Comparative Company Law: A Case-Based Approach - Softcover

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9781509909360: Comparative Company Law: A Case-Based Approach
Softcover
ISBN 10: 1509909362 ISBN 13: 9781509909360
Publisher: Hart Publishing, 2018

Synopsis

As attention moves rapidly towards comparative approaches, the research and teaching of company law has somehow lagged behind. The overall purpose of this book is therefore to fill a gap in the literature by identifying whether conceptual differences between countries exist. Rather than concentrate on whether the institutional structure of the corporation varies across jurisdictions, the objective of this book will be pursued by focusing on specific cases and how different countries might treat each of these cases. The book also has a public policy dimension, because the existence or absence of differences may lead to the question of whether formal harmonisation of company law is necessary. The book covers 12 legal systems from different legal traditions and from different parts of the world (though with a special emphasis on European countries). In alphabetical order, those countries are: Finland, France, Germany, Italy, Japan, Latvia, the Netherlands, Poland, South Africa, Spain, the UK, and the US. All of these jurisdictions are subjected to scrutiny by deploying a comparative case-based study. On the basis of these case solutions, various conclusions are reached, some of which challenge established orthodoxies in the field of comparative company law.

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About the Author

Mathias M Siems is Professor of Commercial Law at Durham University. David Cabrelli is Senior Lecturer in Commercial Law at Edinburgh University.

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Publisher
Hart Publishing
Publication date
2018
Language
English
ISBN 10 
1509909362
ISBN 13 
9781509909360
Binding
Paperback
Edition number
2
Number of pages
584
Editor
Mathias M Siems, David Cabrelli