Die Konvergenz der Rechtssysteme im Recht der Aktionäre

The words globalization, internationalization and Europeanization are currently seen and heard everywhere. Thus, it is also often claimed that national legal systems come closer and closer together. Advocates of the counterhypothesis however maintain that convergence of legal systems is neither realistic nor necessary. Mathias M. Siems takes a look at how to approach this issue in shareholder law. First, he deals with the company law of Germany, France, the United Kingdom, the USA, Japan and China. Second, he analyzes economical and political factors, which might (or might not) lead to convergence. Finally, he assesses this development.