Legal Transplants in European Company Law – The Case of Fiduciary Duties

Fleischer Holger

European Company and Financial Law Review, 2005, vol. 2, issue 3, 378-397

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.

Date: 2005
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DOI: 10.1515/ecfr.2005.2.3.378

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