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The laws applies to a company are the ones where company is registered.
Typology: Lecture notes
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Discuss the two opposing theories: incorporation theory v. real seat theory.
Definition
Definition
Incorporation theory used in UK, Scandinavia and the Netherlands Real seat theory developed in France and used in most continental countries.
What are the impacts of either theory?
Incorporation theory
Incorporation theory
▪ Most important question of the judgment ▪ The extent to which it affects national rules on the question of a company’s nationality.
Facts