An International Survey of Companies Law in the Commonwealth, North America, Asia and Europe

Abstract

This Survey originated as a background paper, A Comparative Survey of Companies Law in Selected Jurisdictions (January 1996), prepared for the Financial Services Branch of the Hong Kong Government as part of a Review of the Hong Kong Companies Ordinance.

The Comparative Survey looked at the state of companies and corporate legislation in the United Kingdom, several Commonwealth jurisdictions (including South Africa), the United States, the European Union, France, Germany, Singapore, the People's Republic of China and Bermuda. As disparate an assortment as this may seem, the companies legislation in these various jurisdictions shared sources and influences.

This Survey is an updated version of the original Comparative Survey and was prepared at the request of The Company Law Review of the Department of Trade and Industry, London, U.K. The Company Law Review was launched in March 1998 as a "fundamental review of the framework of core company law" in the U.K. and resulted in the Companies Act 2006 (UK).