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3. The third type involves stimulating and incentivizing the growth of social enterprises through
robust financial support and comprehensive tax benefits. This approach is exemplified by the
Republic of Korea. While similar to the second model, where the state plays an active role in
supporting social enterprises through public policy, the Korean model differs in the intensity
of support provided. The South Korean government has deliberately positioned social
economy organizations as instruments for addressing economic crises, tackling
unemployment among disadvantaged groups, and countering the erosion of social welfare.
Nevertheless, the three developmental models described above should not be viewed as rigid or
mutually exclusive categories. Even among Anglo-Saxon countries, notable differences exist. For
example, the United Kingdom has enacted policies and legislation to promote investment in social
enterprises and public procurement from such enterprises. In contrast, the United States lacks
comparable legislation, although its laws do allow large corporations to pursue social objectives
alongside profit-making. Additionally, the U.S. tax system creates incentives for billionaires to
establish foundations and spend on social and environmental initiatives as a means of reducing
their tax liabilities. In Europe, since the early 2000s, there has been growing diversity in the
models of social enterprises. An increasing number of countries in Europe, and beyond, have
shown interest in adopting the U.S.-style Benefit corporation model, including Italy, France,
Portugal, Spain, Switzerland, Canada, Australia, and New Zealand. That said, fundamental
differences between the European and American approaches remain. Europe tends to have more
clearly defined public policies that support social enterprises, including the use of financial
instruments managed at both national and regional levels to improve access to funding. In
contrast, the development of social enterprises in the United States is primarily driven by private
sector market mechanisms, with minimal public spending allocated to social welfare services.
This chapter will explore the development of social enterprises in selected countries, following
the frameworks outlined above. The focus will include the United States and the United Kingdom
(excluding Scotland, which operates under a separate legal system distinct from England and
Wales). The United Kingdom stands out as a country with a significant number of social
enterprises and a more advanced legal framework for their regulation compared to many other
nations. Regarding continental Europe, the chapter will provide an overview of the characteristics
of social enterprises across the region. It will examine the policies and legislation of the European
Union (EU), a regional organization, while recognizing that individual member states still differ
significantly in terms of legal structures and levels of economic and social development. The
chapter will also present the case of the Republic of Korea, which is recognized as having the most
advanced legal framework for social enterprises in Asia. Korea’s model offers a unique contrast to
those found in Western countries.
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