Holger Fleischer, Peter Agstner

Personengesellschaften in Italien und Deutschland

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This paper explores the trajectories of partnership law in Italy and Germany, firstly tracing its origins back to both the classical societas in Roman law and the late medieval commenda and compagnia in Northern Italy. It moves on to analyse the key characteristics of partnerships on both sides of the Alps, beginning with their legal nature and the organisation of partnership property either as joint property or as a community of collected hands (Gesamthand). Further topics include the liability of partners vis-à-vis third parties and the principles of management and the legal representation of partnerships in both jurisdictions.

Holger Fleischer is Director at the Max Planck Institute for Comparative and International Private Law in Hamburg and Affiliate Professor at the Bucerius Law School, Hamburg.

Peter Agstner No current data available.