A Comparison of UK, US and German Insolvency Codes

Julian R. Franks, Kjell Nyborg and Walter N. Torous

Financial Management, 1996, vol. 25, issue 3

Abstract: The bankruptcy codes of the United States, the United Kingdom and Germany differ concerning who is permitted to control the debtor in bankruptcy and as to the ability of the debtor to arrange new financing while in bankruptcy. This study compares the efficiency of these three bankruptcy codes against a set of benchmarks.

Date: 1996
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