Author(s)

Jingtong Zhou ¹

Affiliation(s)

¹ School of Law, University of Glasgow, Scotland, United Kingdom

Corresponding Author

Jingtong Zhou

ABSTRACT

This paper explores the concept of limited liability within the frameworks of corporation law in the United Kingdom and the United States, focusing on how each jurisdiction approaches the issue of piercing the corporate veil. Limited liability shields shareholders from losses beyond their investment, but its misuse can harm creditors, the environment, and public welfare. Through comparative analysis, this study examines the legal mechanisms, including common law and statutory provisions, that both countries employ to balance protecting shareholders with preventing abuse of the corporate form. It highlights significant differences: the UK's approach is characterized by a broader, more flexible application of veil-piercing doctrines, whereas the US maintains a stringent, narrowly defined criterion for lifting the corporate veil. These differences are reflected in their respective legal outcomes and affect broader corporate accountability. The findings suggest that while both jurisdictions strive to safeguard stakeholders and maintain corporate integrity, their approaches significantly influence corporate behavior and investor security.

KEYWORDS

Limited liability, Piercing the corporate veil, Shareholder accountability, Corporate misconduct

CITE THIS PAPER

Jingtong Zhou. Veil Piercing and Shareholder Liability: A Comparative Analysis of Legal Frameworks in the UK and US. Science of Law Journal (2024) Vol. 3: 13-16. DOI: http://dx.doi.org/DOI: 10.23977/law.2024.030703.

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