Corporate governance - the way that major businesses are run - has been of in-creasing concern in recent years. Financial scandals in companies like Enron and WorldCom, as well as similar problems in Europe, have resulted in most major countries introducing corporate governance codes. However,...

All jurisdictions supply corporations with legal tools to prevent or punish asset diversion by those, whether managers or dominant shareholders, who are in control. As previous research has shown, these rules, doctrines and remedies are far from uniform across jurisdictions, possibly leading to...