Overview

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.

Full Product Details

Author:   Mathias Siems (Durham University) ,  David Cabrelli
Publisher:   Bloomsbury Publishing PLC
Imprint:   Hart Publishing
Edition:   2nd edition
Weight:   0.994kg
ISBN:  

9781509909360

ISBN 10:   1509909362
Pages:   584
Publication Date:   20 September 2018
Audience:   College/higher education ,  Professional and scholarly ,  Tertiary & Higher Education ,  Professional & Vocational
Format:   Paperback
Publisher's Status:   Active
Availability:   Manufactured on demand  
We will order this item for you from a manufactured on demand supplier.

Table of Contents

1. A Case-Based Approach to Comparative Company Law David Cabrelli and Mathias Siems PARTS 1 to 3 COMPARATIVE CASE STUDIES Country reports by Sonja Siggberg, Jesse Collin and Lena Nordman (Finland), Pierre-Henri Conac (France), Mathias Siems (Germany), Marco Ventoruzzo and Corrado Malberti (Italy), Hisaei Ito and Hiroyuki Watanabe (Japan), Theis Klauberg (Latvia), Mieke Olaerts and Bastiaan Kemp (the Netherlands), Michal Zurek and Kamil Szmid (Poland), Irene-marié Esser and Piet Delport (South Africa), Pablo Iglesias-Rodríguez (Spain), David Cabrelli (UK), Martin Gelter, Nemika Jha and D Gordon Smith (US) PART 1 DIRECTORS’ DUTIES AND LIABILITY 2. General Case on Directors’ Duties Edited by Theis Klauberg 3. Duties of Nominee Directors Edited by Martin Gelter, Nemika Jha and D Gordon Smith 4. Obligations of Directors in Takeovers Edited by Pablo Iglesias-Rodriguez 5. Cross-Border Takeovers and Takeover Defences Edited by Sonja Siggberg, Jesse Collin and Lena Nordman PART 2 CREDITOR PROTECTION 6. Piercing the Corporate Veil Edited by Hisaei Ito and Hiroyuki Watanabe 7. Capital Maintenance Edited by MichalZurek and Kamil Szmid PART 3 SHAREHOLDER PROTECTION 8. Shareholders and Shareholder Law Edited by Pierre-Henri Conac 9. Abuse of Shareholder Rights Edited by Mathias Siems 10. Shareholders’ Rights and Litigation Edited by David Cabrelli 11. Limitations on the Shareholder’s Right to Transfer Shares Edited by Corrado Malberti and Marco Ventoruzzo PART 4 CONCLUSION 12. A Rule-Based Comparison and Analysis of the Case Studies David Cabrelli and Irene-marie Esser 13. A Quantitative Analysis of Similarities and Diff erences in Form, Style and Substance Mathias Siems

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

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