Abstract
The one principle that is central to EU legislation on private international law, is that of mutual trust. States leaving the Union also leave that realm of mutual trust. That was the fate of the United Kingdom, as it officially left the union on 31 January 2020. UK Cross-border insolvency procedures started after the ending of the transition period on 31 December 2020 do not benefit from that principle anymore. The effect of these procedures in the different EU Member States is regulated by their own residual national framework. This article seeks to compare the recognition and execution frameworks of Belgium, Germany and the Netherlands. The question is raised whether further harmonization is needed.
Sign-in/Register to access full text options 
Free) 
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Schedule a call
