Legal Transplants in European Company Law – The Case of Fiduciary Duties
Open Access
- 1 September 2005
- journal article
- research article
- Published by Walter de Gruyter GmbH in European Company and Financial Law Review
- Vol. 2 (3) , 378-397
- https://doi.org/10.1515/ecfr.2005.2.3.378
Abstract
The following article explores the concept of legal transplants with a view to the emerging coporate governance issue of directors’ fiduciary duties which has been developed in UK and US company law and now enters central Continental jurisdictions. It reaches a positive overall assessment of this development and underlines the growing importance of comparative research.Keywords
This publication has 0 references indexed in Scilit: