Executive Summary

This report presents the results of a comparative analysis of South Africa’s National Small Business Act (No. 102) of 1996 with small business legislation in eight other jurisdictions – Brazil, India, Kenya, Malaysia, Nigeria, Taiwan, United Kingdom, and United States. The purpose of the analysis was to gain an understanding of the legislative and regulatory measures that the countries under study have adopted to stimulate, support and grow their small business sector, with a view to ascertaining best practices and innovative approaches that South Africa could learn from.

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