Maritime Cross-Border Insolvency: An Analysis for Germany, England & Wales and the USA

Maritime Cross-Border Insolvency: An Analysis for Germany, England & Wales and the USA
ISBN-10
3030117936
ISBN-13
9783030117931
Category
Law
Pages
154
Language
English
Published
2019-04-03
Publisher
Springer
Author
Erik Göretzlehner

Description

This book provides an analysis and comparison of international insolvency rules, maritime laws and their inevitable intersection in maritime cross-border insolvencies. Until today, the on-going shipping crisis resulted in the insolvency of numerous shipping companies all over the world. The tensions arising between the legal systems of maritime and insolvency law, paired with conflicts of law in maritime insolvencies, are a major source of legal uncertainty and risk. In 2010, the Comité Maritime International installed an international working group on international maritime insolvencies and until today it is work in progress. This book gives an overview on maritime insolvencies, with a focus on Germany, England & Wales and the USA, and assesses the chances of achieving meaningful harmonization in the complex scenarios, where ships as mobile assets add a further complication to international insolvency proceedings.

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