ABSTRACT
This study will not be the first to have raised the issue of holding company liability. Nor will this study be the only one to have submitted concrete proposals for the reform of English law. Indeed, various recommendations for reform in this area o f the law have been put forward over a number of years.1 Some of the recommendations have been rather wide-ranging. Others have been more narrowly circumscribed. The principal ideas which have been developed are the following :
(1) Each company in a corporate group should be jointly and severally liable for the debts due to external creditors of insolvent affiliates.2
