International and Comparative Law Quarterly



Mathias M Siemsa1

a1 Professor of Law, Norwich Law School University of East Anglia and Research Associate, Centre for Business Research, University of Cambridge.


Regulatory competition in company law has been extensively debated in the last few decades, but it has rarely been discussed whether there could also be regulatory competition in partnership law. This article fills this gap. It addresses the partnership law of the US, the UK, Germany, and France, and presents empirical data on the different types of partnerships and companies established in these jurisdictions. The main focus is on the use of a limited liability partnership (LLP) outside its country of origin. It is also considered whether some regulatory competition can take place in the law of limited partnerships.


This paper was written while I was a Visiting Scholar at St John's College, Oxford, to which I am indebted for its hospitality. I am grateful to John Armour, Veronika Korom, Jennifer Payne and Simon Whittaker for helpful discussions and to Deborah Russell and Natasha Bairstow for their research assistance. The usual disclaimer applies. Email: