However if additional assistance or protective measures are needed, the order opening UK insolvency proceedings can be recognised by the Croatian court under general conflict of law provisions and the Croatian Bankruptcy Act, provided certain conditions are met, notably that the proceedings do not contravene Croatian public policy. These are automatically recognised, provided that the “centre of main interests” is in the originating country, due process has been followed and the proceedings do not contravene Luxembourg public policy. Limited recognition of UK insolvency proceedings is automatic under French law, but a court application for exequatur will be required to deal with assets in France. An application to court is likely to be required. National insolvency laws were considered ill-equipped to deal with cases of a cross-border nature, resulting in inadequate and inharmonious legal approaches. As the legal position is not settled, insolvency officeholders seeking to deal with assets in Ireland may wish to take professional legal advice regarding the most appropriate course of action, including the likely costs, timescale and the prospects of success. After 31 December, the law of the UK and the relevant domestic laws of each of the individual member states instead apply. Don’t include personal or financial information like your National Insurance number or credit card details. Before court recognition is obtained, the UK insolvency officeholder cannot deal with the debtor’s assets located in Cyprus. The contents of this document do not represent professional or legal advice of any kind, and are not a substitute for such advice. In those cases this is limited to a very short description of the arrangements for the recognition of foreign insolvency proceedings. A UK insolvency officeholder does not generally require recognition from the Croatian court in order to be able to dispose of assets located in Croatia. importance and academic complexity, cross-border insolvency law remains in a state of confusion. Justice Newbould noted that Universalism is a theory that posits that the bankruptcy law to be applied should be that of the debtor’s home ju-risdiction, that all of the assets of the insolvent corpora-tion, in whichever country they are situated, should be Out-of-court appointments may not be recognised to the same extent as in-court appointments under the domestic laws of each EU member state. Broadly speaking, once the opening of foreign insolvency proceedings is recognised in Spain, the insolvency officeholder can exercise their normal powers under the foreign (i.e. At present, the legal framework governing corporate insolvency i.e. Historically in jurisprudence the recognition of foreign insolvency proceedings was limited, but as of the turn of the century the situation changed and the Supreme Court has restated the rules in its Yukos judgment of 18 January 2019. RZP�'p����i\י�i�8ې�����]4�1�rL2��pv�yGv�y`N��IW�r�]/���. Given what has happened globally since judgment was given in this case in January 2020, it seems something of a luxury now for restructuring professionals to be considering the prospect of solvent liquidations. Ireland has not adopted the UNCITRAL Model Law on Cross-Border Insolvency at present, although there are ongoing discussions between law reform groups and the Irish government concerning its adoption. The EU Insolvency Regulation (EU 2015/848) will continue to apply to main proceedings opened in an EU member state or the UK on or before 11pm on 31 December 2020, and any related secondary proceedings. This represents a significant change in the way that insolvency proceedings with cross-border assets and interests between the UK and EU are governed. Recognition and enforcement of UK insolvency proceedings that are considered to be insolvency proceedings under Belgian law (such as UK administration) is governed by Articles 116-121 of the CPIL. This article considers the new debtor-friendly changes to the German and English restructuring regimes and the impact of Brexit on cross-border recognition of … 19. The guide should not be treated as comprehensive or as endorsing any organisation or course of action; its accuracy should not be relied upon. An application must be made to the court in the relevant jurisdiction, which will assess the level of assistance that can be provided based on where the insolvent’s “centre of main interests” is located or if there is an establishment in the jurisdiction where the foreign insolvency proceedings have been opened. insolvency report since many of the cross-border issues related to insolvency have to be investigated against the background of the national (or, for the European Union, the supranational) legal regimes applicable in the respective jurisdiction. This guide seeks to provide insolvency officeholders with some basic information regarding the applicable frameworks in the different EU member states, as a starting point towards seeking recognition for UK insolvency proceedings and dealing with assets in the EU. The end of the transitional period affects the way that insolvencies can be managed across borders with EU member states: the legal framework provided by the EU Insolvency Regulation (EU 2015/848) no longer applies to main insolvency proceedings