Abstract
The framework in which cross-border insolvency and rescue law is construed focuses on the universalism and territorialism divide, which originated in academic scholarship in the United States. This paper argues that this framework is not the most appropriate for the European Union at present and should be replaced by a theoretical framework tackling the sui generis nature of the EU.
Original language | English |
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Pages (from-to) | 713-728 |
Number of pages | 16 |
Journal | International Company and Commercial Law Review |
Volume | 12 |
Publication status | Published (VoR) - 1 Dec 2018 |