Abstract

With its large population and natural resources, Africa needs investors who can sustain its development. At the same time, foreign investors expect returns on their investments. In this regard, they have shown a preference for countries with more legal stability regardless of the incentives provided, be it tax incentives or access to low-cost labourers. However, there are divergent legal cultures and systems in Africa. French-speaking African countries have inherited the Civil law system, while English speaking African countries have inherited the Common law system. Furthermore, ...