ABSTRACT
In compliance with the guiding principle based on the coordinated approach adopted by both the Regulation and the Model Law, cooperation and communication is the cornerstone of China's Inter-Regional Cross-border Insolvency Arrangement (CICIA). In accordance with the limits on the exercise of judicial authority connoted by comity, public policy is the only exception to recognition under CICIA, which needs to be interpreted in a self-restrained manner. CICIA set out for a balanced approach by choosing the recognition-based system as its overriding objective. Cross-border insolvency agreements are recommended as a key mechanism that can be utilized by the courts and insolvency practitioners to coordinate the interregional insolvency proceedings involving a single debtor and enterprise groups under CICIA. Abiding by the principle of collectivity and seeking an integrated regional legal order, it is intended to establish a uniform and comprehensive interregional cooperation arrangement in China.
