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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...
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This paper discusses the German conflict of law rules as they apply to companies (ie, the private international law of companies in Germany). Amongst others, it addresses the connecting factor, the scope of the lex societatis, outreach statutes and the possibility of reincorporations in German...
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In this Article, we intend to fill a gap in the comparative law literature by adopting a case-based approach to comparative corporate law that highlights the important dimension of specific cases in corporate law matters and how identifiable, but limited issues arising from such case disputes...
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In the growing literature on comparative corporate law there is often a lack of consideration to the recent advances made in the general field of comparative law. This chapter aims to fill this gap. It outlines a conceptual framework that shows how seven core themes of comparative law can be...
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The leximetric research on shareholder protection can contribute to core questions of comparative company law. For example, such research may be able to show whether or not there is a trend to increase shareholder power across countries. It can also provide us with tools to confirm or challenge...
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A case-based approach to comparative company law / David Cabrelli and Mathias Siems -- General case on directors duties / Theis Klauberg -- Duties of nominee directors / Martin Gelter, Memika Gha and D Gordon Smith -- Obligations of directors in takeovers / Pablo Iglesias-Rodríguez --...
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