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...

All jurisdictions supply corporations with legal tools to prevent or punish asset diversion by those, whether managers or dominant shareholders, who are in control. As previous research has shown, these rules, doctrines and remedies are far from uniform across jurisdictions, possibly leading to...

The pattern of legal change in countries that have their legal systems transplanted from abroad differs markedly from countries that develop their own systems, irrespective of the legal family from which their laws come. In transplant countries, law often stagnates for long periods of time; when...

In consideration of the corporate governance discussion and the discussion of the stock corporation act's deregulation and the diminution of mandatory law, one can see that the economy requires different models and legal solutions for different situations. In this regard, it would be reasonable...

Valuation of shares is of critical importance when shareholders are forced to leave their company. Despite this importance, there is little comparative scholarship on how the valuation issue is handled in different jurisdictions. As part of a broader research agenda, this paper explores the...