WITHDRAWAL AGREEMENT BETWEEN THE EUROPEAN UNION AND THE UNITED KINGDOM: CROSS-BORDER INSOLVENCY AND BREXIT. WHAT WILL HAPPEN AFTER THE TRANSITION PERIOD?

marketude Cristina Fussi, Diritto europeo e della concorrenza, Diritto fallimentare e procedure concorsuali, Pubblicazioni, Silvia Doria

Obvious issues which come up in a cross-border insolvency context include the jurisdiction / court in which proceedings should be commenced (choice of jurisdiction), which law should be applied to resolve a particular problem (choice of law) whether the judgment of one court will be recognized and enforced in another court (recognition) and how parallel insolvency processes relating to the same debtor should interact (co-operation)….

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