A legal entity is an entity that has legal personality, giving it legal rights and obligations including allowing it to enter into contracts, own property, and to sue and be sued. A legal entity may be created in order to engage in business activities, charitable work, or other activities. Most often, legal entities in business are formed to sell a product or a service. There are many types of legal entities defined in the legal systems of various countries. These may include corporations, cooperatives, charities, partnerships, sole traders and limited liability companies, although not all of these may be legal entities in all jurisdictions. The specific rules vary by country and by state or province. Some of these types are listed below, by country.
There are a number of forms of legal entity in the United Kingdom, including some types of business partnership, companies incorporated under the Companies Acts, mutual societies, some types of charitable organisation, and others including chartered corporations and statutory corporations.
Partnerships (other forms of partnership exist that are not legal entities):
Companies – corporations incorporated under the Companies Act 2006 (or previous companies acts):
Private limited company (Ltd or Limited; Welsh: Cyfyngedig or Cyf)
Private company limited by shares. The liability is limited to the amount, if any, unpaid on the shares held by them. Its shares cannot be traded publicly.
Private company limited by guarantee. The liability is limited to such amount as the members undertake to contribute to the assets of the company in the event of its being wound up.
Private unlimited company (Welsh: cwmni anghyfyngedig). A company with no limit on the liability of its members.
Public limited company (PLC; Welsh: Cwmni Cyfyngedig Cyhoeddus or CCC). A limited company whose shares may be traded publicly.
Community interest company (CIC) – a company that carries out activities for the benefit of the community. These may be either a company limited by guarantee or a company limited by shares.
UK Societas (UKS) – the form taken by a UK-registered Societas Europaea (European public limited company) from 1 January 2021 following Brexit. Treated in most respects like a public limited company.
Charitable company – a type of company limited by guarantee. Charities incorporated in this form may apply for exemption from the requirement to include "Ltd" (or one of the other forms) in their company name.
Very rarely, a company limited by shares where the shareholders have no right to receive dividends may be registered as a charity; for example, St John's College, Durham, where the council members are the shareholders, and Harvard Global Research, a UK company limited by shares where the sole shareholder is Harvard Global Research and Support Services Inc., a US-based charity.
Chartered corporation – an organisation incorporated by royal charter. These are normally bodies operating in the public interest, e.g., charities or professional bodies, but also including many older universities and, historically, chartered companies.
Corporation sole – a corporation consisting of a single person, normally an incorporated official position such as the Archbishop of Canterbury or the Clerk of the House of Commons. A corporation made up of more than one person (i.e., all other corporations) is a corporation aggregate.
Ecclesiastical corporation – a Church of England corporation (aggregate or sole) established for spiritual purposes. All other corporations are lay corporations.
Eleemosynary corporation – a lay corporation established by a financial endowment "for the perpetual distribution of the free alms or bounty of the founder". All other lay corporations, including other charities, are civil corporations.
Australia
Australian companies are generally either proprietary or public. Under the Corporations Act 2001, proprietary companies commonly use the suffix Pty Ltd.
LLP (Limited liability partnership): partnerships are governed on a state-by-state basis in Australia. In Queensland, a limited liability partnership is composed of at least one general partner and one limited partner. It is thus similar to what is called a limited partnership in many countries.
ILP (Incorporated limited partnership): used for venture capital investments comes in four types: Venture Capital Limited Partnership (VCLP), Early-stage Venture Capital Limited Partnership (ESCVLP), Australian Venture Capital Fund of Funds (AFOF), Venture Capital Management Partnership (VCMP).
Inc. (Incorporated): restricted to non-profit associations
Ltd. (Limited): ≈ plc (UK). The suffix Ltd. may also be used by a private company limited by guarantee, such as a charity or university (these may obtain dispensation from the Registrar of Companies to operate without the suffix).
NL (No liability): A type of mining, speculative, or research company with no right to call up the unpaid issue price of shares.
Pty. Ltd. (Proprietary Limited Company): ≈ Ltd. (UK) ATF Trust. In Australia companies can act as a trustee for a trust.
Pty. (Unlimited Proprietary) company with a share capital: A company, similar to its limited company (Ltd., or Pty. Ltd.) counterpart, but where the liability of the members or shareholders is not limited.
Companies in Canada can be incorporated at the federal or provincial level under the Canada Business Corporations Act or equivalent provincial statutes.
The word or expression "Limited", Limitée, "Incorporated", Incorporée, "Corporation" or Société par actions de régime fédéral or the corresponding abbreviation "Ltd.", Ltée, "Inc.", "Corp." or S.A.R.F. forms part of the name of every entity incorporated under the Canada Business Corporations Act (R.S., 1985, c. C-44). ≈ Ltd. or Plc (UK)
As an exception, entities registered prior to 1985 may continue to be designated Société commerciale canadienne or by the abbreviation S.C.C.
Under the Canada Cooperatives Act (1998, c. 1), a co-operative must have the word "cooperative", "co-operative", "coop", "co-op", coopérative, "united" or "pool", or another grammatical form of any of those words, as part of its name.
Unlike in many other Western countries, Canadian businesses generally only have one form of incorporation available. Unlimited liability corporations can be formed in Alberta "AULC", British Columbia "BCULC" and Nova Scotia "NSULC". The aforementioned unlimited liability corporations are generally not used as operating business structures, but are instead used to create favorable tax positions for either Americans investing in Canada or vice versa. For U.S. tax purposes the ULC is classified as a disregarded entity.
Rather, Canadian businesses are generally formed under one of the following structures:
SP (Sole Proprietorship): No formal business structure is established
GP (General Partnership): Either a formal structure with a partnership agreement, or an informal structure, in which case the Partnerships Act for the province will apply
LP (Limited Partnership): An investment structure, limiting both the liability and the participation of the investor. An investor who takes an active role will be deemed a general partner, and become exposed to unlimited liability.
Corporation
Joint Venture: A business activity shared by two or more business entities. The joint venture's activities must be finite in terms of either time or scope.
Hong Kong
Ltd (Limited/有限公司): may denote either a private or public company limited by shares, or a company limited by guarantee. Under the Companies Ordinance, the name of a Hong Kong incorporated company may be registered in English, Chinese, or both.
Unltd or Ultd (Unlimited/無限公司): similar to a limited liability company (Ltd) but whose members or shareholders do not benefit from limited liability should the company ever go into formal liquidation. It is not a requirement under company law to add or state the word or designation Unlimited (無限公司) or its abbreviations (Unltd or Ultd) at the ending of its legal company name, and most unlimited companies do not.
In India, the Companies Act 2013 provides for public and private companies and introduced the one person company as a single-member private company; naming conventions include "Limited" for public companies and "Private Limited".
Sole proprietorship – a sole proprietorship firm is the simplest form of business entity in India. It is owned and managed by a single person. It is usually considered to be the easiest way of registering and starting a business. It is not governed by any law and hence it is the easiest form of business in India. All the decisions and management of the business are in the hands of one person. Documents required for the registration of a sole proprietorship in India are Aadhar card, PAN card, bank account and a proof of registered office.
Hindu Undivided Family (HUF) - a type entity consisting of members of a joint Hindu family. HUF represent a joint family that is held togrther by strong ties of kinship and estails a variety of joint property relations among the members. The Karta is the head of the family business, who generally is the eldest person in the house. HUF exists both as a family and as a firm.
Partnership – liability is joint and unlimited. Registration is not compulsory and can be done through the registrar of firms. Active partners take part in day-to-day operations of the business, in addition to investing in it. Active partners are entitled to a share of the enterprise's profits. Sleeping partners invest in the business and are entitled to a share of its profits but do not participate in day-to-day operations.
Limited liability partnership – liability is limited and similar to a partnership except that registration is mandatory and liability is limited. At least two partners are 'designated partners' (equivalent to directors in a company), who manage day-to-day working. Regulated by the union government.
Private limited company – a company with 2–200 shareholders; shares are held privately and cannot be offered to the public. Have limited liability and registration is mandatory. Regulated by the union government.
Public limited companies – a company with more than 200 shareholders. Can be listed or unlisted in the share market.
One-person company – a type of private company which can have only one director and member.
Unlimited company – a company, similar to a limited company (Ltd, or Pvt Ltd) but where the liability of the members or shareholders is not limited.
Public sector undertaking (PSU) – alternatively known as public sector enterprise (PSE). It may be a public limited company listed on stock exchanges with a major ownership by a state government, central government, or local government, or it may be an unlisted entity with a major ownership by a state government, central Government, or local government. Some of these entities are formed as business entities through special legislation, where these entities are governed by the statutes of this legislation and may or may not be governed by company laws like a typical business entity.
NGO – A non-governmental organization (NGO), section 8 company, or a non-profit company is a citizen-led organization that functions separately from the government, usually to advance some social cause.
In New Zealand, under the Companies Act 1993, the registered name of a limited liability company must end with "Limited" or "Tāpui".
Ltd (Limited): ≈ plc or Ltd. (UK). Names of limited liability companies that were registered under the Companies Act 1993 (but not those that were registered under the Companies Act 1955) must end with the word "Limited", the words "Tāpui (Limited)", or the suffix "Ltd".
Such companies can also be registered as a co-operative under the Co-operative Companies Act 1996 provided that they conduct "co-operative activities." These co-operatives are still obligated to issue stock, which may be publicly traded (an example of such publicly traded co-operative is the nation's largest company, Fonterra)
Nigeria's Companies and Allied Matters Act 2020 recognizes private and public companies limited by shares, companies limited by guarantee, and unlimited companies it also enables single-member companies.
Limited by Guarantee (Ltd./Gte.): a company limited by guarantee (non-profit company)
Unlimited (ULtd.): A company with a share capital, similar to its limited company (Ltd., or PLC.) counterparts, but where the liability of the members or shareholders is not limited
Limited Liability Partnership (LLP): Only allowed in the state of Lagos, Nigeria.
Partnership: Arrangement in which parties agree to cooperate to advance their mutual interests.
Pakistan
Forms of business include:
Sole Proprietorship
Partnership
Registered Firms
Unregistered Firms
Company
Company limited by shares
Public Limited Companies
Private Limited Companies
Company limited by guarantee
Unlimited company
Singapore
Private Limited Company, Sole Proprietorship and Partnership are the predominant types of business found in Singapore.
In the United States, most legal entities are incorporated under the law of a particular state. The federal government does not generally incorporate entities (and when it does this is normally referred to as "chartering" them), with a few narrow exceptions, either government-sponsored corporations or government-owned corporations.
Laws on what is considered a legal entity differ between states. In particular, older versions of the Uniform Partnership Act, which remain in force in some states, do not consider general partnerships to be legal entities distinct from their partners while newer versions (referred to as the Revised Unified Partnership Act; RUPA) that have been adopted in other states do consider partnerships to be legal entities. However, even when partnerships are considered legal entities with the right to own property and to be sued under RUPA, they continue to be treated as aggregates of their partners for tax and liability purposes.
A company is not necessarily incorporated as a legal entity. For example, a company may be a "corporation, partnership, association, joint-stock company, trust, fund, or organized group of persons, whether incorporated or not, and (in an official capacity) any receiver, trustee in bankruptcy, or similar official, or liquidating agent, for any of the foregoing".[pageneeded]
Tax classifications
Those entities existing on the state level have two separate identities: their legal entity type, e.g., partnership, corporation, or LLC, and their tax classification, what they are regarded as for federal income tax purposes. A further way to classify an entity is whether it is a for-profit or nonprofit enterprise, each classification with its own taxonomy and implications on federal income tax law. For-profit entities exist for the purpose of producing a profit for their owners whereas nonprofits exist for any purpose other than profit.
For federal tax purposes, the Internal Revenue Service has separate entity classification rules, generally depending on whether an entity is a for-profit or non-profit organization. For-profit entities can be collectively regarded as "taxable organizations" while nonprofit entities are collectively regarded as "tax-exempt organizations" or simply "exempt organizations."
Taxable organizations
Under the Internal Revenue Code, a for-profit entity may be classified as a corporation, a partnership, a cooperative or a disregarded entity. A corporation is taxed as a C corporation unless it elects and meets the requirements to be taxed as an S Corporation. A disregarded entity has one owner (or a married couple as owner) that is not recognized for tax purposes as an entity separate from its owner, so the owner is taxed on the individual level. Types of disregarded entities include single-member LLCs; qualified sub-chapter S subsidiaries and qualified real estate investment trust subsidiaries. A disregarded entity's transparent tax status does not affect its status under state law. For example, for federal tax purposes, a sole-member LLC (SMLLC) is disregarded, so that all its assets and liabilities are treated as owned by its single member. But under state law, an SMLLC can contract in its own name and its owner is generally not personally liable for the debts and obligations of the entity. To be recognized as a cooperative for tax purposes cooperatives must follow certain rules under subchapter T of the Internal Revenue Code.
Tax exempt organizations
Nonprofit organizations on the state level are exempt from federal income taxation for most types of income. There are two main types of tax exempt organizations under the Internal Revenue Code: 501(c) organizations and 527 organizations. Tax exemption has two components: exemption from income taxation and the allowance of a deduction on the tax returns of donors.
Section 501(c) encompasses most types of nonprofit entities other than ones engaged substantially in political activity. There are 29 subtypes of 501(c) organizations. For example, section 501(c)(10) includes "domestic fraternal societies, orders, or associations, operating under the lodge system," while section 501(c)(6) includes "business leagues, chambers of commerce, real-estate boards, boards of trade, or professional football leagues" under certain circumstances. The most prevalent type of 501(c)s are 501(c)(3) organizations, known broadly as "charitable organizations," those whose purpose is charitable (i.e., relief from poverty), educational, scientific, religious, or advocatory, among others, as long as such organization does not engage in substantial political activity or inure the benefit of net earnings to shareholders or other individuals. This is the preferred tax status because it is the only 501(c) that obtains both income tax exemption and tax deductible donations. All other 501(c) types only obtain tax exemption. Section 501(c)(3)s can be further divided into private foundations, public charities, and private operating foundations with private foundations given the least favorable deductibility rate. State-level unincorporated nonprofit associations, charitable trusts, and nonprofit corporations may fall into any one of the 501(c) categories depending on their purpose and the activities they engage in.
Section 527 organizations, also called "political organizations," are any nonprofit substantially engaged in "political activity," such as election campaigning or lobbying. These are organizations like political parties and election campaign committees, which are often called political action committees (PACs) or super-PACs. These organizations are subject to more stringent regulations than 501(c) organizations and only receive tax exemption; donations to 527s are not deductible. Any type of nonprofit entity existing on the state level will be regarded as a 527 if it substantially engages in political activity.
