Comparative legal analysis of the concept of "corporation" on the example of countries of the Asia-Pacific Region

Abstract

The article is devoted to the problem of the concept of «corporation» in the law of Russia, China, Japan and the Republic of Korea. The history of the concept of «corporation» in the above-mentioned states is shown, the differences and similarities with the corporations of Russia are given. Also, the author pays attention to the types of legal entities, the problem of ambiguity of the criterion for the division of legal entities is touched upon. The authors compare the foreign experience with domestic legislation, give examples of commercial and non-commercial organizations, specify advantages and characteristics of corporate law in Russia. In addition, the reference is made to such regulatory legal acts as codes and special laws, clarifying concepts, types of legal entities, in general, regulating the activities of corporations in these countries. Proceeding from the features of the concept «corporation» in Russia, China, Japan and the Republic of Korea, it is concluded that there is an acute need for the most detailed settlement of concepts, types, and criteria for classifying certain corporations as commercial or noncommercial. The need for a similar legal regulation in the sphere of corporate law of the countries of Asian-Pacific Region is unambiguous.