"The purpose of this paper consists of giving an overview of the way company laws in some European states have been dealingwith the dividing line between closely held companies limited by shares, and those that have gone public or have widely distributed shares. It analyses whether a case can be made for regrouping the rules relating to “public” companies in a single body of law, a discussion that is going on in Germany. Also analysed is the question to what extent other jurisdictions have a fully mandatory companies act, comparable to the German “Satzungsstrenge”. "

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