Federally chartered
Of the few types of companies that may exist under a federally issued charter, the bulk are banks, credit unions, and similar depository institutions. Such institutions are distinguished from state-chartered banks by including a key word in their formal names. For a bank, the key word is "national". A bank chartered by the Office of the Comptroller of the Currency (OCC) must have the word "national" in its name. A bank chartered by a state cannot have "national" in its name.[citation needed]
For a savings bank (formerly called a savings and loan association) or credit union, the key word is "federal", and the same rules apply; a federally chartered savings bank or credit union must have the word "federal" in its name, while a state chartered savings bank or credit union cannot have "federal" in its name.[citation needed]
Federal Savings Bank (FSB): formerly called federal savings and loan association
National Association (NA): a designation used by banks chartered by the Office of the Comptroller of the Currency (OCC)
Many federal governmental units are specially formed public corporations (which, for tax purposes are also generally 501(c)(1) organizations) and government-sponsored enterprises, while some private organizations have received a Congressional charter.[citation needed]
Limited partnership (L.P. or LP): a partnership where at least one partner (the general partner, which may itself be an entity or an individual) has unlimited liability for the LP's debts and one or more partners (the limited partners) have limited liability (which means that they are not responsible for the LP's debts beyond the amount they agreed to invest). Limited partners generally do not participate in the management of the entity or its business.
Limited liability partnership (L.L.P. or LLP): a partnership where a partner's liability for the debts of the partnership is limited except in the case of liability for acts of professional negligence or malpractice. In some states, LLPs may only be formed for purposes of practicing a licensed profession, typically attorneys, accountants and architects. This is often the only form of limited partnership allowed for law firms (as opposed to general partnerships).
Limited liability company (L.L.C., LLC, L.C., LC, Ltd., or Co.): a form of business whose owners enjoy limited liability, but which is not a corporation. Allowable abbreviations vary by state. Note that in some states Ltd. by itself is not a valid abbreviation for an LLC, because in some states (e.g., Texas), it may denote a corporation instead. See also Series LLC. For U.S. federal tax purposes, in general, an LLC with two or more members is treated as a partnership, and an LLC with one member is treated as a sole proprietorship.
Professional limited liability company (P.L.L.C. or PLLC): some states do not allow certain professionals to form an LLC that would limit the liability that results from the services professionals provide such as doctors, medical care; lawyers, legal advice; and accountants, accounting services; architects, architectural services; when the company formed offers the services of the professionals. Instead those states allow a PLLC or in the LLC statutes, the liability limitation only applies to the business side, such as creditors of the company, as opposed to the client/customer service side, the level of medical care, legal services, or accounting provided to clients. This is meant to maintain the higher ethical standards that these professionals have committed themselves to by becoming licensed in their profession and to prevent them from being immune (or at least limit their immunity) to malpractice suits.
Low-profit limited liability company (L3C): a hybrid for-profit and nonprofit entity available in some states. It is an LLC that is allowed to have a primary nonprofit purpose, and a secondary for-profit purpose.
Corporations
For-profit corporations
Corporation (Corp., Inc., or Ltd.): a legal entity that is owned by shareholders and managed by directors and officers, all of which enjoy limited liability. A corporation can be a public or private company. In some states other suffixes may be used to identify a corporation, such as Ltd., Co./Company, or the Italian term S.p.A. (in Connecticut; see under Italy). Some states that allow the use of "Company" prohibit the use of "and Company", "and Co.", "& Company" or "& Co.". In most states sole proprietorships and partnerships may register a fictitious "doing business as" name with the word "Company" in it. For a full list of allowed designations by state, see the table below.
Benefit corporation (PBC): a for-profit corporation that includes positive impact on society, workers, the community, and the environment in addition to profit as its legally defined goals, in that the definition of "best interest of the corporation" is specified to include those impacts. Some states require the corporation to have "Public Benefit Corporation" or "PBC" in its name (or a similar designation), while others allow any prefix allowed by a corporation (such as Corp. or Inc.), but require that shareholders, investors, and other parties be informed that the company is a public benefit corporation.
Professional corporation (PC or P.C.): those corporate entities for which many corporation statutes make special provision, regulating the use of the corporate form by licensed professionals such as attorneys, architects, accountants, and doctors.
Nonprofit corporations
Nonprofit corporation: a corporation whose primary purpose is to serve a social goal instead of producing a profit for shareholders. As such, nonprofit corporations do not have shareholders but may still have directors and officers which still enjoy limited liability. The naming conventions for nonprofit corporations vary, with naming requirements similar to those of other corporate entities, with some states forbidding names that might mislead the public. Nonprofit corporations are generally divided into three subcategories:
Religious corporation: a nonprofit corporation formed for the purpose of practicing or proselytizing a religion, such as an organized congregation or missionary organization.
Cooperatives
Cooperative (Co-Op, Coop, or CP): a for-profit entity owned and democratically operated by a group of people who share a common economic goal, such as worker cooperatives, agricultural cooperatives, or a utility cooperatives. In most states, a cooperative must have a signifier in its name indicating that it is a cooperative, such as coop, co-op, CP, or cooperative.
Limited cooperative association (LCA): a for-profit entity owned and democratically operated by a group of people who share a common economic goal but which is chartered to allow for outside investment by non-owner members.
Asia
Azerbaijan
Companies in Azerbaijan are registered and operate in accordance with the Civil Code of the Republic of Azerbaijan and the Law "On State Registration and the State Register of Legal Entities." The registration process is supervised by the Ministry of Economy through the State Tax Service. Both local and foreign individuals or legal entities can establish companies in Azerbaijan, including limited liability companies (LLC), joint-stock companies (JSC), and representative or branch offices.
Brunei
There are three main types of business entity in Brunei, namely sole proprietorship, partnership, and company.
A private company contains the term "Sendirian Berhad", meaning "Private Limited" or "Sdn. Bhd." as part of its name; for a public company "Berhad" or "Bhd." is used.
Cambodia
SP (Sole Proprietorship)
GP (General Partnership)
LP (Limited Partnership)
SM Pte Ltd. (Single Member Private Limited Company):
Other than companies, ordinary firms include other two types: (See also Partnership (China))
Sole trader 个人独资企业
Partnership 合伙制企业
Indonesia
Most of the legal entity types are regulated in a modified version of the original version of the Dutch Burgerlijk Wetboek. Business entities (badan usaha) in Indonesia can be grouped into legal entities (Badan hukum) and non-legal entities (Non Badan Hukum), the latter which are not legal person thus cannot sue or be sued.
Legal Entities (Badan Hukum)
Yayasan: ≈ stichting (Netherlands), foundation; common type for non-profit NGOs.
Note: Sometimes this kind of legal entity is called a perusahaan dagang or abbreviated as PD, which sometimes makes confusion with the former name for municipally owned statutory corporations, Perusahaan Daerah, also abbreviated as PD (today they are called Perusahaan Umum Daerah and abbreviated as Perumda).
Firma (vof, Fa): ≈ general partnership, (Dutch: vennootschap onder firma, known locally as just firma)
Persekutuan Komanditer (CV or Commanditaire Vennootschap): ≈ limited partnership (US), kommanditgesellschaft (Germany); a more common type for small businesses.
Persekutuan Perdata (Mts.) (Dutch: maatschap): group practice (of professionals, e.g. doctors, accountants, lawyers); share facilities not profits, members are treated as natural persons for tax and liability purposes.
