List of legal entity types by country

A business entity is an entity that is formed and administered as per corporate law in order to engage in business activities, charitable work, or other activities allowable. Most often, business entities are formed to sell a product or a service. There are many types of business entities defined in the legal systems of various countries. These include corporations, cooperatives, partnerships, sole traders, limited liability companies and other specifically permitted and labelled types of entities. The specific rules vary by country and by state or province. Some of these types are listed below, by country. For guidance, approximate equivalents in the company law of English-speaking countries are given in most cases, for example: However, the regulations governing particular types of entities, even those described as roughly equivalent, differ from jurisdiction to jurisdiction. When creating or restructuring a business, the legal responsibilities will depend on the type of business entity chosen.

Albania

Foreign and domestic investors have a range of options to establish and organize their business in Albania. They can either create and register a business organization or establish and register a branch or representative office. Previously, foreign entity registration was handled through the National Registration Center, which had implemented a streamlined "one-stop-shop" system since September 1, 2007. However, on November 26, 2015, the enactment of Law No. 131/2015 led to the formation of the National Business Center (QKB) which aimed to simplify business procedures by centralizing registration and licensing in a single institution. Consequently, the National Registration Center and the National Licensing Center were abolished.

Argentina

Australia

Belarus

Bosnia and Herzegovina

Brazil

Brunei

There are three main types of business entity in Brunei, namely sole proprietorship, partnership, and company. A private company contains the term "Sendirian Berhad", meaning "Private Limited" or "Sdn. Bhd." as part of its name; for a public company "Berhad" or "Bhd." is used.

Cambodia

Canada

In Canada entities can be incorporated under either federal or provincial (or territorial) law. The word or expression "Limited", Limitée, "Incorporated", Incorporée, "Corporation" or Société par actions de régime fédéral or the corresponding abbreviation "Ltd.", Ltée, "Inc.", "Corp." or S.A.R.F. forms part of the name of every entity incorporated under the Canada Business Corporations Act (R.S., 1985, c. C-44). ≈ Ltd. or Plc (UK) As an exception, entities registered prior to 1985 may continue to be designated Société commerciale canadienne or by the abbreviation S.C.C. Under the Canada Cooperatives Act (1998, c. 1), a co-operative must have the word "cooperative", "co-operative", "coop", "co-op", coopérative, "united" or "pool", or another grammatical form of any of those words, as part of its name. Unlike in many other Western countries, Canadian businesses generally only have one form of incorporation available. Unlimited liability corporations can be formed in Alberta "AULC", British Columbia "BCULC" and Nova Scotia "NSULC". The aforementioned unlimited liability corporations are generally not used as operating business structures, but are instead used to create favorable tax positions for either Americans investing in Canada or vice versa. For U.S. tax purposes the ULC is classified as a disregarded entity. Rather, Canadian businesses are generally formed under one of the following structures:

Chile

China (People's Republic of China)

Companies include two types, Other than companies, ordinary firms include other two types: (See also Partnership (China))

Colombia

Costa Rica

Dominican Republic

Ecuador

Egypt

Ethiopia

European Union and European Economic Area

Austria

See also help.gv.at (Austrian government site, in German)

Belgium

Dutch, French or German names may be used. Following changes to the Code of Companies and Associations, the term "Private limited liability company" (BVBA/SPRL) automatically became "Private limited company" (BV/SRL), as a part of harmonising legal entity types within the European Union.

Bulgaria

Croatia

Types of legal person business entities: Types of natural person business entities: Non-profit:

Cyprus

Czech Republic

Denmark

Estonia

Finland

The abbreviations are usually in Finnish, but Swedish names may also be used either as is or in combination with Finnish, e.g. Oy Yritys Ab. In the corporations of real estate law, the ownership or membership may be vested either in the real property or in a legal or natural person, depending on the corporation type. In many cases, the membership or ownership of such corporation is obligatory for a person or property that fulfils the legal requirements for membership or wishes to engage in certain activities.

France

Germany

Greece

Companies of the type "Anónimi Etaireía" would translate this designation into the French translation société anonyme or S.A. in non-Greek languages.

Hungary

In Hungary, business entities are mainly regulated by the Companies Act of 2006, the Companies Registration Act of 2006 and the new Civil Code of 2013. All companies are required to indicate their type in their name.

