In two recent Hong Kong cases, Power Dekor (Hong Kong) Ltd v. Power Dekor Group Co Ltd [2014]1 HKLRD 845 and Exxon Mobil Corporation v. USA Exxon Mobil Oil Limited & Others (HCA 2188/2013), Zervos J of the Hong Kong Court of First Instance re-opened the debate about shadow companies in Hong Kong. Despite changes to the Companies Ordinance in 2010, aimed specifically at dealing with the shadow companies problem, Zervos J's judgments in effect expressed the view that the amendments do not adequately deal with the problem and called for proactive measures to be taken by the Companies Registry of Hong Kong to deal with the root of the problem.
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