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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 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. Thus,
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.
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 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, which was originally published in
2007, 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.
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