LLC in English: legal nuances of translation

Surely, many heads of limited liability companies, going internationally or in offshore zones, entering into contracts with foreign companies or applying for job contracts abroad, faced with a problem: how to translate an LLC in English? Not only translators, but also lawyers have been “breaking the spears” for many years on this issue. It would seem easier: translate the words “limited liability company” and get a Limited liability company, abbreviated LLC, or Joint stock company - JSC. According to the laws of the English language, the abbreviation is put at the end of the name, for example, Karina LLC.

However, such a translation of the LLC in English implies a host of legal nuances that are not always beneficial for the head of a limited liability company. Even if we do not shock our potential foreign partners with this exotic word, but transfer the name of this form of ownership to the more familiar Ltd or Co Ltd, legal conflicts can not be avoided. Firstly, to be legally strict and meticulous, their Ltd and our LLC nevertheless differ from each other both in legal status and in legal form. In addition, the name of Karina, limited liability company will change depending on which country the company will be represented in: Karina GmbH in Germany, Carina SpA in Italy, Karina TzOV in Ukraine. But the company is registered in the Russian Federation!

The reason for translating the LLC into English, rather than transliterating it, is that large foreign corporations of the same form of ownership, “coming” to Russia, call themselves the three letters “O”. For example, OOO Siemens. Logically, if a foreign Society (corporation), entering the Russian market, calls itself the Russian abbreviation, why not translate our acronym into English as Ltd. However, such a transfer will not reflect the country of incorporation of the corporation.

When translating an abbreviation that reflects the form of ownership, the head of the company may take into account the “Letter of the Bank of Russia,” ordering the company to be written in English in Latin letters. The comments on this Letter were set forth in the journal International Banking Operations (No. 3 for 2005). True, the recommendations to replace the three Russian letters “O” with the three English letters “O” apply only to credit institutions and do not apply to other companies of owners and shareholders . You can, of course, to show firmness, intransigence and to what extent the patriotism and call yourself a company to its foreign partners, but how then to disclose complete. company name, as that requires a form of contract - transcribe "society with restrictions liability company "?

Writing an LLC in English, in fact, does not look inorganic. Indeed, many foreign firms simply transliterate not only their form of ownership, but also the name. Let’s recall, for example, Honda Motor Co. Ltd., Ferrol SpA or Hans Weber Machinenfabrik GmbH. The name of the company is also worth transliterating. The name of the company is like the name of a person. After all, we used to say Michael Jackson, not Michael Jackson. If we want the name of the corporation to immediately say a lot about the nature of its activity, then we can make a semantic translation of the name in brackets after the official name.

Some companies, in order to avoid difficulties with the translation in the future, already include the word Ltd in the name. For example, Topaz Ltd. Limited Liability Company. Then in a foreign spelling they indicate: “Topaz Ltd” Ltd. The translation into English of the Charter and official documents makes life easier for the leaders of such firms. Since there is no consensus on this score, and “everything that is not forbidden is allowed”, it depends on the leaders how they translate the abbreviation. Here you need to intuitively feel the most foreign partner. You can use LLC or Ltd in the name of the company, you can LLC. However, when specifying the details, we explicitly write transliteration - this, as the address of the company, is not translated.

Source: https://habr.com/ru/post/C955/


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