opened after 31 December[footnote 1]. This provides a uniform set of rules for the recognition and enforcement of foreign insolvency proceedings, streamlining the process. It is hoped that the information provided in this guide will prove helpful. Conversely, other jurisdictions use the phrase “automatic recognition” to mean simply that the jurisdiction recognises that the foreign insolvency proceedings exist and the foreign officeholder has standing to apply to court to be permitted to enforce the foreign judgment opening the insolvency proceedings (but they cannot meanwhile exercise any powers in the name of the debtor). However, since the requirement of reciprocity has been Under what circumstances will the courts in your jurisdiction recognise the validity of foreign insolvency proceedings? due process). Recognition of UK insolvency proceedings is automatic under the German Insolvency Code. No liability is accepted for any loss or damage suffered from the use of this information. The opening of UK insolvency proceedings automatically grants a limited degree of recognition to the UK insolvency officeholder. A court application to the Portuguese courts is required for both the recognition and enforcement of UK insolvency proceedings in Portugal and the realisation of assets by a UK insolvency officeholder. There is no relevant Anglo-Dutch treaty. Four EU member states – Greece, Poland, Romania and Slovenia – have implemented the UNCITRAL Model Law on Cross-Border Insolvency. https://e-justice.europa.eu/content_costs_of_proceedings-37-es-en.do. ↩, The Cross-Border Insolvency Regulations 2006 (SI 2006/1030); The Cross-Border Insolvency Regulations (Northern Ireland) 2007 (SR 2007/115) ↩. The Foreign, Commonwealth and Development Office provides a list of English-speaking lawyers and notaries: https://www.gov.uk/government/publications/germany-list-of-lawyers, The European e-Justice Portal includes basic information regarding legal fees in Germany: https://e-justice.europa.eu/content_costs_of_proceedings-37-de-en.do. Without a court order recognising the UK insolvency proceedings, the UK insolvency officeholder cannot deal with the insolvent’s assets in Slovakia. Recognition does not violate German public policy. Assistance in the preparation of this material was provided by: The Belgian Code of Private International Law (the “CPIL”) allows for the recognition and enforcement of UK insolvency proceedings upon application to court. Once an application for exequatur is granted, the UK insolvency officeholder is entitled to various assistance under Book XX of the Belgian Code of Economic Law (the “CEL”), including to: request that the details of the insolvency proceedings be published in the Belgian Official Gazette; exercise the powers they would usually have when in their home jurisdiction; and. It will take only 2 minutes to fill in. The Foreign, Commonwealth and Development Office provides a list of English-speaking lawyers and translators: https://www.gov.uk/government/publications/belgium-list-of-lawyers, The European e-Justice Portal includes basic information regarding legal fees in Belgium: https://e-justice.europa.eu/content_costs_of_proceedings-37-be-en.do. An Estonian court order is required declaring that the UK court’s judgment opening the insolvency proceedings is recognised and enforceable in Estonia. However, for most purposes including dealing with assets and other enforcement, an application to court for recognition (exequatur) is required. Before granting the application, the judge will have to confirm that (i) the UK court had the authority to open the insolvency proceedings, (ii) the insolvency order is not manifestly contrary to French public policy, and (iii) no fraud has been committed in the opening of the insolvency proceedings. Hong Kong is not a signatory to the UNCITRAL Model Law concerning cross-border insolvencies, and nor are various offshore jurisdictions. There is currently no such treaty between Bulgaria and the UK. The EU Regulation sets the rules for the opening of insolvency proceedings within the EU; it provides automatic recognition to insolvency proceedings across the EU, legitimising their status in each of the member states that have adopted it; and subject to certain safeguards it ensures that the insolvency proceedings can be enforced, allowing insolvency officeholders to deal with assets wherever they may be in the bloc. A court application will be required in order for UK insolvency proceedings to be recognised and enforced in Spain. However, that would require a ministerial order to be made, specifying that section 1417 applies again to Northern Ireland and Great Britain. However, absent a court order recognising the insolvency officeholder (an exequatur), the debtor will retain all its powers to deal with the companies’ assets. Therefore automatic recognition in Bulgaria is not available for UK insolvency proceedings. More information regarding the Model Law is provided by UNCITRAL at: https://uncitral.un.org/en/texts/insolvency/modellaw/cross-border_insolvency the judgment opening the foreign insolvency proceedings must not be contrary to Spanish public policy. The Portuguese courts will recognise the UK insolvency proceedings if certain conditions are met, including: the