COMPARATIVE-LEGAL ANALYSIS OF STATE PROPERTY MANAGEMENT: FOREIGN EXPERIENCE AND PROSPECTS FOR UZBEKISTAN

Authors

  • Shavkatbek Tursunkulovich Juraboev Associate Professor, Department of Civil and Economic Procedural Law, Namangan State University

Keywords:

State property, state property management, comparative law, state-owned enterprises, corporatization, privatization, corporate governance, Temasek, SASAC, public domain.

Abstract

The article presents a comparative-legal analysis of state property management and identifies lessons for Uzbekistan. Four broad models are distinguished: the holding-company model (Singapore — Temasek), the centralized-supervision model (China — SASAC), the public-domain model (France), and the agency-plus-corporate-forms model (Germany — BImA; Russia — Rosimushchestvo). Against this background, the article examines Uzbekistan’s current framework — the State Assets Management Agency, the 2024 Law on Privatization of State Property, and the corporate-governance reform of enterprises with state participation. The study argues that Uzbekistan should combine an arm’s-length professional holding for commercial assets, unified supervision with corporatization, a protected category for strategic assets, and international corporate-governance standards, while adapting these solutions to its civil-law tradition and institutional capacity.

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Published

2026-06-09

Issue

Vol. 52 (2026)

Section

Articles

License

Creative Commons License

This work is licensed under a Creative Commons Attribution-NoDerivatives 4.0 International License.

How to Cite

COMPARATIVE-LEGAL ANALYSIS OF STATE PROPERTY MANAGEMENT: FOREIGN EXPERIENCE AND PROSPECTS FOR UZBEKISTAN. (2026). European Journal of Interdisciplinary Research and Development , 52, 249-256. https://ejird.journalspark.org/index.php/ejird/article/view/2204