News for hackers. Stuff that matters.
Re:Europe's Software Problem by imNotTheProb on Tuesday June 15, 2021 @09:23AM (#27515061)
They don't have LLCs?
Re:Europe's Software Problem by zerkten on Tuesday June 15, 2021 @10:02AM (#27515669)
LLCs aren't really relevant to this. The poster was commenting on bankruptcy laws with the assumption of familiarity. You can check out articles like https://link.springer.com/article/10.1007%2Fs10657-006-8978-..., but the gist is that bankruptcy in the US is forgiving versus being a terminal state in Europe. This is both in law and in society.

Once someone has gone bankrupt in Europe, they are historically, are a pariah. They will struggle to get financing to take a risk with another company. This is on top of a risk-averse system that generally places much higher requirements on non-bankrupt people seeking financing.

Compare this to the situation in the US. Here there is relatively easy access to financing at all sizes of organization. It only noticeably tightens when there is a recession or there are very serious issues with the founders. When a company fails there are more options for recovery, sell-off, acquisition, etc. Labor law permits companies to jettison all employees easily too in certain situations whereas that is much more difficult in Europe. Although this is starting to get away from pure bankruptcy law it overlaps.

Re:Europe's Software Problem by kdomanski on Tuesday June 15, 2021 @08:40PM (#27523512)
This. In addition, in some countries like Germany, having your name connected to a bankruptcy will ruin your credit score, making it difficult to e.g. rent an apartment.
Re:Europe's Software Problem by Juliate on Tuesday June 15, 2021 @09:33AM (#27515258)
There are equivalents (https://fr.wikipedia.org/wiki/Responsabilit%C3%A9_limit%C3%A... - in French) but country-specific, there's no a European common structure.

But another benefit from LLCs in the USA might be the lighter paperwork and simpler taxes filing.

Which we also have (in France at least, as entrepreneur individuel), but both don't intersect.

Re:Europe's Software Problem by Bayart on Tuesday June 15, 2021 @11:21AM (#27516780)
>there's no a European common structure.

There are European corporate entities nowadays. See SE[0], SCE[1] and SPE[2]. The SPE is what you'd call an LLC, GmbH, SARL etc.

[0] https://en.wikipedia.org/wiki/Societas_Europaea

[1] https://en.wikipedia.org/wiki/Societas_cooperativa_Europaea

[2] https://en.wikipedia.org/wiki/Societas_privata_Europaea

Re:Europe's Software Problem by MatthewMcDonald on Tuesday June 15, 2021 @09:38AM (#27515350)
I don't know about the bankruptcy laws, but Germany's GMBH (similar to an LLC) requires 25k in capital to get started.
Re:Europe's Software Problem by thesimon on Tuesday June 15, 2021 @12:36PM (#27517859)
UG requires only 1ct, though extracting profit is a bit more difficult until you get to 25k.
Re:Europe's Software Problem by jbverschoor on Tuesday June 15, 2021 @06:29PM (#27522409)
It used to be 18k here. Not anymore. However an LLC will provide you with almost no protection anymore.
Re:Europe's Software Problem by tluyben2 on Wednesday June 16, 2021 @01:31AM (#27525224)
What does that mean? A BV protects you unless you pierce the veil. You are negligent or a malicious if you do so; otherwise it does protect you. But maybe you mean something else.