CEU Electronic Theses and Dissertations, 2018
| Author | Akhaeva, Medine Vaapovna |
|---|---|
| Title | Comparison Of The Doctrine Of Enterprise Liability In U.S., Germany And Uzbekistan |
| Summary | As a rule, a parent company and its subsidiary are district legal entities that are not liable for the obligations of each other. Even though limited liability protects a parent company from incurring debts of its subsidiary, nevertheless, there are exceptions to this principle that allow a parent company to be held liable for the debts and obligations of the subsidiary. Such exceptions can be applicable both to individual and corporate shareholders. This thesis provides comparison of “enterprise liability” doctrines, i.e. rules regulating parent-subsidiary liability in the U.S., Germany and Uzbekistan. In U.S. these rules which are known as “piercing the corporate veil” doctrine has been developed by court practice. In civil law countries like Germany and Uzbekistan rules that regulate situations when a parent company can be held liable for the actions of its subsidiary are of statutory nature and are contained in Codes and Acts. This thesis analyzes “enterprise liability” rules in each of these jurisdictions and provides their comparison. These approaches to parent-subsidiary liability differ with their sources, the scope of application, however, they all are aimed at providing protection to the subsidiary’s creditors and other shareholders. |
| Supervisor | Lawrence, Jessica Charles |
| Department | Legal Studies LLM |
| Full text | https://www.etd.ceu.edu/2018/akhaeva_medine.pdf |
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