fund's  Board (or  committee  thereof)  on a timely  basis.  In
         addition, the Board (or committee thereof) will review the Officer Code
         at least annually for its continued  appropriateness  and may amend the
         Code as necessary or appropriate.

         The DeAM Compliance Officer will coordinate and facilitate any required
         public disclosures of Code amendments.

VII.     Acknowledgement and Certification of Adherence to the Officer Code

         Each  Covered  Officer  must sign a  statement  upon  appointment  as a
         Covered Officer and annually  thereafter  acknowledging  that he or she
         has  received  and read the Officer  Code,  as amended or updated,  and
         confirming  that  he or she has  complied  with  it  (see  Appendix  B:
         Acknowledgement  and  Certification  of  Obligations  Under the Officer
         Code).

         Understanding  and  complying  with the  Officer  Code  and  truthfully
         completing the  Acknowledgement  and Certification Form is each Covered
         Officer's obligation.

         The DeAM Compliance Officer will maintain such  Acknowledgements in the
         Fund's books and records.

VIII.    Scope of Responsibilities

         A Covered Officer's responsibilities under the Officer Code are limited
         to:

                  (1)      Fund  matters  over  which  the  Officer  has  direct
                           responsibility  or  control,  matters  in  which  the
                           Officer  routinely  participates,  and  matters  with
                           which  the  Officer  is  otherwise   involved  (i.e.,
                           matters  within  the scope of the  Covered  Officer's
                           responsibilities  as a Fund  officer);  and

                  (2)      Fund   matters  of  which  the   Officer  has  actual
                           knowledge.


IX.      Recordkeeping

         The DeAM  Compliance  Officer  will  create  and  maintain  appropriate
         records regarding the implementation and operation of the Officer Code,
         including records relating to conflicts of interest  determinations and
         investigations of possible Code violations.



                                                                               8


X.       Confidentiality

         All reports and records prepared or maintained pursuant to this Officer
         Code  shall be  considered  confidential  and shall be  maintained  and
         protected  accordingly.  Except as  otherwise  required  by law or this
         Officer Code,  such matters shall not be disclosed to anyone other than
         the DeAM Compliance  Officer,  the Fund's Board (or committee thereof),
         legal counsel, independent auditors, and any consultants engaged by the
         Compliance Officer.



                                                                               9




         Appendices

         Appendix A:



         List of Officers Covered under the Code, by Board:


================================================================================
Fund Board     Principal Executive   Principal Financial    Other Persons with
                   Officers               Officers          Similar Functions
- --------------------------------------------------------------------------------
New York         Richard T. Hale        Charles A. Rizzo       --
================================================================================

         DeAM Compliance Officer:

         Name: Amy Olmert

         DeAM Department: Compliance

         Phone Numbers: 410-895-3661 (Baltimore) and 212-454-0111 (New York)

         Fax Numbers: 410-895-3837 (Baltimore) and 212-454-2152 (New York)









As of:   [July 15], 2003


                                                                              10



Appendix B: Acknowledgement and Certification


                    Initial Acknowledgement and Certification
                      of Obligations Under the Officer Code



- --------------------------------------------------------------------------------
Print Name             Department               Location         Telephone




         1.       I  acknowledge  and certify that I am a Covered  Officer under
                  the Scudder Fund  Principal  Executive and  Financial  Officer
                  Code of Ethics ("Officer Code"),  and therefore subject to all
                  of its requirements and provisions.

         2.       I have received and read the Officer Code and I understand the
                  requirements and provisions set forth in the Officer Code.

         3.       I have disclosed any conflicts of interest of which I am aware
                  to the DeAM Compliance Officer.

         4.       I will act in the best interest of the Funds for which I serve
                  as an  officer  and have  maintained  the  confidentiality  of
                  personal information about Fund shareholders.

         5.       I will report any known or suspected violations of the Officer
                  Code in a timely manner to the DeAM Compliance Officer.













- --------------------------------------------------------------------------------
Signature                                               Date


                                                                              11





                    Annual Acknowledgement and Certification
                      of Obligations Under the Officer Code



- --------------------------------------------------------------------------------
Print Name             Department               Location         Telephone




         6.       I  acknowledge  and certify that I am a Covered  Officer under
                  the Scudder Fund  Principal  Executive and  Financial  Officer
                  Code of Ethics ("Officer Code"),  and therefore subject to all
                  of its requirements and provisions.

         7.       I have  received and read the Officer  Code,  and I understand
                  the requirements and provisions set forth in the Officer Code.

         8.       I have adhered to the Officer Code.

         9.       I have not knowingly been a party to any conflict of interest,
                  nor have I had  actual  knowledge  about  actual  or  apparent
                  conflicts  of  interest  that I did  not  report  to the  DeAM
                  Compliance  Officer  in  accordance  with the  Officer  Code's
                  requirements.

         10.      I have  acted in the best  interest  of the  Funds for which I
                  serve as an officer and have maintained the confidentiality of
                  personal information about Fund shareholders.

