Internationale Insolvenzaufrechnung

Christoph Jeremias deals with the circumstances under which a right to a set-off still exists after the insolvency date and examines the origin, role and legitimacy of the ordinary and the insolvency set-off. Looking at this issue from the perspective of comparative law, the author describes the set-off and insolvency set-off rules in the main European countries (Germany, England, France, Italy, Switzerland and Austria) and then provides a commentary on the new European and German rules concerning insolvency set-offs in international insolvency proceedings.