Bridging the Channel: Mutual Recognition of Proceedings Between the UK & EU

Jat Bains and Simon Beale of Macfarlanes share that varied post-Brexit approaches to recognition have produced divergent outcomes, such as Ireland’s recognition of a UK administration and Germany’s refusal to recognise a UK restructuring plan, with future cooperation likely to depend on careful navigation of COMI rules, reciprocity concerns and the continued influence of the rule in Gibbs.

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