South Africa.—In Cape Colony the law is contained in No. 25 of 1892, amended 1895 and 1906; it follows English law.
In Natal the law is contained in Nos. 10 of 1864, 18 of 1865, 19 of 1893 and 3 of 1896.
In the Orange Free State in Law Ch. 100 and Nos. 2 and 4 of 1892.
For the Transvaal see Nos. 5 of 1874, 6 of 1874, 1 of 1894 and 30 of 1904.
In Rhodesia companies are regulated by the Companies Ordinance 1895—a combination of the Cape Companies Act 1892, and the British Companies Acts 1862-1890.
France.—There are two kinds of limited liability companies in France—the société en commandite and the société anonyme. The société en commandite corresponds in some respects to the British private company or limited partnership, but with this difference, that in the société en commandite the managing partner is under unlimited liability of creditors; the sleeping partner’s liability is limited to the amount of his capital. The French equivalent of the English ordinary joint stock company is the société anonyme. The minimum number of subscribers necessary to form such a company is (as in the case of a British trading company) seven, but, unlike a British company, the société anonyme is not legally constituted unless the whole capital is subscribed and one-fourth of each share paid up. Another precaution unknown to British practice is that assets, not in money, brought into a company are subject to verification of value by a general meeting. The minimum nominal value of shares, where the company’s capital is less than 200,000 fcs., is 25 fcs.; where the capital is more than 200,000 fcs., 100 fcs. The société is governed by articles which appoint the directors, and there is one general meeting held every year. A société anonyme may, since 1902, issue preference shares. The doctrine that a corporation never dies has no place in French law. A société anonyme may come to an end.
Germany.—In Germany the class of companies most nearly corresponding to English companies limited by shares are “share companies” (Aktiengesellschaften) and “commandite companies” with a share capital (Kommanditgesellschaften auf Aktien). Since 1892 a new form of association has come into existence known by the name of partnership with limited liability (Gesellschaften mit beschrankter Haftung), which has largely superseded the commandite company.
In forming this paid-up company certain preliminary The “share company.” steps have to be taken before registration:—
1. The articles must be agreed on;
2. A managing board and a board of supervision must be appointed;