Persekutuan Perdata Umum (Dutch: algehele maatschap): for general purpose
Persekutuan Perdata Khusus (Dutch: bijzondere maatschap): specific purpose
Persekutuan Keuntungan (Dutch: algehele maatschap van winst): profit-sharing variant
Badan Layanan Umum (BLU): for state-owned non-profit services like universities, hospitals, or other government agency
Badan Layanan Umum Daerah (BLUD): local government owned BLU
Iran
شرکت سهامی عام (Sherkat Sahami Am): ≈ plc (UK), public
شرکت سهامی خاص (Sherkat Sahami Khas): ≈ plc (UK), private
شرکت با مسئولیت محدود (Sherkat ba Masouliyat Mahdoud): ≈ Ltd. (UK)
شرکت مختلط غیر سهامی (Sherkat Mokhtalet Gheyr Sahami): ≈ limited partnership
شرکت مختلط سهامی (Sherkat Mokhtalet Sahami): mixed joint-stock partnership
شرکت نسبی (Sherkat Nesbi): proportional liability partnership
شرکت تعاونی تولید و مصرف (Sherkat Ta'avoni Tolid va Masraf): production and consumption cooperative
Israel
Company (khevra, חברה) – for-profit entity which may engage in any lawful activity. Most companies limit the liability of their shareholders. In that case, the phrase "Limited" or the abbreviation "Ltd." must appear as part of the full name of the company. The term "B.M."/"BM" (בע"מ), literally: by limited liability/warranty, is usually translated as "Ltd." in English and pronounced "ba'AM" in Hebrew. Companies are governed by the Companies Act, 5759-1999 (חוק החברות, תשנ"ט-1999). Few sections are still in force from the Companies Ordinance [New Form], 5743-1983 (פקודת החברות [נוסח חדש], תשמ"ג-1983).
Private company – any company which is not a public company.
Public company – any company whose shares are listed on an exchange or have been offered to the public, and are held by the public.
Charity company (khevra le'to'ellet ha'tzibur, חברה לתועלת הציבור) – company generally governed by the Companies Act, except it is a nonprofit. A charity company must have pre-defined goals, rather than engage in any lawful activity. Some provisions in the Companies Act apply specifically to charity companies. The letters "CC" (חל"צ) must be appended to such company's name.
Partnership (shutafut, שותפות) – created by default, even without registration, when two or more persons run a business together for profit. Personal liability of partners is not limited, unless they are limited partners of a limited partnership. Partnerships are governed by the Partnerships Ordinance [New Form], 5735-1975 (פקודת השותפויות [נוסח חדש], תשל"ה-1975).
Cooperative (aguda shitufit, אגודה שיתופית) – entity which may pursue profit, but with certain legal properties meant to facilitate greater participation by each shareholder, or member, in the entity's affairs. Shareholders usually have an additional relationship with the cooperative, such as employees or consumers. This type of entity is found mainly in agriculture (a kibbutz or moshav is often a cooperative), transportation, or certain types of marketing operations associated with agricultural products. Cooperatives are governed by the Cooperatives Ordinance (פקודת האגודות השיתופיות).
Voluntary association (amuta, עמותה) – nonprofit entity, which must have its goals defined in its founding agreement. Includes, among others, academic institutions, hospitals and various charitable organizations. Voluntary associations are governed by the Voluntary Associations Act, 5740-1980 (חוק העמותות, תש"מ-1980).
Japan
Japanese company law recognizes several types of companies, with the most common being the Kabushiki Kaisha, similar to a joint-stock company. Another popular form is the Gōdō Kaisha, which resembles a limited liability company. The Companies Act of 2005 established the legal framework for these and other business entities in Japan, regulating their formation, governance, and operation.
Business corporations are referred to as kaisha (会社) and are formed under the Companies Act of 2005. There are currently (2015) 4 types and each of them has legal personality:
株式会社 (kabushiki gaisha or kabushiki kaisha, "K.K." (usually translated in company names as "Company, Limited"/"Co., Ltd.")) – lit. "stock company", the most typical form of business corporation.
合同会社 (gōdō gaisha or gōdō kaisha, "G.K.") – lit. "amalgamated company", a close corporation form similar to the American LLC, introduced in 2006
有限会社 (yūgen gaisha or yūgen kaisha, "Y.K.") – lit. "limited company", a close corporation form for smaller businesses, abolished in 2006 and replaced by G.K. above
合名会社 (gōmei gaisha or gōmei kaisha, "GMK") – corporation similar to a general partnership
合資会社 (gōshi gaisha or gōshi kaisha, "GSK") – corporation similar to a limited partnership
Partnerships are referred to as kumiai (組合). Each of these 4 types has no legal personality though other corporations, which include "kumiai" in their name, have:
任意組合 (nin'i kumiai, "NK") – general partnership (Civil Code)
匿名組合 (tokumei kumiai, "TK") – anonymous partnership, an investment bilateral contract (Commercial Code, Book 2 Ch.4 Article 535 et seq)
投資事業有限責任組合 (tōshi jigyō yūgen sekinin kumiai) – limited partnership for investment (Limited Partnership for Investment Act 1998, Rev.2004)
有限責任事業組合 (yūgen sekinin jigyō kumiai) – similar to a Limited Liability Partnership (Limited Liability Partnership Act of 2005)
Company: In the Korean Commercial Act, a company is a corporation established for commercial activities or other for-profit purposes. A company comes into existence by registering its incorporation at the location of its head office.
Cooperative: In Korean Framework Act On Cooperatives, a cooperative is a business organization that seeks to improve the rights and interests of its members and contribute to the local community by engaging in cooperative purchasing, production, sales, and provision of goods or services. Cooperatives cannot engage in finance or insurance business.
협동조합;協同組合;hyeopdongjohap
협동조합연합회;協同組合聯合會;hyeopdongjohabyeonhapoe: It is a federation established to promote the common interests of cooperatives.
Taiwan (Republic of China)
無限公司 (Unlimited Company)
有限公司 (Limited Company, yǒuxiàn gōngsī)
兩合公司 (Limited Partnership)
股份有限公司 (Public Limited Company or Corporation, gǔfèn yǒuxiàn gōngsī)
Thailand
บริษัทมหาชนจำกัด, name format บริษัท corporation name จำกัด (มหาชน): plc (UK). Minimum 15 shareholders.
บริษัทเอกชนจำกัด (name format บริษัท corporation name จำกัด): Ltd. (UK). At least 2 shareholders.
ห้างหุ้นส่วนจำกัด (name format ห้างหุ้นส่วนจำกัด corporation name): limited partnership There are two kinds of partnership: Limited partnership which has limited liability of the partnership, and unlimited partner which has unlimited liability to the third party for the partner. The unlimited partnership has the right to control the partnership. On the other hand, the limited partnership has no right to make decision in the partnership.
ห้างหุ้นส่วนสามัญนิติบุคคล (name format ห้างหุ้นส่วน corporation name): general partnership
Vietnam
Cty TNHH (Công ty trách nhiệm hữu hạn / "Company with Limited Liability"): Limited Liability Company
Cty TNHH MTV (Công ty trách nhiệm hữu hạn một thành viên/ "Limited Liability Company with a Single member") since 2005
Cty CP (Công ty cổ phần / "Company with Joint Stock"): Joint Stock Company
Công ty hợp danh / "Company of Partners": Partnership
Doanh nghiệp hợp danh / "Enterprise Partnership": Partnership
DNNN (Doanh nghiệp nhà nước / "Enterprise of the State"): State-Owned Enterprise
DNTN (Doanh nghiệp tư nhân / "Enterprise Private"): Proprietorship
DTNN (Doanh nghiệp có vốn đầu tư nước ngoài "Enterprise with Foreign Investment"): Foreign Investment Enterprise
HTX (Hợp tác xã/ Co-operation)
Chi nhánh: Branch Company
Nhóm Cty (Công Ty / "Group Company"): Holding Company
EP (Empresa Pública): Legal entity owned by the Government.
Africa
Egypt
The principal forms for private investment include the joint-stock company and the limited liability company, regulated by Law No.159 of 1981 and related investment legislation.