         11.      With  respect to the  duties I perform  for the Fund as a Fund
                  officer,  I believe that  effective  processes are in place to
                  create and file public  reports and  documents  in  accordance
                  with applicable regulations.

         12.      With  respect to the  duties I perform  for the Fund as a Fund
                  officer,  I have complied to the best of my knowledge with all
                  Applicable  Laws (as that term is defined in the Officer Code)
                  and  have  appropriately  monitored  those  persons  under  my
                  supervision for compliance with Applicable Laws.

         13.      I have  reported  any  known or  suspected  violations  of the
                  Officer  Code  in a  timely  manner  to  the  DeAM  Compliance
                  Officer.



- --------------------------------------------------------------------------------
Signature                                               Date

                                                                              12




         Appendix C:  Definitions

         Principal Executive Officer

         Individual  holding  the office of  President  of the Fund or series of
         Funds, or a person performing a similar function.

         Principal Financial Officer

         Individual  holding  the office of  Treasurer  of the Fund or series of
         Funds, or a person performing a similar function.

         Registered Investment Management Investment Company

         Registered  investment  companies other than a face-amount  certificate
         company or a unit investment trust.

         Waiver

         A waiver is an approval of an exemption from a Code requirement.

         Implicit Waiver

         An implicit  waiver is the failure to take action  within a  reasonable
         period of time  regarding a material  departure  from a requirement  or
         provision  of the  Officer  Code that has been  made  known to the DeAM
         Compliance Officer or the Fund's Board (or committee thereof).


                                                                              13

EX-99.CERT

                                             Deutsche Asset Management [LOGO]
                                             A Member of the Deutsche Bank Group



Chief Executive Officer
Form N-CSR Certification under Sarbanes Oxley Act






I, Richard T. Hale, certify that:

1.            I have reviewed this report, filed on behalf of Scudder
              International Equity Fund, a series of Scudder Advisor Funds, on
              Form N-CSR;

2.            Based on my knowledge, this report does not contain any untrue
              statement of a material fact or omit to state a material fact
              necessary to make the statements made, in light of the
              circumstances under which such statements were made, not
              misleading with respect to the period covered by this report;

3.            Based on my knowledge, the financial statements, and other
              financial information included in this report, fairly present in
              all material respects the financial condition, results of
              operations, changes in net assets, and cash flows (if the
              financial statements are required to include a statement of cash
              flows) of the registrant as of, and for, the periods presented in
              this report;

4.            The registrant's other certifying officer(s) and I are responsible
              for establishing and maintaining disclosure controls and
              procedures (as defined in Rule 30a-3(c) under the Investment
              Company Act of 1940) and internal control over financial reporting
              (as defined in Rule 30a-3(d) under the Investment Company Act of
              1940) for the registrant and have:

                  (a)      Designed such disclosure controls and procedures, or
                           caused such disclosure controls and procedures to be
                           designed under our supervision, to ensure that
                           material information relating to the registrant,
                           including its consolidated subsidiaries, is made
                           known to us by others within those entities,
                           particularly during the period in which this report
                           is being prepared;

                  (b)      Designed such internal control over financial
                           reporting, or caused such internal control over
                           financial reporting to be designed under our
                           supervision, to provide reasonable assurance
                           regarding the reliability of financial reporting



                           and the preparation of financial statements for
                           external purposes in accordance with generally
                           accepted accounting principles;

                  (c)      Evaluated the effectiveness of the registrant's
                           disclosure controls and procedures and presented in
                           this report our conclusions about the effectiveness
                           of the disclosure controls and procedures, as of a
                           date within 90 days prior to the filing date of this
                           report based on such evaluation; and

                  (d)      Disclosed in this report any change in the
                           registrant's internal control over financial
                           reporting that occurred during the registrant's most
                           recent fiscal half-year (the registrant's second
                           fiscal half-year in the case of an annual report)
                           that has materially affected, or is reasonably likely
                           to materially affect, the registrant's internal
                           control over financial reporting; and

5.            The registrant's other certifying officer(s) and I have disclosed
              to the registrant's auditors and the audit committee of the
              registrant's board of directors (or persons performing the
              equivalent functions):

                  (a)      All significant deficiencies and material weaknesses
                           in the design or operation of internal control over
                           financial reporting which are reasonably likely to
                           adversely affect the registrant's ability to record,
                           process, summarize, and report financial information;
                           and

                  (b)      Any fraud, whether or not material, that involves
                           management or other employees who have a significant
                           role in the registrant's internal control over
                           financial reporting.

