Piercing the corporate veil, comparative outlines of this institute and recodification of czech private law
Abstract
This article discusses the institution of corporate veil (and its analogies) in the economically most important traditional legal orders (USA , England and Wales, Germany and France). It focuses on an analysis of the theoretical concepts of such institutions in the respective legal orders and points out conceptual differences of these institutions in relevant legal orders.
Having done so, the current writer turns to the 2011 proposed concept of the Czech corporate law and proposed piercing of corporate veil vis-a-vis managers in such entities under the planned Czech legislation and by comparison to the applicable outlines and framework of this institution abroad, the current writer points to the weaknesses of the content Czech bill, suggesting it be re-drafted before passing.