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- DescriptionAs 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 10 legal systems. With respect to countries of the European Union, it focuses on the most populous countries (Germany, France, the UK, Spain, Italy and Poland) as well as two smaller Member States (Finland and Latvia). In addition, the laws of two of the world's largest ecomies (the US and Japan) are included for the purposes of wider comparison. 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.
- Author BiographyMathias Siems is a Professor of Commercial Law at Durham University. David Cabrelli is a Senior Lecturer in Commercial Law at the University of Edinburgh.
- PublisherBloomsbury Publishing PLC
- Date of Publication01/02/2013
- SubjectLaw: General & Reference
- Place of PublicationOxford
- Country of PublicationUnited Kingdom
- First Published2010
- ImprintHart Publishing
- Content NoteIllustrations
- Weight756 g
- Width171 mm
- Height244 mm
- Spine20 mm
- Edited byDavid Cabrelli,Mathias M. Siems
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