December 22, 2003                                  /s/Richard T. Hale
                                                     -------------------------
                                                   Richard T. Hale
                                                   Chief Executive Officer
                                                   Scudder International Equity
                                                   Fund, a series of Scudder
                                                   Advisor Funds



                                             Deutsche Asset Management [LOGO]
                                             A Member of the Deutsche Bank Group



Chief Financial Officer
Form N-CSR Certification under Sarbanes Oxley Act






I, Charles A. Rizzo, certify that:

1.            I have reviewed this report, filed on behalf of Scudder
              International Equity Fund, a series of Scudder Advisor Funds, on
              Form N-CSR;

2.            Based on my knowledge, this report does not contain any untrue
              statement of a material fact or omit to state a material fact
              necessary to make the statements made, in light of the
              circumstances under which such statements were made, not
              misleading with respect to the period covered by this report;

3.            Based on my knowledge, the financial statements, and other
              financial information included in this report, fairly present in
              all material respects the financial condition, results of
              operations, changes in net assets, and cash flows (if the
              financial statements are required to include a statement of cash
              flows) of the registrant as of, and for, the periods presented in
              this report;

4.            The registrant's other certifying officer(s) and I are responsible
              for establishing and maintaining disclosure controls and
              procedures (as defined in Rule 30a-3(c) under the Investment
              Company Act of 1940) and internal control over financial reporting
              (as defined in Rule 30a-3(d) under the Investment Company Act of
              1940) for the registrant and have:

                  (a)      Designed such disclosure controls and procedures, or
                           caused such disclosure controls and procedures to be
                           designed under our supervision, to ensure that
                           material information relating to the registrant,
                           including its consolidated subsidiaries, is made
                           known to us by others within those entities,
                           particularly during the period in which this report
                           is being prepared;

                  (b)      Designed such internal control over financial
                           reporting, or caused such internal control over
                           financial reporting to be designed under our
                           supervision, to provide reasonable assurance
                           regarding the reliability of financial reporting



                           and the preparation of financial statements for
                           external purposes in accordance with generally
                           accepted accounting principles;

                  (c)      Evaluated the effectiveness of the registrant's
                           disclosure controls and procedures and presented in
                           this report our conclusions about the effectiveness
                           of the disclosure controls and procedures, as of a
                           date within 90 days prior to the filing date of this
                           report based on such evaluation; and

                  (d)      Disclosed in this report any change in the
                           registrant's internal control over financial
                           reporting that occurred during the registrant's most
                           recent fiscal half-year (the registrant's second
                           fiscal half-year in the case of an annual report)
                           that has materially affected, or is reasonably likely
                           to materially affect, the registrant's internal
                           control over financial reporting; and

5.            The registrant's other certifying officer(s) and I have disclosed
              to the registrant's auditors and the audit committee of the
              registrant's board of directors (or persons performing the
              equivalent functions):

                  (a)      All significant deficiencies and material weaknesses
                           in the design or operation of internal control over
                           financial reporting which are reasonably likely to
                           adversely affect the registrant's ability to record,
                           process, summarize, and report financial information;
                           and

                  (b)      Any fraud, whether or not material, that involves
                           management or other employees who have a significant
                           role in the registrant's internal control over
                           financial reporting.

December 22, 2003                                  /s/Charles A. Rizzo
                                                     ---------------------------
                                                   Charles A. Rizzo
                                                   Chief Financial Officer
                                                   Scudder International Equity
                                                   Fund, a series of Scudder
                                                   Advisor Funds

EX-99.906

                                             Deutsche Asset Management [LOGO]
                                             A Member of the Deutsche Bank Group



Chief Executive Officer
Section 906 Certification under Sarbanes Oxley Act




I, Richard T. Hale, certify that:


1.   I have reviewed this report, filed on behalf of Scudder International
     Equity Fund, a series of Scudder Advisor Funds, on Form N-CSR;

2.   Based on my knowledge and pursuant to 18 U.S.C. ss. 1350, the periodic
     report on Form N-CSR (the "Report") fully complies with the requirements of
     ss. 13 (a) or ss. 15 (d), as applicable, of the Securities Exchange Act of
     1934 and that the information contained in the Report fairly presents, in
     all material respects, the financial condition and results of operations of
     the Company.





December 22, 2003                                  /s/Richard T. Hale
                                                     -------------------------
                                                   Richard T. Hale
                                                   Chief Executive Officer
                                                   Scudder International Equity
                                                   Fund, a series of Scudder
                                                   Advisor Funds



                                             Deutsche Asset Management [LOGO]
                                             A Member of the Deutsche Bank Group



Chief Financial Officer
Section 906 Certification under Sarbanes Oxley Act




I, Charles A. Rizzo, certify that:


1.   I have reviewed this report, filed on behalf of Scudder International
     Equity Fund, a series of Scudder Advisor Funds, on Form N-CSR;

2.   Based on my knowledge and pursuant to 18 U.S.C. ss. 1350, the periodic
     report on Form N-CSR (the "Report") fully complies with the requirements of
     ss. 13 (a) or ss. 15 (d), as applicable, of the Securities Exchange Act of
     1934 and that the information contained in the Report fairly presents, in
     all material respects, the financial condition and results of operations of
     the Company.





December 22, 2003                                  /s/Charles A. Rizzo
                                                     ---------------------------
                                                   Charles A. Rizzo
                                                   Chief Financial Officer
                                                   Scudder International Equity
                                                   Fund, a series of Scudder
                                                   Advisor Funds