SAE (Sharikat al-Mossahamah) ≈ plc (UK). Minimum capital E£250,000.
LLC (Limited Liability Company) ≈ Ltd. (UK). No Minimum capital .
PLC (Private limited company Amharic ሃላፊነቱ የተወሰነ የግል ማህበር)
SC (Share company Amharic አክሲዩን ማህበር)
CS (Cooperative societies Amharic ህብረት ስራ ማህበራት)
PE or PC (public enterprises or public corporations Amharic የመንግስት ልማት ድርጅቶች or ኮርፖሬሽን)
Ghana
Sole Proprietorship
Private Limited By Share
Private Unlimited By Share
Private Limited By Guarantee
Public Unlimited Company
External Company
Public Limited Company
Public Limited By Guarantee
Partnership
Subsidiary Business Name
Kenya
Kenya's Companies Act 2015 provides for private and public companies, including public limited companies. It sets naming and formation rules and consolidates modern company law in Kenya.
South Africa
Under the Companies Act 2008, South Africa provides for non-profit companies and several profit-company forms: private companies, public companies, personal liability companies, and state-owned companies.
Private company: ≈ private limited company (UK), limited liability company (US); has 1 or more shareholders, one or more directors. The name must end "(Pty) Ltd"; registration number ends /07. Registration number and directors' names must appear on all correspondence.
Section 53(b) company (unlimited liability company): ≈ professional limited liability company (PLLC) (US)
Public company (Ltd.): ≈ public limited company (UK), corporation (US); has at least 7 shareholders (unless it is a wholly owned subsidiary of another company) and at least two directors. The company's name must end in "LTD"; its registration number ends in /06.
CC (Close corporation): Has 1–10 non-corporate members. The name must end with "CC"; registration number ends /23. Registration number and members' names must appear on all correspondence. On 1 May 2011 the new Companies Act (Act 71 of 2008) came into force and disallows any new incorporations under this form.
Europe
European Union and European Economic Area
Directive 2017/1132 consolidates EU company-law measures on incorporation, capital, disclosure and cross-border aspects for limited-liability companies the EU also recognizes the Societas Europaea.
Decentralised EU/Euratom bodies established through secondary legislation
Foreign and domestic investors have a range of options to establish and organize their business in Albania. They can either create and register a business organization or establish and register a branch or representative office.
Previously, foreign entity registration was handled through the National Registration Center, which had implemented a streamlined "one-stop-shop" system since September 1, 2007. However, on November 26, 2015, the enactment of Law No. 131/2015 led to the formation of the National Business Center (QKB) which aimed to simplify business procedures by centralizing registration and licensing in a single institution. Consequently, the National Registration Center and the National Licensing Center were abolished.
Sh.p.k. (Shoqëri me përgjegjësi të kufizuar); a business entity established by one or several natural or legal persons;
Sh.A. (Shoqëri Aksionere); a company whose capital is divided into shares signed by its founders;
Sh.K. (Shoqëri komandite); the liability of at least one partner is limited to the value of their contribution;
Shoqëri kolektive; the liability of the company's partners before its creditors is unlimited;
Degë; entities created by a parent company that carry the same legal presence as the company;
Zyrë e përfaqësimit; business offices where a company's activities can operate from that are not intended to generate revenue.
Austria
Gen (Genossenschaft; types: Erwerbs- und Wirtschaftsgenossenschaft): ≈ cooperative
stG (stille Gesellschaft): ≈ partnership by estoppel (i.e., no partnership agreement)
GesbR (Gesellschaft des bürgerlichen Rechts): ≈ partnership by contract (i.e., formed by partnership agreement); statutes and regulations concerning Austrian companies, especially with regards to the companies register (Firmenbuch), do not apply.
coöperatieve vennootschap met onbeperkte aansprakelijkheid (CVOA)
société coopérative à responsabilité illimitée (SCRI)
Unlimited liability cooperative
Following changes to the Code of Companies and Associations, the term "Private limited liability company" (BVBA/SPRL) automatically became "Private limited company" (BV/SRL), as a part of harmonising legal entity types within the European Union.
Bosnia and Herzegovina
d.d. (dioničko društvo): ≈ plc (UK) ≈ AG (Germany)
a.d. (akcionarsko društvo): ≈ plc (UK) ≈ AG (Germany)
d.n.o. (društvo s neograničenom solidarnom odgovornošću): ≈ general partnership
Bulgarian commercial law recognizes several forms of merchants and commercial companies, including sole traders, general partnerships, limited partnerships, limited liability companies, joint-stock companies, and partnerships limited by shares.
d.d. (dioničko društvo): ≈ plc (UK) ≈ AG (Germany)
d.o.o. (društvo s ograničenom odgovornošću) is company with limited liability: ≈ Ltd. (UK) or LLC (US); minimum capital: kn20,000
j.d.o.o. (jednostavno društvo s ograničenom odgovornošću): simple Ltd.; minimum capital: kn10 (same liabilities as an Ltd., but has to set aside 25% of annual profit to collect enough equity capital to become a d.o.o.)
obrt: ≈ sole proprietorship; several types: slobodni obrt (free proprietorship), vezani obrt (tied proprietorship), and povlašteni obrt (privileged proprietorship) registered according to profession where tied and privileged types are reserved only for master craftsmen): paušalni obrt (flat-rate proprietorship), obrt-dohodaš (income tax proprietorship), obrt-dobitaš (profits tax proprietorship); these are registered according to the type of taxation; first two are obligated to pay income tax and the last one is obligated to pay profits tax), sezonski obrt (seasonal proprietorship) that runs for a limited number of months during a year.
ortakluk: partnership of two or more sole proprietors
slobodna djelatnost: free profession; self-employment but only for certain types of professions: e.g. artists, journalists, lawyers, etc.; freelancing (similar to sole proprietors in their obligations)
domaća radinost and sporedno zanimanje: home business and side profession; limited forms of self-employment aimed at registering supplementary income from, say, small repairs or hobbies with yearly income limited to 10 average gross salaries (approx. EUR 11,700 in January 2020)
OPG (obiteljsko poljoprivredno gospodarstvo): family run agricultural business
Non-profit:
udruga ≈ voluntary association; any form of free and voluntary association of natural or legal persons to accomplish a purpose without intent to acquire profit.
Cyprus
Ιδιωτική Εταιρεία - LTD
Δημόσια Εταιρεία - PLC
Συνεργατικά Πιστωτικά Ιδρύματα - COOP
Αυτοτελώς εργαζόμενος - SP
Σωματεία και Ιδρυμάτα - SF
Οντότητες που διέπονται από το δημόσιο δίκαιο - PUBLaw
IVS (Iværksætterselskab): private limited company startup with limited equity capital. Must use 25% of profit to collect enough equity capital to become an ApS.
valtion liikelaitos (Swedish: statens affärsverk): commercial government agency, expected to fund themselves, but debts directly backed by state funds—distinguished from regular companies where the government owns stock. (See: List of Finnish government enterprises)
kunnallinen liikelaitos (Swedish: kommunal affärsverk): municipal enterprise, similar as previous but run by a municipality
paliskunta: a reindeer herding corporation, governed like a stock company except that the "stocks" are reindeer
Economic entities for special purpose
asunto-osakeyhtiö (Swedish: bostadsaktiebolag), a limited liability company for the ownership, construction and maintenance of an apartment building
julkinen keskinäinen vakuutusyhtiö, abbreviated jy (Swedish: publikt ömsesidigt försäkringsbolag), public mutual insurance company
keskinäinen kiinteistöosakeyhtiö (Swedish: ömsesidiga fastighetsaktiebolag, a limited liability company for the ownership, maintenance and construction of real property.
