Shareholding Structure and Corporate Governance: Rethinking of the Theoretical Logic of the Two Corporate Governance Models

The issues of corporate governance of one particular country are determined by different shareholding structure. Whereas the shareholding structure of Anglo-saxson corporations is dispersed, their corporate governance issues are characterized by the conflict between the management and shareholders, and the policy measures to improve corporate governance lies in the accountability of the management. However, large corporations in the other side of the world are characterized by centralized shareholding structure and the predominate corporate governance issue thereof is exploitation of minority shareholders by controlling shareholders. Therefore the relevance of Anglo-saxon measures to improve corporate governance is limited in solving the corporate problems in centralized shareholding corporations. The Chinese corporate law reform should take into consideration the observations of comparative corporate governance and be very cautious in introducing Anglo-saxon models.