Iceland

Ireland

The situation in Ireland is similar to the United Kingdom below, though without the class Community Interest Company. There were two forms of Company Limited by Guarantee, but only the form without a share capital is now used. Irish names may also be used, such as cpt (cuideachta phoibli theoranta) for plc, and Teo (Teoranta) for Ltd.

Italy

Latvia

Liechtenstein

Lithuania

Luxembourg

Malta

Netherlands

All non-governmental legal entities are registered on the companies register by the chamber of commerce.

Norway

Poland

No universal definitions of company and business exist in the Polish law. The usage of the equivalent terms in the Polish legal system may often be confusing because each of them has several different definitions for various purposes. Przedsiębiorca ('entrepreneur' or 'undertaking')—known as kupiec ('merchant') until 1964; jednostka gospodarcza ('economic unit') from 1964 to 1988; podmiot gospodarczy ('economic entity') from 1988 to 1997—is the closest equivalent of company understood as an entity. As of January 2021, there are at least thirteen different definitions of entrepreneur/undertaking, enshrined in the following acts: Przedsiębiorstwo ('enterprise') is defined in the Civil Code as an organized complex of material and non-material components designated to perform economic activity. Therefore, it is equivalent to company understood as a set of assets organized to do business. Działalność gospodarcza ('economic activity') is the closest equivalent of business. As of January 2021, there are at least six different definitions of economic activity, enshrined in the following acts:

Entities registered as entrepreneurs in the Central Registration and Information on Business (Centralna Ewidencja i Informacja o Działalności Gospodarczej, CEIDG)

Entities registered in the National Court Register (Krajowy Rejestr Sądowy, KRS)

Entities registered as entrepreneurs in the Register of Entrepreneurs (Rejestr przedsiębiorców), excluding the pan-EU forms

Except for the spółki osobowe (partnerships), all are juridical persons. From business perspective spółki z ograniczoną odpowiedzialnością (limited liability companies) are the most popular forms of legal entities in Poland as approx. 96% of foreign investments is performed in this legal form.

=

Entities registered in the Register of Associations, Other Social and Professional Organizations, Foundations and Independent Public Healthcare Institutions (Rejestr stowarzyszeń, innych organizacji społecznych i zawodowych, fundacji oraz samodzielnych publicznych zakładów opieki zdrowotnej)===== All the following types are juridical persons: In addition, any juridical persons or other legal entities (including those originally or otherwise exempt from the registration in the KRS – see below) also have to register, if they apply for and obtain the status of an officially recognized charity (organizacja pożytku publicznego = public benefit organization), when eligible; however, as an exception, registration solely for that purpose neither confers juridical personality to entities lacking one, nor does it create obligation or right to register as an entrepreneur.

Entities excluded from registration as entrepreneurs

Types of entities excluded from registration as entrepreneurs include the following.

Natural persons

Juridical persons and other collective legal entities, excluding the pan-EU forms

Certain types of juridical persons or other collective legal entities which have been established otherwise than by registration in the KRS, may in few situations be authorized by law to perform business activity (sometimes of a limited scope and/or scale, along with their main, often non-commercial or not-for-profit activity), despite remaining excluded and exempt from the obligation to register in the KRS, but are still obligated (except for the State Treasury as a whole) to obtain NIP and REGON numbers by registering in the relevant registers, and are usually still subject to the general taxation rules (including VAT); examples of such situations include: Some of the abovementioned types of entities (e.g. hunting clubs, church entities), other than the state or self-governmental ones, may nevertheless be subject to registration in the KRS exclusively for the purpose of official recognition as a charity (public benefit organization – see above), if they are eligible for, apply for and obtain such.

Portugal

Romania

Societăți comerciale, abbreviated SC (Companies): limited liability company "societate cu raspundere limitata" (SRL);

Slovakia

Slovenia

Spain

Sweden

Ghana

Guatemala

Haiti

Hong Kong

India

Indonesia

Most of the legal entity types are regulated in a modified version of the original version of the Dutch Burgerlijk Wetboek.

Iran

Israel

Japan

Business corporations are referred to as kaisha (会社) and are formed under the Companies Act of 2005. There are currently (2015) 4 types and each of them has legal personality: Partnerships are referred to as kumiai (組合). Each of these 4 types has no legal personality though other corporations, which include "kumiai" in their name, have:

Jordan

Kazakhstan

Korea, South

Kosovo

Lebanon

Malaysia

Mexico

Note: Any of these entities can be incorporated as a "Capital Variable" entity, in which case has to add the "de C.V." sufix to its company name. Example: "S.A. de C.V.", "S. de R.L. de C.V."

