Institutioneller Gläubigerschutz im Recht der kleinen Kapitalgesellschaft

Against the background of the question of which domestic creditor protection instruments should be applied to an English private limited company which has its seat in Germany, Alexander von Rummel asks whether and where English creditor protection law falls short in comparison with German law. In providing a comprehensive functional categorization of creditor protection instruments, the author studies company law and related fields, such as insolvency law. His analysis is based on recently reformed English law and includes current reform tendencies in Germany. The author concludes with a critical assessment of the main German proposals for reform from the perspective of creditor protection.