Comparative company law : a case-based approach

著者

• Siems, Mathias M.
• Cabrelli, David A.

書誌事項

Comparative company law : a case-based approach

edited by Mathias Siems and David Cabrelli

Hart, 2018

2nd ed

• : pbk

注記

Includes index

内容説明・目次

内容説明

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.

目次

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-marie Esser and Piet Delport (South Africa), Pablo Iglesias-Rodriguez (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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詳細情報

• NII書誌ID(NCID): BB26918954
• ISBN:
  • 9781509909360
• LCCN: 2018019378
• 出版国コード: uk
• タイトル言語コード: eng
• 本文言語コード: eng
• 出版地: Oxford
• ページ数/冊数: xiii, 566 p.
• 大きさ: 25 cm
• 分類:
  • LCC : K1315
  • DC23 : 346/.066
• 件名:
  • LCSH : Corporation law