Abstract
The objective of this research is to identify challenges associated with adapting the regulatory mechanisms employed in common law jurisdictions for resolving corporate disputes to the specific legal framework of Kazakhstan. The methodological foundation of this study rests on technical, legal, and comparative legal approaches to analyze the fundamental principles underpinning legislative regulations in the realm of corporate (business) legal relations. This paper examines the practices employed in common law, civil law, and mixed legal systems for regulating relevant legal matters. Additionally, it explores the experience of non-common law countries in adopting elements of case law systems that are not native to their legal traditions. Against the backdrop of the ongoing convergence of legal systems, elements of case law are increasingly being integrated into the mechanisms of corporate dispute resolution in countries with civil and mixed legal systems (France and the United Arab Emirates (UAE)). In Kazakhstan, this process meets obstacles caused by the lack of a clear definition of corporate law. The application of common law procedures and elements in Kazakhstan remains a relatively niche phenomenon, primarily confined to the operations of the Astana International Financial Centre (AIFC) court.