From real to fictitious personality: The concept of juridical person in soviet civil regulations and influences on Russia, China and Vietnam

The findings reveal a remarkable consistency: all three legal systems predominantly follow the fictitious doctrine when conceptualizing “juridical person” in their civil regulations, especially their Civil Codes. While variations exist due to ideological and historical contexts, this uniformity emphasizes the enduring influence of Soviet law and legal tradition on legislators’ approach to this concept across these nations.