Anatomy and terminology of business organizations: a brief comparison and assimilation between Chinese and Italian companies

Andrea Sebastiani


The aim of this article is to remove the initial confusion that could occur in the comparison between Italian
and Chinese business organizations. The analysis focuses mainly on company types, classification adopted,
sources, and terminology used, in both countries. In this wide and general juxtaposition, it is proposed to
use an assimilation method through which the main features of Italian and Chinese business entities have
been compared regarding various aspects, in order to better understand differences and similarities arising
from these two legal systems. One consequence of resorting to this method was the need to use certain general
English notions – such as people’s organization, business organization, company – to clarify the comparison.
For instance, the term company itself has been used to outline a wide group of business entities which include
not only the Limited Lability Companies or Joint Stock Companies (gongsi) - as it might appear reasonable
at a first look at the Chinese system - but even other form of partnerships, in accordance with the Italian
and Roman concept of "società and societas", which even comply to the notion offered by the Black’s law

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Comparative Law Review is registered at the Courthouse of Monza (Italy) - Nr. 1988 - May, 10th 2010.
Editors - Prof. Giovanni Marini, Prof. Pier Giuseppe Monateri, Prof. Tommaso Edoardo Frosini, Prof. Salvatore Sica, Prof. Alessandro Somma, Prof. Giuseppe Franco Ferrari, Prof. Massimiliano Granieri.

Direttore responsabile:Alessandro Somma