5 ms·

They don't have LLCs?

Juliate 5y ago
There are equivalents (https://fr.wikipedia.org/wiki/Responsabilit%C3%A9_limit%C3%A9e https://fr.wikipedia.org/wiki/Responsabilit%C3%A9_limit%C3%A... - in French) but country-specific, there's no a European common structure. But another benefit from LLCs in the USA might be the lighter paperwork and simpler taxes filing. Which we also have (in France at least, as entrepreneur individuel), but both don't intersect.
- Bayart 5y ago
  >there's no a European common structure. There are European corporate entities nowadays. See SE[0], SCE[1] and SPE[2]. The SPE is what you'd call an LLC, GmbH, SARL etc. [0] https://en.wikipedia.org/wiki/Societas_Europaea https://en.wikipedia.org/wiki/Societas_Europaea [1] https://en.wikipedia.org/wiki/Societas_cooperativa_Europaea https://en.wikipedia.org/wiki/Societas_cooperativa_Europaea [2] https://en.wikipedia.org/wiki/Societas_privata_Europaea https://en.wikipedia.org/wiki/Societas_privata_Europaea
MatthewMcDonald 5y ago
I don't know about the bankruptcy laws, but Germany's GMBH (similar to an LLC) requires 25k in capital to get started.
- thesimon 5y ago
  UG requires only 1ct, though extracting profit is a bit more difficult until you get to 25k.
- jbverschoor 5y ago
  It used to be 18k here. Not anymore. However an LLC will provide you with almost no protection anymore.
  - tluyben2 5y ago
    What does that mean? A BV protects you unless you pierce the veil. You are negligent or a malicious if you do so; otherwise it does protect you. But maybe you mean something else.
zerkten 5y ago
LLCs aren't really relevant to this. The poster was commenting on bankruptcy laws with the assumption of familiarity. You can check out articles like https://link.springer.com/article/10.1007%2Fs10657-006-8978-2 https://link.springer.com/article/10.1007%2Fs10657-006-8978-..., but the gist is that bankruptcy in the US is forgiving versus being a terminal state in Europe. This is both in law and in society. Once someone has gone bankrupt in Europe, they are historically, are a pariah. They will struggle to get financing to take a risk with another company. This is on top of a risk-averse system that generally places much higher requirements on non-bankrupt people seeking financing. Compare this to the situation in the US. Here there is relatively easy access to financing at all sizes of organization. It only noticeably tightens when there is a recession or there are very serious issues with the founders. When a company fails there are more options for recovery, sell-off, acquisition, etc. Labor law permits companies to jettison all employees easily too in certain situations whereas that is much more difficult in Europe. Although this is starting to get away from pure bankruptcy law it overlaps.
- kdomanski 5y ago
  This. In addition, in some countries like Germany, having your name connected to a bankruptcy will ruin your credit score, making it difficult to e.g. rent an apartment.

There are equivalents (https://fr.wikipedia.org/wiki/Responsabilit%C3%A9_limit%C3%A9e https://fr.wikipedia.org/wiki/Responsabilit%C3%A9_limit%C3%A... - in French) but country-specific, there's no a European common structure. But another benefit from LLCs in the USA might be the lighter paperwork and simpler taxes filing. Which we also have (in France at least, as entrepreneur individuel), but both don't intersect.

Bayart 5y ago
>there's no a European common structure. There are European corporate entities nowadays. See SE[0], SCE[1] and SPE[2]. The SPE is what you'd call an LLC, GmbH, SARL etc. [0] https://en.wikipedia.org/wiki/Societas_Europaea https://en.wikipedia.org/wiki/Societas_Europaea [1] https://en.wikipedia.org/wiki/Societas_cooperativa_Europaea https://en.wikipedia.org/wiki/Societas_cooperativa_Europaea [2] https://en.wikipedia.org/wiki/Societas_privata_Europaea https://en.wikipedia.org/wiki/Societas_privata_Europaea

MatthewMcDonald 5y ago

I don't know about the bankruptcy laws, but Germany's GMBH (similar to an LLC) requires 25k in capital to get started.

thesimon 5y ago
UG requires only 1ct, though extracting profit is a bit more difficult until you get to 25k.
jbverschoor 5y ago
It used to be 18k here. Not anymore. However an LLC will provide you with almost no protection anymore.
- tluyben2 5y ago
  What does that mean? A BV protects you unless you pierce the veil. You are negligent or a malicious if you do so; otherwise it does protect you. But maybe you mean something else.

zerkten 5y ago

LLCs aren't really relevant to this. The poster was commenting on bankruptcy laws with the assumption of familiarity. You can check out articles like https://link.springer.com/article/10.1007%2Fs10657-006-8978-2 https://link.springer.com/article/10.1007%2Fs10657-006-8978-..., but the gist is that bankruptcy in the US is forgiving versus being a terminal state in Europe. This is both in law and in society. Once someone has gone bankrupt in Europe, they are historically, are a pariah. They will struggle to get financing to take a risk with another company. This is on top of a risk-averse system that generally places much higher requirements on non-bankrupt people seeking financing. Compare this to the situation in the US. Here there is relatively easy access to financing at all sizes of organization. It only noticeably tightens when there is a recession or there are very serious issues with the founders. When a company fails there are more options for recovery, sell-off, acquisition, etc. Labor law permits companies to jettison all employees easily too in certain situations whereas that is much more difficult in Europe. Although this is starting to get away from pure bankruptcy law it overlaps.

kdomanski 5y ago
This. In addition, in some countries like Germany, having your name connected to a bankruptcy will ruin your credit score, making it difficult to e.g. rent an apartment.