keskinäinen vakuutusyhtiö (Swedish: ömsesidigt försäkringsbolag), mutual insurance company
laivaisännistöyhtiö (Swedish: partrederi), a type of general partnership for the owning of a merchantman
In the corporations of real estate law, the ownership or membership may be vested either in the real property or in a legal or natural person, depending on the corporation type. In many cases, the membership or ownership of such corporation is obligatory for a person or property that fulfils the legal requirements for membership or wishes to engage in certain activities.
keskivedenkorkeuden muuttamista varten perustettu yhteisö (Swedish: Sammanslutning som bildas för höjning av medelvattenståndet), a corporation of water law for the permanent change of the median water level
ojitusyhteisö (Swedish: dikningssammanslutning), a corporation of water law for the construction and maintenance of ditches
säännöstely-yhteisö (Swedish: regleringssammanslutning), a corporation of water law for the regulation of water level in a body of water
tiekunta (Swedish: väglag), a type of limited-liability corporation for the maintenance of private road
uittoyhteisö (Swedish: flottningssammanslutning), a corporation of water law for timber-floating
vesioikeudellinen yhteisö (Swedish: vattenrättslig sammanslutning), a corporation of water law for a project that involves economic use of bodies of water
yhteisalue (Swedish: samfälliga område), a corporation for the maintenance of a real property jointly used by several other properties or persons
yhteismetsä (Swedish: samfälld skog), a jointly owned forest
osakaskunta (historically "jakokunta"), a partition unit, i.e. a corporation for maintenance of the commons.
France
France's widely used forms include the "société par actions simplifiée", "société à responsabilité limitée" and "société anonyme" government guidance sets out their main features and minimum capital and confirms SAS as the most common commercial form.
Micro-entreprise: special framework for minute businesses, a recent addition to French business law -with both revenue and pre-tax net income caps, of which Auto-entrepreneur (below) is a special case
Auto-entrepreneur: ≈ self-employed (UK), independent contractor (US), a recent addition to French business law -with both a revenue cap and a specific set of derogatory income tax rates
SICAF (Société d'investissement à capital fixe): ≈ investment trust (UK); closed-end fund (CEF), closed-end company (US); listed investment company (LIC) (Au)
SICAV (Société d'investissement à capital variable): ≈ investment company with variable capital (ICVC), open-ended investment company (OEIC) (UK); mutual fund, open-end company (US)
GIE (Groupement d'intérêt économique): economic interest grouping
SAS (Société par actions simplifiée): ≈ limited liability company (US, especially in Delaware), unlisted public company (Au), close corporation (CC) (S. Africa), private corporation (Can); often used for subsidiaries; minimum of one director and two members/shareholders; no limit on share capital; liability can be restricted to director; no "one share – one vote" principle
SASU[fr] (U- unipersonnelle): limited liability, sole shareholder Ltd. company (UK) or single member close corporation
Germany
In Germany, the most common corporate forms include the Gesellschaft mit beschränkter Haftung and the Aktiengesellschaft. The GmbH is a private limited liability company, widely used for small and medium-sized enterprises. The AG is a public limited company used by larger firms and those listed on stock exchanges. German corporate law is governed by the Handelsgesetzbuch. Companies must register with the local commercial register and comply with strict disclosure and accounting standards.
individuals
Einzelunternehmen: individual entrepreneur ≈ sole trader (UK), sole proprietorship; only professional services, agriculture and forestry as well as small commercial businesses
Eingetragener Kaufmann (male/both genders)/eingetragene Kauffrau (female) (e.K./e.Kfm./e.Kfr.): registered merchant ≈ sole trader (UK), sole proprietorship (US); individual entrepreneur with commercial business (Handelsgewerbe)
partnerships (Personengesellschaften)
Gesellschaft bürgerlichen Rechts[de] (GbR), BGB-Gesellschaft: simple partnership; no minimum capital, two or more partners, unlimited liability of partners, no commercial business (Handelsgewerbe) that is not small.
nicht-eingetragener Verein: non-registered association; non-commercial/idealistic purposes only; similar to e.V. but lacking juridical personality
Offene Handelsgesellschaft (OHG): literally "open business company" ≈ general partnership: no minimum capital, unlimited liability of partners; GbR with commercial business (Handelsgewerbe)
In case the general partner is a limited company, the legal form of the general partner, followed by "& Compagnie" (shortened to & Co.), must be included in the name of the company, resulting in combined legal forms such as:
ApS & Co. KG: the general partner is a Danish Anpartsselskab
LLC & Co. KG: the general partner is a US LLC
Note that when a KG's general partner is a limited company, the resulting form is legally considered as a different subtype of KG
Partnerschaftsgesellschaft (PartG): partnership company; only for professional services
Partnerschaftsgesellschaft mit beschränkter Berufshaftung (PartGmbBH): partnership company with limited professional liability ≈ limited liability partnership (US); only for professional services
Partenreederei: combined and continued ownership of a single merchant vessel; no longer available for new businesses since 24 April 2013.
corporations (Körperschaften)
eingetragener Verein (e.V.): incorporated association; non-commercial/idealistic purposes only, commercial business cannot be the main purpose of the e.V.
altrechtlicher Verein/rechtsfähiger Verein (r.V.): association established before 1 January 1900; extremely rare
wirtschaftlicher Verein: commercial purpose, established by public grant; rare
Companies limited by shares (equity) (Kapitalgesellschaften)
Kommanditgesellschaft auf Aktien (KGaA): ≈ publicly traded partnership (US); although it is a company limited by shares, the KGaA has at least one general partner whose liability is not limited
As with the KG, the legal form of the general partner, followed by "& Compagnie" (shortened to & Co.), must be included if it is another limited company, resulting in combined legal forms such as:
GmbH & Co. KGaA: the general partner is a GmbH
AG & Co. KGaA: the general partner is an AG
SE & Co. KGaA: the general partner is a societas Europaea
Note that when a KGaA's general partner is a limited company, the resulting form is legally considered as a different subtype of KGaA
The "mit beschränkter Haftung (mbH)" suffix (German:[ˈɛmbeːˌhaː], "with limited liability") is sometimes added to the name of a firm that already ends in "-gesellschaft" ("company"), e.g., "Mustermann Dental-Handelsgesellschaft mit beschränkter Haftung" ("dental trading company with limited liability"), which would be abbreviated as "Mustermann Dental-Handelsgesellschaft mbH".
gemeinnützige GmbH[de] (gGmbH); In German tax law, the non-profit GmbH is a limited liability company whose income is used for charitable purposes.
Unternehmergesellschaft (haftungsbeschränkt) (UG (haftungsbeschränkt)): literally "entrepreneurship company (with limited liability)": identical to GmbH but with a minimum capital of €1 (times the number of shares); part of earnings needs to remain in the company to reach a minimum equity of €25,000; the word haftungsbeschränkt ("with limited liability") may not be abbreviated.
I.K.E. (Idiotiki Kefalaiouchiki Etaireía / Ιδιωτική Κεφαλαιουχική Εταιρεία) = Private Company, minimum capital=€0. The shares do not take the form just of capital but also warranties, labor offer etc. This form is a composite form between A.E. E.P.E and O.E. which is greatly affected by the Articles of Incorporation.
atomikís epicheírisis / ατομικής επιχείρησης: sole proprietorship
Companies of the type "Anónimi Etaireía" would translate this designation into the French translation société anonyme or S.A. in non-Greek languages.
Hungary
In Hungary, business entities are mainly regulated by the Companies Act of 2006, the Companies Registration Act of 2006 and the new Civil Code of 2013. All companies are required to indicate their type in their name.
