The UK is a
well-established jurisdiction for cross border insolvencies, both within the EU
and the rest of the world. The English Court’s jurisdiction in cross border
insolvency cases derives from one of four key sources: the EC Council Regulation 1346/2000 (EUIR), the Cross Border Insolvency Regulations 2006, Section 426 of the Insolvency Act 1986, which modified the UK law
under Article 3, and the common law.1 The
main piece of EU legislation that governed this area of law was the EC Council
Regulation EUIR, or “the Insolvency Regulation” and the UNCITRAL
Model Law (“Model Law”), which in the UK has been implemented by way of the
Cross Border Insolvency Regulations 2006 (“CBIR 2006”).2

1 Note too, Foreign Judgements
(Reciprocal Enforcement) Act 1933, which provides for enforcement in England of
civil and commercial judgements made in designated jurisdictions provided that
the judgement has been registered under the statute.

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2 Marelli,F (2016) “What will
be the impact of Brexit on insolvency proceedings?”,