Robot Rules by Jacob Turner
Author:Jacob Turner
Language: eng
Format: epub
ISBN: 9783319962351
Publisher: Springer International Publishing
2.4 Mutual Recognition of Foreign Legal Persons
As soon as one country grants AI legal personality, this may have a domino effect on other nations.31 Many countries operate a doctrine of “mutual recognition” in their conflict of law provisions whereby they will accord the same status for legal persons recognised in other countries even where that entity would not be considered a person under the local law. This occurred in the UK case, Bumper Development Corp. v. Commissioner of Police for the Metropolis,32 where the Court of Appeal held that an Indian temple that was “little more than a pile of stones” could be a treated as a legal person in England because it held that status in India, even though English law had no equivalent standing for religious buildings.
EU freedom of establishment provisions require that all Member States recognise all legal persons formed in accordance with the law of at least one other Member.33 Article 54 of the Treaty on the Functioning of the EU (the TFEU) enshrines this principle:Companies or firms formed in accordance with the law of a Member State and having their registered office, central administration or principal place of business within the Union shall, for the purposes of this Chapter, be treated in the same way as natural persons who are nationals of Member States.
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