Abstract
The comparative approach offers improved understanding of what is at stake for enterprises, workers and States in developing private pension schemes to fill the gap left by public schemes. The features that distinguish private schemes result from the freedom with which they were designed — by enterprises themselves or through collective bargaining — and the limits imposed by growing state intervention in granting fiscal concessions or stipulating social guarantees. Depending on how these various components are combined, private schemes may offers workers added protection or form a source of insecurity.
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