基本説明
Examines the company law of the UK, the USA, Germany, France, Japan and China.
Full Description
On the one hand, it can be argued that the increasing economic and political interdependence of countries has led to the convergence of national legal systems. On the other hand, advocates of the counterhypothesis maintain that this development is both unrealistic and unnecessary. Mathias M. Siems examines the company law of the UK, the USA, Germany, France, Japan and China to see how this issue affects shareholder law. The author subsequently analyses economic and political factors which may or may not lead to convergence, and assesses the extent of this development. Convergence of Shareholder Law not only provides a thorough comparative legal analysis but also shows how company law interconnects with political forces and economic development and helps in evaluating whether harmonisation and shareholder protection should be enhanced.
Contents
Introduction; Part I. The Object and Course of the Investigation: 1. Dimensions of convergence in shareholder law; Part II. The Status Quo of Convergence: 2. Legal bases; 3. Bases for a shareholder typology; 4. The 'Shareholder as Such'; 5. The shareholder in the power structure of the company; 6. Conclusions of Part II; Part III. Developmental Trends and Patterns: 7. Bases; 8. Convergence through congruence; 9. Convergence through pressure; 10. Future convergences in shareholder law; 11. Conclusions of Part III; Part IV. Conclusion: 12. Convergence as a model for the future; 13. Summary of principal findings.
