Law
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.]
Published in German.
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.