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In Search of a Competition Law Model for ASEAN through a Case Study of Singapore, Malaysia and Vietnam: Does the EU Competition Law Model Fit?
Dufková, Barbara ; Tomášek, Michal (advisor) ; Šmejkal, Václav (referee) ; Petr, Michal (referee)
In Search of a Competition Law Model for ASEAN through a Case Study of Singapore, Malaysia and Vietnam: Does the EU Competition Law Model Fit? Abstract The thesis aims to identify a fitting competition law regime for ASEAN countries. It operates upon presumption expressed in the scholarship on legal transplanting and competition law and development that for a transplanted competition law to be successful, it has to be tailored to fit the domestic environments. As the thesis observes that in adoption of their competition regulation, ASEAN member states resorted to legal transplanting of competition models from other jurisdictions, especially that of the EU, tailoring the EU model to fit their domestic conditions seems to be a key to their success. These differences in domestic conditions resulting in different national competition laws will also influence the design of a region-wide competition law regime that is being constructed. To identify those market-related needs and pain-points of ASEAN members states, the thesis classifies them into clusters depending on their level of economic development. Singapore, Malaysia and Vietnam (the examined jurisdictions) were selected as representatives of the economies of ASEAN member states from the most developed to the least developed ones. The thesis first analyses...

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