Preventive restructuring frameworks: Jurisdiction, recognition and applicable law
نویسندگان
چکیده
The Preventive Restructuring Directive (PRD) has triggered a new era of regulatory competition. Member States are introducing laws aimed at making themselves the destination choice for corporate restructuring. However, PRD failed to provide clear answer some key issues: international jurisdiction, recognition and applicable law. This article analyses these questions in detail proposes answers.
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ژورنال
عنوان ژورنال: International Insolvency Review
سال: 2021
ISSN: ['1180-0518', '1099-1107']
DOI: https://doi.org/10.1002/iir.1447