Leasing and Legal Culture
Towards consistent behaviour in tax treatment in civil law and common law jurisdictions
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This dissertation provides a historical comparative study of the phenomenon of leasing as a common law concept developed in the United States and transplanted into the civil law recipient countries of Colombia, France and the Netherlands. I demonstrated that the recipient countries did not transplant the approach of the donor country but provided their own rules and solutions to the problems encountered by the legal transplant of leasing. I also argued and proved that the differences in legal rules for leasing could be explained in terms of differences in legal systems and legal cultures.The m...
This dissertation provides a historical comparative study of the phenomenon of leasing as a common law concept developed in the United States and transplanted into the civil law recipient countries of Colombia, France and the Netherlands. I demonstrated that the recipient countries did not transplant the approach of the donor country but provided their own rules and solutions to the problems encountered by the legal transplant of leasing. I also argued and proved that the differences in legal rules for leasing could be explained in terms of differences in legal systems and legal cultures.The mismatch between the common law legal system of the United States and the civil law legal system of Colombia, France and to some extent the Netherlands has been confirmed by this research. In this study, I have demonstrated that approach to common law as a case law based legal system and the civil law as a codified legal system is of a general character and therefore deviations occur. For instance, tax law in the Netherlands concerning determination of profits provides for a system of consensus with open norms.
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