business until 10% of its authorized capital has been
subscribed and paid for. The word "limited" as part of the company's
name is--as in the case of British companies--to be conspicuously
exhibited and used in all documents. The directors are not to be less
than three or more than fifteen, and must be holders of stock. Directors
are jointly and severally liable to the clerks, labourers and servants
of the company for six months' wages. Borrowing powers may be taken by a
vote of holders of two-thirds in value of the subscribed stock of the
company.
_South Africa._--In Cape Colony the law is contained in No. 25 of 1892,
amended 1895 and 1906; it follows English law.
In Natal the law is contained in Nos. 10 of 1864, 18 of 1865, 19 of 1893
and 3 of 1896.
In the Orange Free State in Law Ch. 100 and Nos. 2 and 4 of 1892.
For the Transvaal see Nos. 5 of 1874, 6 of 1874, 1 of 1894 and 30 of
1904.
In Rhodesia companies are regulated by the Companies Ordinance 1895--a
combination of the Cape Companies Act 1892, and the British Companies
Acts 1862-1890.
_France._--There are two kinds of limited liability companies in
France--the _societe en commandite_ and the _societe anonyme_. The
_societe en commandite_ corresponds in some respects to the British
private company or limited partnership, but with this difference, that
in the _societe en commandite_ the managing partner is under unlimited
liability of creditors; the sleeping partner's liability is limited to
the amount of his capital. The French equivalent of the English ordinary
joint stock company is the _societe anonyme_. The minimum number of
subscribers necessary to form such a company is (as in the case of a
British trading company) seven, but, unlike a British company, the
_societe anonyme_ is not legally constituted unless the whole capital is
subscribed and one-fourth of each share paid up. Another precaution
unknown to British practice is that assets, not in money, brought into a
company are subject to verification of value by a general meeting. The
minimum nominal value of shares, where the company's capital is less
than 200,000 fcs., is 25 fcs.; where the capital is more than 200,000
fcs., 100 fcs. The _societe_ is governed by articles which appoint the
directors, and there is one general meeting held every year. A _societe
anonyme_ may, since 1902, issue preference shares. The doctrine that a
corporation never dies has no place in French law. A _societe
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