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This second edition of The International Insolvency Review once again offers an in-depth review of market conditions and insolvency case developments in a number of key countries. Building on the first edition, coverage has been expanded to bring the total number of jurisdictions covered to 31.
While a large and increasing coterie of countries have adopted legislation based on the UNCITRAL Model Law, with its universalist vision of global recognition of a single controlling “main” or home country insolvency proceeding, countries continue to find it difficult to allow the rules of the foreign main proceeding to control within their borders. In addition, neither the Model Law, nor other enactments, like the European Union’s Regulation on insolvency, provide the tools necessary for consolidated administration of insolvencies involving multiple legal entities in a corporate group, with operations, assets and stakeholders under different corporate umbrellas in different jurisdictions. It is difficult enough for local authorities and local commercial interests to relinquish local control of the treatment of a single foreign company’s local assets and stakeholders. It is almost impossible for them to do so with respect to a locally organized entity with local operations, employees, assets and creditors. Embedded expectations that local law, local courts, local procedures and local insolvency administrations will apply are simply too strong.