This article describes and analyzes the doctrine of piercing the corporate veil in various jurisdictions across the world. First, it introduces the development and history of this doctrine in the United States - the jurisdiction, which has nurtured this legal concept for several centuries. Second, it analyzes its possible implementation within two chosen jurisdictions in Central and Eastern Europe: Romania and Slovakia. The authors’ aim is to assess their home jurisdictions and examine whether these jurisdictions apply the doctrine, if so, then in which form and to what extent. The authors analyze different areas of their respective legal systems - company law, civil law, and bankruptcy law. Lastly, the authors reason why the doctrine of corporate veil piercing is of importance to any legal system, and why the legislators in CEE region specifically should consider inserting and applying it.
Alexandra Horvathova & Catalin G. Stanescu,
Piercing The Corporate Veil US Lessons From Romania And Slovakia,
Chi.-Kent J. Int'l
& Comp. Law
Available at: http://scholarship.kentlaw.iit.edu/ckjicl/vol17/iss1/7