Comparative analysis of the provisions of a corporate contract in the context of the development of modern Russian and foreign legal systems
The current situation of the corporate contract both in Russia and in other foreign countries requires the study of the historical course of the presented issue and the display of legal forms of its solution in order to adapt the gradual development of a modern legal institution. The author of the presented study examines two models of a corporate contract that have found their place in the Anglo-Saxon and Romano-Germanic legal families. The comparative analysis of the provisions of the corporate contract in the context of the development of modern Russian and foreign legal systems was able to demonstrate that the current situation of Russian corporate law institutions is directly interfaced with the economic situation of the country, and is also caused by the frequent borrowing of the features of the foreign corporate-contractual model of foreign law and the order for domestic law. At the end of the study, the author comes to the conclusion that one should not deny the importance of borrowing foreign experience, including in solving relevant problems of maintaining domestic corporate law institutions, but it requires adapting an autonomous vision of the possibility of solving urgent problems of Russian corporate law, which is largely interfaced with other provisions of the legislation of the Russian Federation, in order to identify the level of appropriateness of implementing certain provisions of European civil law into it.