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Directors' Fiduciary Duties in Cross-Border Listings: A Comparative Analysis of Mainland China and Hong Kong
Abstract: The proliferation of cross-border listings between Mainland China and Hong Kong has created unprecedented challenges for corporate governance, particularly regarding directors' fiduciary duties. This article examines the fundamental disparities between China's civil law approach to directors' duties and Hong Kong's common law heritage, analysing how these differences manifest in cross-border listing contexts. Through comparative legal analysis and case study methodology, this research reveals that while both jurisdictions have codified directors' duties, their underlying theoretical... [Read More]
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