ABSTRACT
This chapter seeks to appraise, through a comparative perspective, the unique institutional and regulatory model adopted and practised by the Dubai International Financial Centre (DIFC) and the Qatar Financial Centre (QFC), with respect to insolvency law. The key institutional innovation of these two financial centres is their transplanting and operation of laws based on the English Common Law, independent of their national legal systems. There are three dimensions of comparison in this chapter: (1) comparing the centres’ rules and regulations with their UK counterparts to reveal the degree of legal transplantation; (2) comparing the centres’ rules and regulations with their domestic counterparts to explore a potential regulatory gap between the two systems and (3) comparing the regimes of the DIFC and QFC to reveal their potentially different experience in transplanting (insolvency) law from the UK.
