Legal Transplants in European Company Law - The Case of Fiduciary Duties
Posted: 1 Dec 2007
Abstract
The following article explores the concept of legal transplants with a view to the emerging corporate 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.
Suggested Citation: Suggested Citation
Fleischer, Holger, Legal Transplants in European Company Law - The Case of Fiduciary Duties. European Company and Financial Law Review, Vol. 2, No. 3, 2006, Available at SSRN: https://ssrn.com/abstract=1034062
Holger Fleischer (Contact Author)
Max Planck Institute for Comparative and International Private Law ( email )
Mittelweg 187
Hamburg, 20148
Germany
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