Personal Liability in a Partnership

The study explores the complexities of selecting a business association type in the context of increasing cross-border commerce. It highlights how parties, influenced by their own legal systems, are now considering foreign legal options due to the shift from the real seat theory to the incorporation theory in international company law. This transition allows for the extraterritorial application of national business associations. Additionally, the mandatory nature of business associations law regarding external relationships encourages the use of foreign associations that may offer significant advantages over domestic options.