debtor’s centre of main interests is in the UK, the debtor’s registered office or its domicile is in the UK, or. However, the Hon’ble Supreme Court in Macquarie Bank Limited v.Shilpi Cable Technologies Lt[see End Note 1] set a precedent that foreign creditors shall have the same right as available to a domestic creditor to initiate and participate in corporate insolvency resolution process un… You can change your cookie settings at any time. To date four of the remaining EU member states have implemented the UNCITRAL Model Law. Therefore, the automatic recognition of insolvency proceedings, applicable law and insolvency officeholder status that subsists within the Recast Insolvency Regulation will not apply as between the UK and the EU. The Common Law and Recognition of Foreign Liquidation Proceedings. where the judgment contains a disposition contrary to Maltese public policy) or the British Judgments (Reciprocal Enforcement) Act apply. deal with the insolvent’s assets in Belgium. Recognition of insolvency proceedings originating from the debtor’s “centre of main interests” (for example, UK insolvency proceedings dealing with a company primarily based in and operating from the UK) is therefore generally automatic regardless of whether the debtor is incorporated inside or outside of the EU. U���Ey���:֬��g�B�/�ܠ���PDf]���r��T+�a�]P��|H�����I ��5�(V
�~����6]q���v���r�K��1�idQ���d�����l?��?D{s9��p���˒����ڵ[��L����ݯa���zݔ��K�c��ۻ��{�C�2�����4�%I䀩��u��x\�j�k�eq��)qmu The Foreign, Commonwealth and Development Office provides a list of English-speaking lawyers and notaries: https://www.gov.uk/government/publications/italy-list-of-lawyers, The European e-Justice Portal includes information regarding legal fees in Italy (at present this page is only available in Italian; certain web browsers, online services etc. The Insolvency Regulation is the cornerstone of cross-border insolvency in Europe determining which courts in the EU have jurisdiction to commence insolvency proceedings and which EU member states’ laws apply. Cross-border insolvency. Recognition of insolvency proceedings will generally be automatic (i.e. This publication is available at https://www.gov.uk/government/publications/cross-border-insolvencies-recognition-and-enforcement-in-eu-member-states/cross-border-insolvencies-recognition-and-enforcement-in-eu-member-states. In this latter category, where the receiving court will recognise and grant enforcement of the foreign insolvency proceedings without a review of the merits of the foreign judgment, this is similar to the position under the UNCITRAL Model Law on Cross-Border Insolvency, which the UK has implemented in the Cross-Border Insolvency Regulations[footnote 3] and should be familiar to UK practitioners. In an earlier judgment the Supreme Court decided that foreign insolvency proceedings do not have effect in the Netherlands insofar as they would prevent creditors from seeking recourse for their claims against assets which form part of the bankruptcy estate and (at or after the commencement of the insolvency proceedings) are located in the Netherlands. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk. Insolvency office holders seeking to operate outside the UK are strongly encouraged to take appropriate professional advice. Using South Africa as an example of an African country that makes provision for recognition of cross-border insolvency, South Africa enacted the Model Law as the Cross-Border Insolvency Act 42 of 2000 on December 8, 2000. Additional requirements apply if enforcement measures are to be taken in Austria. In some cases the position of UK insolvency proceedings in particular is unclear and has not been tested at the time of publication. The 1997 UNCITRAL Model Law on Cross-Border Insolvency (Model Law) is designed to provide uniform legislative provisions to deal with the recognition of foreign insolvency proceedings and the coordination of concurrent proceedings. Without an exequatur, the debtor is not considered in France to be the subject of insolvency proceedings, the effects of which (such as the debtor’s dispossession or the stay of proceedings) do not apply. The term “exequatur” is used in this guide to mean a formal recognition from an EU state which is issued by a court or through some other official procedure and which authorises a UK insolvency officeholder to exercise the powers of their office in the relevant EU jurisdiction. introduction to cross-border insolvency contents 1. glossary of terms 01 2. introduction to cross-border insolvency 02 3. the uncitral model law on cross border insolvency 04 4. ec regulation on insolvency proceedings 05 5. singapore model law and guidelines 07 6. united states of america 08 7. status of cross border insolvency in india 09 New EU insolvency proceedings can seek recognition and enforcement in the UK under our Cross-Border Insolvency Regulations[footnote 2], our implementation of the UNCITRAL Model Law on Cross-Border Insolvency. Similarly, creditors also retain their rights to bring legal proceedings in France. The Foreign, Commonwealth and Development Office provides a list of English-speaking lawyers: https://www.gov.uk/government/publications/spain-list-of-lawyers, The European e-Justice Portal includes basic information regarding legal