Resumen de Rechtsvergleichende Betrachtungen de lege ferenda zum 11. Titel des IPRG
The following article analyzes the provisions on international insolvency law (recognition and enforcement of foreign insolvency proceedings in Switzerland) of the Swiss PIL Code (Title 11) from a comparative perspective. The conceps underlying the 11th Title of the Swiss PIL Code are thereby set side by side with the most relevant international instruments in this field, these being the European Cross-Border Insolvency Regulation (EuInsReg) and the UNCITRAL Model Law on Cross-Border Insolvency. A comparison of some key elements of the selected sources allows to draw some preliminary conclusions as to the need for reform of the 11th Title of the Swiss PIL Code.
