Incorporation (business) - International Perspective

International Perspective

The legal concept of incorporation is recognized all over the world.

• In the United States, there are many ways that a corporation can be identified. The four forms that are valid in all 50 states and the District of Columbia are "Corporation", "Incorporated," and the abbreviations "Corp." and "Inc." Some states allow the use of "Company" and some have additional optional names. A complete list of which names are allowed in each state can be found at Types_of_business_entity#United_States.
• In Germany, Austria and Switzerland, the GmbH ("Gesellschaft mit beschränkter Haftung", meaning "limited liability business association"), as well as the AG ("Aktiengesellschaft", meaning "business association with shares"), are the entities most similar to the corporations in the U.S.
• In the United Kingdom, with the exception of an unlimited company or corporation which requires no designation as part of its legal company name, the titles Ltd. (limited company) or plc (public limited company) are used for corporations.
• In France, Switzerland, Belgium and Luxembourg, the term "SARL" (société à responsibilité limitée, company with limited liability) or SA (société anonyme, anonymous partnership) is used.
• Spain, Portugal, Poland, Romania and Latin America use the title SA (anonymous partnership) for stock corporations or Ltda (limitada or limited liability) for limited companies. (Ltda is denoted SL in Spain, for "Sociedad Limitada", and SRL in Argentina, for ("Sociedad de Responsabilidad Limitada").
• Denmark and Norway uses the title A/S for stock corporations (Danish: Aktieselskab, Norwegian: Aksjeselskap), while Sweden uses the similar AB (Swedish: aktiebolag). Finland uses Oy (Finnish:Osakeyhtiö), Oyj for stock corporations (Osakeyhtiö, julkinen) and Ay (Avoin yhtiö) or Ky (Kommandiittiyhtiö) for private enterprises.
• In India, the term Pvt. Ltd. is used for a company that is private, an entity similar to LLC in U.S. Ltd. is used for public unlisted company or a public corporation, a similar entity to a corporation in the U.S.
• Italy uses "Srl" or "Società a Responsabilità Limitata" (limited liability company), and "SpA" or "Società Per Azioni" (stock corporation).
• In the Netherlands, NV and BV are used.
• Malaysia uses Sdn. Bhd. (Malay: Sendirian Berhad), meaning "private limited", which is the equivalent of an incorporated entity in the U.S.
• Indonesia uses P.T. (Indonesian: Perseroan Terbatas), meaning "private limited", which is the equivalent of an incorporated entity in the U.S. This legal title is stated in front of the corporation name. If the shares become publicly listed for trading in stock exchange, it's called Tbk. (Indonesian: Terbuka), appended after the corporation name.
• Slovakia uses s.r.o. ("spoločnosť s ručením obmedzeným" meaning "business with limited liability") and a.s. ("akciová spoločnosť" meaning "business with shares").
• In Latvia, the most commonly used title of a corporation is "S.I.A." (Latvian: Sabiedrība ar Ierobežotu Atbildību) for "limited liability company", or "LLC", and "A/S" (Latvian: Akciju Sabiedrība) for "joint stock company", or "JSC". The title "S.I.A." and "A/S" are put before the name of the corporation.
• Albania uses "Sh.p.k" (Albanian: Shoqëri me Përgjegjësi të Kufizuar) for "limited liability company", "Sh.a." (Albanian: Shoqëri Anonime), meaning "anonymous partnership", for stock corporations. Pursuant to the Albanian legislation, the possible business structures are:

Sole proprietorship (person fizik) - A business owned and managed by one individual who is personally liable for all business debts and obligations.

Limited liability company (LLC) - A hybrid legal structure that provides the limited liability features of a corporation and the tax efficiencies and operational flexibility of a partnership.

Corporation - A legal entity owned by shareholders.

Non-profit - An organization engaged in activities of public or private interest where making a profit is not a primary mission. Some non-profits are exempt from federal taxes.

• Singapore uses Pte. Ltd., meaning "private limited", which is the equivalent of an incorporated entity in the U.S.
• In Canada, the process of incorporation can be done either at the federal or provincial level. Companies which incorporate with the federal government will generally need to register extra-provincially in the province that they elect to do business. Similarly, a provincial corporation may need to register extra-provincially if they are to have offices outside of their home province. Incorporations are effected quite quickly, depending upon the jurisdiction of registration, as several provinces and the federal government have started to allow for electronic filing. Incorporated Canadian companies can generally use either Limited, Incorporated or Corporation in their name, however this may vary province to province.
• Dubai uses "LLC" to denote a limited liability company. Listed companies use "PJSC" to denote public joint stock company.
• In Turkey Ltd. Şti. (which stands for Limited Şirketi) is a common form to denote limited liability companies.