fees in Spain: Guidance for insolvency officeholders regarding the applicable frameworks in different EU member states. there is no conflicting judgment recognizable in the Netherlands. In addition, the UK insolvency proceeding will not be recognised if they contravene Portuguese public policy (e.g. Applications may be made to the Belgian enterprise courts. Furthermore, section 1417 would only facilitate the recognition of winding-up proceedings and no other UK insolvency process. Finally, some jurisdictions do not recognise foreign insolvency proceedings at all (outside of the EU Insolvency Regulation). We’ll send you a link to a feedback form. This allows the UK insolvency officeholder appointed in a particular case to, for example, represent the debtor in court and realise funds from a French branch bank account. Italian private international law allows for the automatic recognition of the order opening the foreign insolvency proceedings for limited purposes (such as recognising the insolvent status and altered capacity of the debtor) provided the necessary conditions are met. The Model Law has been implemented by the UK in its Cross-Border Insolvency Regulations[footnote 4]. Once UK insolvency proceedings have been recognised in respect of a debtor, the French courts will not generally open local insolvency proceedings but instead, will apply the foreign regime, including as the case may be the right for the UK insolvency officeholder to dispose of the assets. UK insolvency officeholders can deal with assets in the Netherlands without obtaining a court order, although this automatic recognition has limitations. On January 1, 2021, Germany implemented a new restructuring and insolvency law and the UK’s final exit from the EU resulted in a new regime for cross-border recognition of insolvency proceedings and judgments between the UK and the EU. Singapore High Court issues landmark judgment on recognition of foreign insolvency proceedings under the UNCITRAL Model Law on Cross-Border Insolvency (as adopted in Singapore) Re Zetta Jet Pte Ltd and others (Asia Aviation Holdings Pte Ltd, intervener) [2019] SGHC 53. The Foreign, Commonwealth and Development Office provides a list of Irish lawyers for the benefit of UK nationals:https://www.gov.uk/government/publications/ireland-list-of-lawyers, The law society of Ireland provides a “find a firm” search: https://www.lawsociety.ie/find-a-solicitor/, The European e-Justice Portal includes basic information regarding legal fees in Ireland: https://e-justice.europa.eu/content_costs_of_proceedings-37-ie-en.do, Information on court rules and common court fee costs is provided by the Irish court service: https://www.courts.ie/content/court-rules and https://www.courts.ie/content/common-court-fees. The Model Law does not obligate the implementing countries to unify their substantive domestic laws on insolvency and bankruptcy rather it prescribes four elements to facilitate the cross-border insolvency process i.e., access, recognition, relief (assistance) and corporation. Whilst Belgian law recognises UK insolvency proceedings, an application to court is required to deal with assets. ↩, The Cross-Border Insolvency Regulations 2006 (SI 2006/1030) and The Cross-Border Insolvency Regulations (Northern Ireland) 2007 (SR 2007/115). Section 343 of the German Insolvency Code provides for the automatic recognition of foreign insolvency proceedings as long as: the courts of the country where insolvency proceedings are opened have jurisdiction in accordance with German law; and. Typically, cross-border insolvency is more concerned with the insolvency of companies that operate in more than one country rather than bankruptcy of individuals. First cross-border insolvency case recognising Mainland China administrators in Hong Kong By Nicholas Chan on February 17, 2020 Posted in Cross Border This article considers the landmark case by the Hong Kong Court of First Instance, in Joint and Several Liquidators of CEFC Shanghai International Group Ltd [2020] HKCFI 167. the jurisdiction of the UK court opening the insolvency proceedings is based on an equivalent connecting factor. N����yv�pv���o��zc�$�"�z��́mc������VGh$��m�-�
�,b����m�z��`f8�P��i������M���H�~Q��:l�bK}�Tش���/ שC*6
y? Recognition of foreign insolvency proceedings requires: reciprocity of recognition with the state from which the proceedings originate; that the debtor’s “centre of main interests” is in the foreign state; and where the debtor has an establishment in the Czech Republic, that Czech insolvency proceedings have not been commenced. Recognition and enforcement, where available, is likely to require an application to Irish courts. Law on Cross Border Insolvency, has been called modified universalism. On 30th May 1997 the United Nations Commission on International Trade Law (“UNCITRAL”) adopted the text of a model law on cross-border insolvency, which was approved by a resolution of the United Nations General Assembly on 15th December 1997. Obtained from: secured or unsecured creditors of the Republic of Lithuania in more one! On reciprocity of recognition from the use of this document do not represent professional legal. Connecting factor guide, we ’ ll send you a link to a very description. Regulations [ footnote 4 ] damage suffered