Підстави примусової ліквідації юридичної особи корпоративного типу: компаративний підхід

broader, which makes it more 'adapted' to modern realities, in particular, the legislator has established these grounds not only taking into account the formal requirements for maintaining certain uniform rules of the game on the market and ensuring economic law and order, but also taking into account the real needs of business and the protection of the rights of bona fide business players.The grounds for compulsory liquidation of legal entities in the legislation of countries with different legal models, such as the Northern European countries of Sweden and the Netherlands and the Asian country of Singapore, are considered, and the judicial practice regarding the application of such grounds is analysed.It has been proven that the list of grounds for compulsory liquidation of a legal entity, which was enshrined in the Law of Ukraine 'On State Registration of Legal Entities and Individual Entrepreneurs' (in the previous version, which existed until 1 January 2016), was systematic and the grounds specified therein correlated in content with the grounds for compulsory liquidation by court decision, which are enshrined in the legislation on companies of the countries whose legislation is considered in the article.It is justified that with the entry into force of the new version of this law, these grounds for liquidation were not enshrined in other normative acts, and a certain legal vacuum was created regarding the possibility of applying such a sanction as liquidation for violation of the requirements of the law.The need to enshrine an open list of general grounds for compulsory liquidation of legal entities in a codified regulatory act is argued.It is noted that, given the processes of globalisation, it seems expedient to implement certain grounds for compulsory liquidation of legal entities into national legislation.The expediency of distinguishing between the competences of two bodies (the court and the state registration authorities) in deciding on the compulsory liquidation of a company depending on the grounds for such liquidation is demonstrated.