The share capital of the SE must be at least EUR 120 000. In other respects, the SE's capital, the increase and maintenance of capital and the conduct of business and the issue of securities shall be governed by the same provisions as those applicable to a public limited-liability company in the Member State in which the SE has its registered office. The SE is limited to multinational companies, i.e. companies established in at least two European countries, either by merger, as a holding company, subsidiary or simply by the nature of their business. The biggest difference results from the mixture of common law and civil law traditions. In contrast to the AG, the SE offers both a monistic (one-tier) and a dualistic (two-tier) form of administration, whereby the monistic has one administrative body and the dualistic functions like the AG model with administrative and supervisory bodies.