Comparative Study of the Basics of Piercing the Corporate Veil in English, US, and Iranian Law

Limited liability of shareholders in companies as the primary rule has abundant legal effects and benefits. but, there are several basic situations in which the corporate veil is removed and consequently the managers or the shareholders directly or indirectly, individually and jointly, must account for the payment of debts and fulfillment of obligations of the company. These basic situations have developed in common law especially in England and the United States and the case law in the named countries. Considering the current growth of corporations the Iranian law, and also the necessity of confronting to the instrumental use of companies and the phenomenon of paper companies, it seems vital to draw on the jurisprudence of some states such the United Kingdom and the United States to broaden the scope of directors’ liability in the Iranian commercial law.