The situation in Ireland is similar to the United Kingdom below, though without the class Community Interest Company. There were two forms of Company Limited by Guarantee, but only the form without a share capital is now used. Irish names may also be used, such as cpt (cuideachta phoibli theoranta) for plc, and Teo (Teoranta) for Ltd.
Limited Company – Four types:
Private company limited by shares – If company is wound up, members' liability is limited to the amount, if any, unpaid on the shares they hold. Maximum number of members in Ireland is 99.
Company limited by guarantee not having a share capital – Public company. Must have at least seven members. Members' liability limited to amount they have undertaken to contribute to company assets. If wound up, liability does not exceed amount specified in memorandum. If a guarantee company does not have a share capital, members are not required to buy shares (such as charities).
Company limited by guarantee having a share capital – As with a private company if the maximum number of members is 99. Members have liability either for the amount, if any, that is unpaid on the shares they hold, or for the amount they have undertaken to contribute to company assets, in the event that it is wound up.
A public limited company. Must have at least seven members. Liability is limited to the amount, if any, unpaid on shares they hold. Unlawful to issue any form of prospectus except in compliance with the Companies Acts 1963–2006. Nominal value of Company's allotted share capital must satisfy specified minimums which must be fully paid before company commences business or exercises any borrowing powers.
Single Member Company – Private company limited by shares or a guarantee company having a share capital, which is incorporated with one member, or whose membership is reduced to one person. Must have at least two directors and one secretary. Sole member can dispense with holding General Meetings including Annual General Meetings.
Unlimited Company – No limit on liability of members. Creditors may have recourse to shareholders for unpaid liabilities of the company. Must have at least two shareholders.
Undertakings for Collective Investment in Transferable Securities (UCITS) – Public limited companies formed under EU Regulation and the Companies Acts 1963–2006. Sole object of a UCIT is collective investment in transferable securities of capital raised from the public that operates on the principle of risk-spreading. Central Bank of Ireland must approve all registrations of UCITS.
A designated activity company (Irish: Cuideachta Ghníomhaíochta Ainmnithe) or DAC is a form of company in Ireland created by the Companies Act 2014. Like a limited company, designated activity companies have limited liability. Additionally, they may only carry out activities listed in their constitution documents, and so the concept of ultra vires continues to apply to them.
Société en Commandite Spéciale (SCSp): unlike an SCS, an SCSp does not have a legal personality separate from those of its partners; it is formed by an agreement among its partners and allows for more flexible structuring, not having to comply with corporate law requirements
SAS (Société par Actions Simplifiée): ≈ simplified joint stock company, offering flexible corporate governance and well-suited for diverse business models.
SOPARFI (Société de Participations Financières): ≈ non-regulated holding company, primarily used for holding and financing, benefitting from Luxembourg's tax treaties.
SIF (Specialized Investment Fund): ≈ regulated investment vehicle for institutional and qualified investors.
RAIF (Reserved Alternative Investment Fund): ≈ unregulated alternative fund structure requiring an authorized AIFM.
SC (Société Civile): ≈ civil company used mainly for estate planning and holding assets.
GIE (Groupement d'Intérêt Économique): ≈ economic interest grouping enabling cooperation between companies without merger.
Malta
Ltd: Limited liability company
Plc: Public limited liability company
Netherlands
All non-governmental legal entities are registered on the companies register by the chamber of commerce.
Stichting: ≈ foundation, comparable to German Stiftung. They can run a business but no profit distributions to the founders or board members are allowed.
mutual societies (associations which are allowed to pay dividends to their members; liability may be unlimited (W.A. – wettelijke aansprakelijkheid), limited (B.A. – beperkte aansprakelijkheid) or exempt (U.A. – uitsluiting van aansprakelijkheid)):
Coöperatie: ≈ co-operative society
Onderlinge waarborgmaatschappij: ≈ mutual insurance company
Vereniging ≈ association. Can run a business, but may not distribute profit among its members.
Mts (Maatschap): ≈ group practice (of professionals, e.g. doctors, accountants, lawyers); share facilities not profits, members are treated as natural persons for tax and liability purposes.
bv (besloten vennootschap): ≈ Ltd (UK), Ltd. (US). May appear in a company name as the suffix of "B.V.". A bv can be started by an individual (perhaps as the major or only shareholder) or together with partners. Shares cannot be traded publicly. Private liability as owner or director is limited, although financiers may require individual to co-sign loans and in case of mismanagement directors may be personally held accountable.
nv (naamloze vennootschap): ≈ plc (UK), Corp. (US). May appear in company name as the suffix of "N.V." Minimum issued share capital upon incorporation: €45,000. Literally translated, the title is "nameless company", as shareholders are not formally known as such in company statutes and other legal documents.
Norway
ASA (Allmennaksjeselskap): ≈ plc (UK). Minimum capital NKr1,000,000
AS (Aksjeselskap): ≈ Ltd. (UK). Minimum capital NKr30,000.
Stiftelse: a foundation, comparable to German Stiftung, with capital but without members or shareholders. It is allowed to make a profit, but is more suited for non-commercial purposes.
UB (Ungdomsbedrift): youth enterprise, only used in education
Poland
No universal definitions of company and business exist in the Polish law. The usage of the equivalent terms in the Polish legal system may often be confusing because each of them has several different definitions for various purposes.
Przedsiębiorca ('entrepreneur' or 'undertaking')—known as kupiec ('merchant') until 1964; jednostka gospodarcza ('economic unit') from 1964 to 1988; podmiot gospodarczy ('economic entity') from 1988 to 1997—is the closest equivalent of company understood as an entity. As of January 2021, there are at least thirteen different definitions of entrepreneur/undertaking.
Przedsiębiorstwo ('enterprise') is defined in the Civil Code as an organized complex of material and non-material components designated to perform economic activity. Therefore, it is equivalent to company understood as a set of assets organized to do business.
Działalność gospodarcza ('economic activity') is the closest equivalent of business. As of January 2021, there are at least six different definitions of economic activity.
Portugal
Cooperativa ≈ cooperative: The name of the entity should include the expression "Cooperativa" or "União de Cooperativas" or "Federação de Cooperativas" or "Confederação de Cooperativas"
CRL (Cooperativa de Responsabilidade Limitada): limited liability cooperative
S.A. (Sociedade Anónima): ≈ plc (UK), and these are further classified as:
O.N.G. (Organizație Non-Guvernamentală): ≈ Non-state pension fund (literally: Non-Governmental Organization) — strictly speaking, ONGs do not exist in Romanian law, they are legally called either associations or foundations. Political parties, trade unions and religious denominations/churches/temples/synagogues/mosques aren't considered ONGs. And "privately managed pension funds" (legal term) are another matter than ONGs.
In Russia, companies are governed by the Civil Code and federal laws such as the Law on Joint-Stock Companies and the Law on Limited Liability Companies. Common types of corporate entities include the Open Joint-Stock Company, the Closed Joint-Stock Company, and the Limited Liability Company.
