الشركات القابضة بين المفهومين الغربي و العربي : دراسة مقارنة

الملخص EN

The positions of the comparative legisalations contradicted in their treatment of the concept of the holding company, While some législations tried to provide an accurate définition of it that includes all its éléments and components, other legisalations confined themselves to clarifying their features by defining the means of its establishment or limiting the subject of its activity.

The législative discrepancy in the définition of the holding company, and the specificity on which its legal system is based, was reflected in the jurisprudential positions that did not agree on a specific définition for it