Introduction

This book aims at explaining the interrelationships between economic elements and legal principles with reference to business and company law. Three jurisdictions are taken into consideration: US, UK, and Italian law (the latter chosen as a prototype of continental European legal systems). In addition, since Italy is a member state of the European Union that harmonizes, through regulations and directives, company law among European member states, an introduction to European company law will be covered by the book. The economic elements that lie at the ground of business and company law are actually common to the three legal systems, and consequentially, legal principles and rules are very similar despite the fact that one jurisdiction (namely, Italy) belongs to civil law and the other two to common law legal families. Similarity also depends on the historical origins of the legal instruments that are covered by the book: partnership law traces back to Roman law, while company law traces back to English law. Roman law and English law have influenced, respectively, the law of partnerships and of companies worldwide.