Ltd (Russian: AO - Акционерное общество, romanized:Aktsionernoye obschestvo): private limited company (UK: Ltd), privately held shares (similar to a close corporation, or closely held corporation, in the US) (maximum fifty "owners of capital" (not shareholders); if there are more than fifty "owners of capital", they have a year to transform into a PAO)
Cooperative (Russian: Кооператив, lit.'cooperative'): these include many types, which differ by the type of activity, e.g. farming or other kind of production
S.L.N.E. (Sociedad Limitada Nueva Empresa): similar to S.L., it was introduced in 2003 to speed up new company registration (registration can be completed in one day), minimum capital €3,012
S.A.D. (Sociedad Anónima Deportiva): a limited liability sports corporation
S.L.L. (Sociedad Limitada Laboral): a labour limited corporation
S.Com p.A.P. (Sociedad Comanditaria por Acciones Profesional)
S.Coop. (Sociedad Cooperativa): a cooperative that typically is owned and democratically controlled by its workers
Other initialisations are used for cooperatives; Sociedad Anónima Laboral (SAL); some are region specific e.g. Sociedad Cooperativa Catalana Limitada (SCCL)
Kom. Şti (komandit şirket): ≈ Commandite partnership: Can be established as simple commandite partnership or as commandite company divided into shares (Sermayesi paylara bölünmüş komandit şirket.).
A.Ş. / A.O. (Anonim Şirket / Anonim Ortaklık): ≈ Joint-stock company: Minimum capital is TL 250,000. Bearer or registered shares, of a minimum par value of TL 0.01 each. Only type of company that can be publicly traded in Turkish law.
Ltd. Şti. / L.Ş. / L.O. (Limited şirket / Limited ortaklık) ≈ Limited company: Minimum capital is TL 50,000. Registered shares only, of a minimum par value of TRY 25 each.
According to the Capital Markets Act (Act No: 6362):
HAAO (Halka Açık Anonim Ortaklık) ≈ Publicly held corporation: This essentially is a special type of A.O. These types of companies can only be established as A.O.'s. When there are no specific rules under Capital Markets legislation, A.O. rules under Turkish Commercial Code will be applied to HAAO's.
Company formation is regulated by the Ukrainian Civil Code and Commercial Code, Law On Business Associations, Law On Joint Stock Companies, Law On Limited Liability Companies and Additional Liability Companies.
Mexico
Mexico's General Law of Commercial Companies recognizes, among other forms, the Sociedad Anónima and the Sociedad por Acciones Simplificada, the latter added by 2016 reforms to facilitate single-shareholder startups.
Business entities according to the "Ley General de Sociedades Mercantiles" (General Law of Commercial Companies)
Note: Any of these entities can be incorporated as a "Capital Variable" entity, in which case has to add the "de C.V." sufix to its company name. Example: "S.A. de C.V.", "S. de R.L. de C.V."
Business entities according to the "Ley del Mercado de Valores" (Stock Market Law)
S.A.B. (Sociedad Anónima Bursátil)
S.A.P.I. (Sociedad Anónima Promotora de Inversión)
Oman
SAOG (Société Anonyme Omanaise Générale) Public Joint Stock Company
SAOC (Société Anonyme Omanaise Close) Closed Joint Stock Company
Sociedad Anónima Abierta (S.A.A.): To qualify to register as an S.A.A., a company must meet one or more conditions laid down in Article 249 of Peru's General Corporation Law. Those conditions state there must be a primary public offering of shares or convertible bonds in stocks, which are held by more than 750 shareholders, more than 35% of its capital belonging to 175 shareholders, or that all shareholders entitled to vote approve the adjustment to the scheme. The S.A.A. is then audited by the Comisión Nacional Supervisora de Empresas y Valores (CONASEV).
Sociedad Anónima Cerrada (S.A.C.): These companies must have a minimum of 2 and a maximum of 20 shareholders. These shares can't be registered in the Public Registry.
Corporation and Incorporated (may be abbrrviated as Corp. and Inc. respectively): ≈ Ltd and plc (UK) or corporation (US) with two or more shareholders and directors. (Prior to the enactment of the 2019 Revised Corporation Code, minimum number of shareholders were 5)
Company (Co.): ≈ General partnership (UK, US). Historically also used by corporations and other legal entities, such as the Manila Railroad Company. Existing corporations like Manila Broadcasting Company, Meralco, Metrobank still retain this older suffix, but new or renamed corporations must now include either Corp. or Inc. in their legal name to distinguish them from partnerships. This happened to the Philippine Long Distance Telephone Company after it decided to instead go for the initialism of their previous corporate name, ending up as "PLDT Inc."
Limited company (Ltd., Ltd. Co.): ≈ Limited partnership (UK, US). Not to be confused with the obsolete private limited company below.
Enterprise (Ent.): Used by some sole proprietorships but are not true legal entities.
Obsolete:
Compañía (Cía): For partnerships and other forms of business during the Spanish rule (e.g. Ayala y Compañía).
Private limited company (Ltd., Co. Ltd., or Co., Ltd.): ≈ Ltd (UK), LLC (US). Initially used during the early American colonial period, it has since been replaced by Corp. and Inc.
Sociedad anónima (SA, S.A.): Formed under Spanish rule. Replaced by private limited company.
Hybrid legal systems (Islamic)
Saudi Arabia
Private Limited Company ( شركة ذات مسئولية محدودة)
Joint-Stock company ( شركة مساهمة )
General Partnership Company ( شركة تضامن )
Limited Partnership (شركة التوصية البسيطة )
Foreign Company ( شركة أجنبية )
Individual Establishment ( مؤسسة فردية )
Saudi Arabia's new Companies Law modernized company forms and introduced the Simplified Joint Stock Company to support startups and VC activity.
United Arab Emirates
The UAE's Federal Decree-Law No. 32 of 2021 governs company types. Since 2021 reforms, onshore "mainland" companies in many sectors may be 100% foreign-owned.
In UAE Free Zones, a Free Zone Establishment (FZE) or Free Zone Company (FZC) is a limited liability company governed by the rules and regulations of the free zone in which it is established.
↑"HARVARD GLOBAL FOUNDATION LIMITED ANNUAL REPORT AND FINANCIAL STATEMENTS FOR THE YEAR ENDED 30 JUNE 2025". Charity Commission for England and Wales. p.2. Retrieved 5 June 2026. The Charity is a company limited by shares (with a non-profit distribution clause) with company registration number 13904921, and is governed by its Memorandum and Articles of Association. The Charity is also a registered educational charity, with charity registration number 1200419. The charity forms part of a "dual-qualified" structure, where the sole shareholder of the charity is Harvard Global Research and Support Services Inc, a charity registered in the United States of America.
↑Chirashree Das Gupta and Mohit Gupta, “The Hindu Undivided Family in Independent India’s Corporate Governance and Tax Regime”, South Asia Multidisciplinary Academic Journal [Online], 15 | 2017, Online since 22 March 2017, connection on 05 June 2026. URL: http://journals.openedition.org/samaj/4300; DOI: https://doi.org/10.4000/samaj.4300
↑Andrew J Hosmanek; Brendan Smith; Michael Dayton (2022). "12 Small Business Organizations". Business Law, Ethics, and Sustainability. University of Iowa Pressbooks. 12.2.1 Entity Characteristics of a Partnership.
↑Garner, Bryan A., ed. (2009). "company". Black's Law Dictionary. Black's Law, 9th Edition. Vol.1 (9ed.). St. Paul, Minnesota: West Publishing, Inc. p.318. ISBN9780314199492. Retrieved 20 Apr 2019. 2. A corporation, partnership, association, joint-stock company, trust, fund, or organized group of persons, whether incorporated or not, and (in an official capacity) any receiver, trustee in bankruptcy, or similar official, or liquidating agent, for any of the foregoing. Investment Company Act 2(a)(8)(15 USCA 80a-2(a)(8)).[permanent dead link]
↑"Register a Joint Stock Company". Sultanate of Oman, Ministry of Commerce and Industry. Archived from the original on 2014-09-13. Retrieved 21 July 2013. The commercial name should bear Omani Joint Stock Company (S.A.O.G)