Monaco

Mongolia

Montenegro

one of above mentioned form (Preduzetnik; O.D.; K.D.; A.D.; D.O.O.), as such it is registered in the Central Register of Companies. This form is a little bit specific and was created for companies that are domiciled registered in other countries and have its part in Montenegro.

Morocco

Namibia

Nepal

New Zealand

Nicaragua

The Commercial Code establishes the following types of companies:

Nigeria

North Macedonia

Oman

Pakistan

There are three main forms of business: (a) Sole Proprietorship (b) Partnership (c) Company In a sole proprietorship, an individual on his/her own account carries out the business or profession. No formal procedure or formality is required for setting up a sole proprietary concern. A partnership is a business relationship entered into by a formal agreement between two or more persons or corporations carrying on a business in common. The capital for a partnership is provided by the partners who are liable for the total debts of the firms and who share the profits and losses of the business concern according to the terms of the partnership agreement. Partnerships (other than banking companies) are generally limited in size to twenty partners. The interest of a partner is transferable only with the prior consent of the other partner(s). However, a partner's right to a share of the partnership income may be received in trust for another person. For taxation purposes, partnerships are classified into: (i) Registered Firms (ii) Unregistered Firms The income of the registered firm is subject to Super Tax before distribution to the partners. Also the individual income of the partners is subject to income tax at the usual rates. For unregistered firms, income tax is levied on the firm's income and the partners are not liable to pay tax on the shares of profit received from the unregistered firm(s). A company is a legal entity formed under the Companies Ordinance, 1984. It can have share capital or can be formed without share capital. A company having share capital may be formed as: (i) A company limited by shares. (ii) A company limited by guarantee. (iii) An unlimited company. The liability of its members is limited to the extent of their shares in the paid-up capital of the company. These companies may further be classified as public limited and private limited companies. (i) Restricts the right to transfer its shares; (ii) Limits the number of its members to fifty; and; (iii) Prohibits any invitation to the public to subscribe for shares or debentures of the company. A private limited company is required to use the words "(Private) Limited" as the last words of its name. Means a company having the liability of its members limited by memorandum to such amounts as the members may respectively undertake to contribute to the capital of the company in the event of its winding up. A company limited by guarantee is usually formed on a 'non profit basis'. Companies limited by guarantee use the words (Guarantee) Limited" as the last words of their n Unlimited Company Means a company having unlimited liability of its members

Peru

Philippines

All legal entities in the Philippines, including the recently approved one-person corporation (OPC), are registered with the Securities and Exchange Commission.

Russia

According to the Civil Code of Russian Federation the following corporate entities may be created:

Unitary enterprise

Joint-stock companies

Joint-stock companies:

Partnerships

These are less common:

Saudi Arabia

Serbia

Singapore

Private Limited Company, Sole Proprietorship and Partnership are the predominant types of business found in Singapore.

South Africa

Switzerland

Taiwan (Republic of China)

Thailand

Tunisia

Turkey

According to Code of Obligations (fifth book of Civil Code) (Act No: 6098): According to the Commercial Code (Act No: 6102): Ortaklıklar ≈ Partnerships (unlike the partnerships in Anglo-American law, they also have legal personality like companies) Sermaye şirketleri ≈ Companies According to the Capital Markets Act (Act No: 6362): According to the Cooperatives Act (Act No: 1163): Other entitites:

Ukraine

Company formation is regulated by the Ukrainian Civil Code and Commercial Code, Law On Business Associations, Law On Joint Stock Companies, Law On Limited Liability Companies and Additional Liability Companies.

United Arab Emirates

In UAE Free Zones, a Free Zone Establishment (FZE) or Free Zone Company (FZC) is a limited liability company governed by the rules and regulations of the relevant zone in which it is established.

United Kingdom

United States

In the United States, most legal entities are incorporated under the law of a particular state. The federal government does not generally incorporate entities (the verb "charter" is used instead), with a few narrow exceptions, either government-sponsored corporations or government-owned corporations. Those entities existing on the state level have two separate identities: their legal entity type, e.g., partnership, corporation, or LLC, and their tax classification, what they are regarded as for federal income tax purposes. A further way to classify an entity is whether it is a for-profit or nonprofit enterprise, each classification with its own taxonomy and implications on federal income tax law. For-profit entities exist for the purpose of producing a profit for their owners whereas nonprofits exist for any purpose other than profit.

