Clash of Corporate Personality Theories: A Comparative Study of One-Member Company in Singapore and China
Hong Kong Law Journal, Vol. 38, pp.425-452, 2008
28 Pages Posted: 9 Jun 2010
Date Written: May 1, 2008
Abstract
China accords the one-member company special treatment distinct from the normal company. This is in sharp contrast with Singapore's indifferent attitude towards one-member company vis-à-vis normal company. This paper critically examines these two distinct approaches including the respective substantive rules, legislative background and underlying jurisprudential theories. The respective advantages and limitations of the theories / approaches are then identified. The aim is to propose a new jurisprudential approach towards corporate personality which draws on the strength of the two theories while avoiding their pitfalls.
Keywords: Company Law, Comparative Law, Corporate Personality, One-Member Company, China, Singapore
Suggested Citation: Suggested Citation