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Sebastian Zeeck
Das Internationale Anfechtungsrecht in der Insolvenz
Die Anknüpfung der Insolvenzanfechtung
[T The International Right of Avoidance in Insolvency Proceedings. The Connecting Factor to Insolvency Rescission.]
2003. XVII, 152 pages. Published in German.
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- 978-3-16-158528-9
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Summary
Which law should be applied for judging the voidability of legal acts which cause damage to assets in the case of cross-border insolvencies? Sebastian Zeeck examines the three models which have been discussed up to now and rejects all three. In their stead, he suggests a new one: an alternative connection which invokes the law most favorable to avoidance, thus giving rescission better chances of success in international insolvency procedures which are, by nature, especially prone to manipulation.