Author: | Leuz, C. Deller, D. Stubenrath, M. |
Title: | An international comparison of accounting-based payout restrictions in the United States, United Kingdom and Germany |
Journal: | Accounting and Business Research
1998 : SPRING, VOL. 28:2, p. 111-129 |
Index terms: | dividends regulations |
Language: | eng |
Abstract: | This article compares restrictions in corporations' ablility to pay dividends to shareholders in the United States, the United Kingdom and Germany. In order to obtain a more clear picture both legal and contractual dividend restrictions are explored. The comparison shows, that despite marked institutional differences between the US, the UK and Germany, corporations are restricted in a similar fashion in all three countries. |
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