Skip to main content Accessibility help
×
Hostname: page-component-848d4c4894-tn8tq Total loading time: 0 Render date: 2024-06-24T23:31:14.908Z Has data issue: false hasContentIssue false

24 - Convergence and Divergence in Company Law

from Part III - Central Themes in Comparative Law

Published online by Cambridge University Press:  26 January 2024

Mathias Siems
Affiliation:
European University Institute, Florence
Po Jen Yap
Affiliation:
The University of Hong Kong
Get access

Summary

The debate about legal convergence and divergence has played a prominent role in many areas of law including company law. Although the rules of company law are largely country-specific, certain good governance principles are recognised throughout the EU and many modern jurisdictions around the globe. One of these norms is the equal treatment of shareholders in corporate governance. Shareholder rights usually develop mainly as a means of protection granted to shareholders against management (or controlling shareholders). In terms of comparative law, dissimilarities in shareholder protection may be because of differences in substantive law, but in the case of Turkey variations in the patterns of legal culture and institutional development are seen as the main sources of divergence.

Type
Chapter
Information
Publisher: Cambridge University Press
Print publication year: 2024

Access options

Get access to the full version of this content by using one of the access options below. (Log in options will check for institutional or personal access. Content may require purchase if you do not have access.)

Save book to Kindle

To save this book to your Kindle, first ensure coreplatform@cambridge.org is added to your Approved Personal Document E-mail List under your Personal Document Settings on the Manage Your Content and Devices page of your Amazon account. Then enter the ‘name’ part of your Kindle email address below. Find out more about saving to your Kindle.

Note you can select to save to either the @free.kindle.com or @kindle.com variations. ‘@free.kindle.com’ emails are free but can only be saved to your device when it is connected to wi-fi. ‘@kindle.com’ emails can be delivered even when you are not connected to wi-fi, but note that service fees apply.

Find out more about the Kindle Personal Document Service.

Available formats
×

Save book to Dropbox

To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Dropbox.

Available formats
×

Save book to Google Drive

To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Google Drive.

Available formats
×