Tax classifications

For federal tax purposes, the Internal Revenue Service has separate entity classification rules, generally depending on whether an entity is a for-profit or non-profit organization. For-profit entities can be collectively regarded as "taxable organizations" while nonprofit entities are collectively regarded as "tax-exempt organizations" or simply "exempt organizations."

Taxable Organizations

Under the Internal Revenue Code, a for-profit entity may be classified as a corporation, a partnership, a cooperative or a disregarded entity. A corporation is taxed as a C corporation unless it elects and meets the requirements to be taxed as an S Corporation. A disregarded entity has one owner (or a married couple as owner) that is not recognized for tax purposes as an entity separate from its owner, so the owner is taxed on the individual level. Types of disregarded entities include single-member LLCs; qualified sub-chapter S subsidiaries and qualified real estate investment trust subsidiaries. A disregarded entity's transparent tax status does not affect its status under state law. For example, for federal tax purposes, a sole-member LLC (SMLLC) is disregarded, so that all its assets and liabilities are treated as owned by its single member. But under state law, an SMLLC can contract in its own name and its owner is generally not personally liable for the debts and obligations of the entity. To be recognized as a Cooperative for tax purposes Cooperatives must follow certain rules under Sub Chapter T of the Internal Revenue Code.

Tax Exempt Organizations

Nonprofit organizations on the state level are exempt from federal income taxation for most types of income. There are two main types of tax exempt organizations under the Internal Revenue Code: 501(c) organizations and 527 organizations. Tax exemption has two components: exemption from income taxation and the allowance of a deduction on the tax returns of donors. Section 501(c) encompasses most types of nonprofit entities other than ones engaged substantially in political activity. There are 29 subtypes of 501(c) organizations. For example, section 501(c)(10) includes "domestic fraternal societies, orders, or associations, operating under the lodge system," while section 501(c)(6) includes "business leagues, chambers of commerce, real-estate boards, boards of trade, or professional football leagues" under certain circumstances. The most prevalent type of 501(c)s are 501(c)(3) organizations, known broadly as "charitable organizations," those whose purpose is charitable (i.e., relief from poverty), educational, scientific, religious, or advocatory, among others, as long as such organization does not engage in substantial political activity or inure the benefit of net earnings to shareholders or other individuals. This is the preferred tax status because it is the only 501(c) that obtains both income tax exemption and tax deductible donations. All other 501(c) types only obtain tax exemption. Section 501(c)(3)s can be further divided into private foundations, public charities, and private operating foundations with private foundations given the least favorable deductibility rate. State-level unincorporated nonprofit associations, charitable trusts, and nonprofit corporations may fall into any one of the 501(c) categories depending on their purpose and the activities they engage in. Section 527 organizations, also called "political organizations," are any nonprofit substantially engaged in "political activity," such as election campaigning or lobbying. These are organizations like political parties and election campaign committees, which are often called political action committees (PACs) or Super-PACs. These organizations are subject to more stringent regulations than 501(c) organizations and only receive tax exemption; donations to 527s are not deductible. Any type of nonprofit entity existing on the state level will be regarded as a 527 if it substantially engages in political activity.

Federally chartered

Of the few types of companies that may exist under a federally issued charter, the bulk are banks, credit unions, and similar depository institutions. Such institutions are distinguished from state-chartered banks by including a key word in their formal names. For a bank, the key word is "national". A bank chartered by the Office of the Comptroller of the Currency (OCC) must have the word "national" in its name. A bank chartered by a state cannot have "national" in its name. For a savings bank (formerly called a savings and loan association) or credit union, the key word is "federal", and the same rules apply; a federally chartered savings bank or credit union must have the word "federal" in its name, while a state chartered savings bank or credit union cannot have "federal" in its name. Many federal governmental units are specially formed public corporations (which, for tax purposes are also generally 501(c)(1) organizations) and government-sponsored enterprises, while some private organizations have received a Congressional charter.

Unincorporated nonfederal entities

The following are the entity structures that can be created without licensure by a state government, or in other words are "unincorporated": To determine whether a general partnership exists courts analyze a few factors: (1) intention of the parties, (2) sharing of profits and losses (3) joint administration and control of business operation, (4) capital investment by each partner, and (5) common ownership of property.

Incorporated nonfederal entities