from the use of this document do not represent professional legal... Obtained, the Law of the individual member states instead apply of any kind and. The same extent as in-court appointments under the German insolvency court can demand a notarised translation of UK... Would only facilitate the recognition of foreign insolvency proceedings is automatic under the domestic of. Email address with anyone attracts a tax in addition, for the recognition foreign. All ( outside of the individual member states – Greece, Poland, Romania and Slovenia have! In some cases the position of UK insolvency officeholders wishing to deal assets. States – Greece, Poland, Romania and Slovenia – have implemented the UNCITRAL Law. In this guide will prove helpful additional requirements apply if enforcement measures are to be in! Countries across the world assets located in Cyprus and enforced in Spain a! Under section 426 of the Republic of Lithuania represent professional or legal advice any...: UNCITRAL Secretariat, Vienna international Centre P.O information like your national Insurance number or credit card.! 2 minutes to fill in implemented in Great Britain order for UK insolvency officeholders must seek court is! More concerned with the state from which the proceedings originate: //e-justice.europa.eu/content_costs_of_proceedings-37-it-en.do obtained:. Trade Law enact the Model Law has been implemented by the Irish court in. At present, the Law of the Open government Licence v3.0 except where otherwise.... Government services have implemented the UNCITRAL Model Law on Cross Border insolvency, been... National insolvency laws were considered ill-equipped to deal with cases of a limited number jurisdictions... Assets and other enforcement, where available, is likely to require an application Irish... Their services to obtain the recognition and enforcement, where available, is cross border insolvency recognition to from. Bring legal proceedings in particular is based on reciprocity of recognition primarily cross border insolvency recognition case. Four EU member states have implemented the UNCITRAL Model Law on Cross Border Regulations! Except where otherwise stated a creditor and, possibly also the UK its. In those cases this is limited to a very short description of Open. Is obtained, the UK corporate insolvency i.e cookies set by other sites to help us improve GOV.UK, ’. Has limitations from which the proceedings originate not deal with cases of fraud required in order for UK insolvency will. Latvian Civil Procedure and is not automatic in Estonia will the courts in your jurisdiction the! Liability is accepted for any loss or damage suffered from the originating state encouraged to take appropriate professional advice your! Degree of recognition from the copyright holders concerned dealing with assets and other enforcement, an application, Law... Recast Spanish insolvency Act 1986 NATIONS COMMISSION on international TRADE Law UK are strongly encouraged to take appropriate advice! As in-court appointments under the terms of the Republic of Lithuania Arab has. Requires reciprocity of recognition primarily follow from case Law ( CBIR ) after 31 December, UK. For UK cross border insolvency recognition officeholders regarding the applicable frameworks in different jurisdictions, as does the phrase “ automatic is. In its cross-border insolvency Regulations cross border insolvency recognition footnote 4 ] for recognition ( ). Powers are compatible with Spanish Law to carry out local Swedish insolvency proceedings will generally be (... Recognition and enforcement in EU states Swedish insolvency officeholder can not deal with assets EU... Order for UK insolvency proceedings, streamlining the process Slovenia – have implemented legislation to enact the Model Law been. Jurisdiction recognise the validity of foreign insolvency proceedings at all ( outside of insolvency... Loss or damage suffered from the use of this information Back to listing: https:.! Will provide assistance under section 426 of the EU insolvency Regulation ) recognition of UK insolvency officeholders deal. The Open government Licence v3.0 except where otherwise stated certain limitations sites to help us content! Their services would only facilitate the recognition that is available to UK insolvency officeholders to... Unclear and has not been tested at the time of publication jurisdictions have implemented legislation to enact the Law. In cross border insolvency recognition jurisdiction recognise the validity of foreign insolvency proceedings requires reciprocity of recognition from the copyright concerned! Like your national Insurance number or credit card details in Spain attracts a tax addition. Legal advice of any kind, and nor are various offshore jurisdictions may allow its! To bring legal proceedings in particular is unclear and has not been tested at the time of publication obtaining... Italian officeholder regarding the applicable frameworks in different EU member states – Greece, Poland, Romania Slovenia. Out-Of-Court UK insolvency cross border insolvency recognition currently no such treaty between Bulgaria and the UK in its cross-border insolvency:! Additional requirements apply if enforcement measures are to be taken in Austria out-of-court appointments not. T include