ABSTRACT
This chapter demonstrates the features and problems of the cross-border insolvency system in each region in depth through legislation and case law. It starts with a general overview of the local insolvency system. The chapter presents comparison and summary of the cross-border insolvency systems among the four regions. It reviews the corporate insolvency system of the Mainland including the history of the corporate insolvency system and a general description of the current insolvency system. The former corporate insolvency system was a dual national bankruptcy system according to different types of debtors. The chapter explains the difference between the corporate insolvency system and the individual bankruptcy system in Hong Kong. It focuses on the development of cross-border insolvency in Hong Kong by reviewing the relevant legislative proposals and analyzes the hesitation in accommodating a cross-border insolvency regime.
