Abstract
This paper focuses on the harmonisation narrative of the European insolvency law. It provides an analysis of alternative approaches, notably top-down regulation and bottom-up competition, geared towards supporting the convergence of insolvency and restructuring laws across the Member States. Its focus is on recent changes in the restructuring law of England and Germany.
| Original language | English |
|---|---|
| Title of host publication | Insolvency Law: Back to the Future |
| Publisher | INSOL Europe |
| Chapter | 10 |
| Pages | 111 |
| Number of pages | 120 |
| Publication status | Published - 2022 |
Keywords
- insolvency
- restructuring
- executory contracts
- harmonisation
- Germany
- England
- cross-class cram-down