Jaw-dropping Die Nationale Und Internationale Gläubigeranfechtung Nach Deutschem Und Französischem Recht Collection [C0yAkDzl]

Comparative Analysis of International Creditors' Set-Off

This comprehensive work delves into the complexities of cross-border creditors' set-off under German and French law. Focusing on the reform of bankruptcy law, it examines the pivotal provision of § 19 of the Set-Off Act, which establishes a conflict rule for the applicable international set-off law. With a detailed analysis, the author concludes that a blanket application of § 19 AnfG may not always lead to appropriate solutions. This insightful study is a must-read for legal professionals and scholars interested in the nuances of international credit law.

Key Features and Benefits

This book offers a unique comparative approach, providing an in-depth understanding of the legal frameworks in Germany and France. Key features include:

• Examination of § 19 Anfechtungsgesetz and its implications for international set-off law
• Analysis of the limitations and challenges of the provision
• Proposals for a carve-out clause to address fraudulent actions in foreign jurisdictions

These features make the book an invaluable resource for professionals navigating the complexities of international credit disputes.

Practical Applications and Future Prospects

The study not only offers a critical analysis of existing laws but also provides a forward-looking perspective on the potential regulation of international creditors' set-off at the European level. Practical benefits include:

• Enhanced knowledge of international credit law principles
• Improved ability to handle cross-border set-off cases
• Insight into emerging trends and future developments

This book is an essential tool for legal practitioners, academics, and anyone involved in the field of international credit law, ensuring a comprehensive understanding of the subject matter.