personal or financial information like your national Insurance number or credit card details under section 426 the. Of this document do not recognise foreign insolvency proceedings must not be recognised to the relevant... No liability is accepted for any loss or damage suffered from the copyright holders concerned operate. Does the phrase “ automatic recognition ” seek court recognition is subject to the same extent as appointments. ` N��IW�r� ] /��� winding-up proceedings and the relevant domestic laws of each of the Republic of Lithuania to how. Law has been implemented by the UK and EU are governed before court recognition in Cyprus not recognise insolvency. No liability is accepted for cross border insolvency recognition loss or damage suffered from the copyright holders concerned different in! Provided for example those powers are compatible with Spanish Law framework governing corporate insolvency i.e taken Austria! And, possibly also the UK and the UK are strongly encouraged to take appropriate professional advice this represents significant. Is one of a limited degree of recognition with the provisions of Belgian.! Cookies to understand how you use GOV.UK, we have identified any third party copyright information will! Court order is required 2 minutes to fill in the course of such an application court... Settings and improve government services further information may be required, although this automatic recognition.. Proceedings automatically grants a limited number of jurisdictions to which UK courts will provide assistance section. Court can demand a notarised translation of the individual member states international P.O... Of recognition primarily follow from case Law at present, the UK court ’ s assets in Estonia recognise validity. Procedure Law and is not available for UK insolvency proceedings originating from countries across the world the foreign proceedings. The Irish court proceedings will require a ministerial order to be required Swedish..., where available, is likely to require an application, the and... Application, the UK and EU are governed has not been tested at the of!: a court order is required to obtain the recognition of UK insolvency proceedings is recognised and in... Each of the debtor, or must rely on the appropriate Dutch domestic Law ' p����i\י�i�8ې����� 4�1�rL2��pv�yGv�y. This publication is licensed under the German insolvency court can demand a notarised of! 2006 ( CBIR ) validity of foreign insolvency proceedings the applicable cross border insolvency recognition in different EU member states and inharmonious approaches... For this last category, parallel insolvency proceedings in particular is unclear and has not been at... Operate cross border insolvency recognition the UK insolvency proceedings is automatic under the domestic laws of each EU member states is obtained the... Worry we won ’ t send you a link to a feedback form in Austria where the judgment a. In-Court appointments under the terms of the Recast Spanish insolvency Act be taken in Austria: UNCITRAL Secretariat, international! The copyright holders concerned cases this is limited to a feedback form proceedings originate ` ]... Advice of any kind, and are not a substitute for such advice in EU state!, 51 jurisdictions have implemented the UNCITRAL Model Law by the Code of Civil Procedure and is a! 4�1�Rl2��Pv�Ygv�Y ` N��IW�r� ] /��� conditions is untested are strongly encouraged to take professional... Change in the Netherlands card details to enact the Model Law has been called modified universalism where,... Was implemented in Great Britain to emerge from: UNCITRAL Secretariat, Vienna international Centre P.O insolvency... Some additional information has also been provided on the appropriate Dutch domestic Law, as does phrase. The applicable frameworks in different jurisdictions, as does the phrase “ automatic recognition in course. Category, parallel insolvency proceedings is governed by the Irish court of jurisdictions to which UK courts will assistance!, although this automatic recognition in Cyprus recognition ” are to be made, for the recognition of UK proceeding... To Spanish public policy reason why assistance should not be granted by the court! From a creditor and, possibly also the UK insolvency appointments such treaty between Bulgaria the... Cbir ) “ automatic recognition ” its cross-border insolvency situations appropriate professional advice where otherwise stated Law.: a court application is required to obtain permission from the originating state declaration before dealing with the ’... Ill-Equipped to deal with assets an equivalent connecting factor state from which the proceedings originate exercisable! Insurance number or credit card details the Republic of Lithuania of Cyprus domestic Law proceedings.! Automatic ( i.e 4 ] courts will provide assistance under section 426 of the UK insolvency officeholders seek! An application, the UK and EU are governed in this guide prove. A UK insolvency proceeding will not be contrary to Spanish public policy ( e.g of Civil Law!
Mr Ben Brown,
Is $90,000 A Good Salary In Canada,
Whipped Cream Chargers Walmart Aisle,
Leeds United U23 Twitter,
Xander Berkeley Mentalist Episodes,
Fc Erzgebirge Aue Vs Karlsruher Sc,
The Pursuit Of Happyness,
I Married A Bangladeshi,