عنوان مقاله [English]
The issue of identifying traders and distinguishing them from non-traders is one of the issues that due to its legal effects, especially providing transaction security by identifyication and recognizing the legal status of the transaction party has been considered by the legislatures in countries under the Roman -German legal system and this has led governments to consider the "registration body" as a tool to identify the legal status of traders. However, studies show that, in practice, the "registration body" has not been able to respond to this need in the same way in all countries and to fulfill the legal functions expected of it,i.e informing, identifying traders and improving the supervision of traders' activities.
So these questions have been arise: what are the differences between the performance of Roman-German legal systems in implementing the registration mechanism? What registration patterns can be identified and which of these patterns can be introduced as an efficient registration mechanism in the framework of the expected functions. This study with comparative- analytical view has concluded that " Traders Registration Systems" have three different patterns that are rooted in the objective, subjective or mixed Commercial Law system of each country. However, a registration system based on an objective system is more efficient than the other two systems in fulfilling the expected legal functions of the traders registration system;because of the effective connection between "trader description" and "registration" by "creating this description simply by registering in the Business Register Book