Restructuring Plans · glossary
A court abroad giving effect to an English court’s order. No EU rule makes a Dutch court recognise Valkenrade’s plan. Dutch counsel relies instead on the EU rule that a contract’s own law decides how its obligations end, and both plan debts are under English law. Explanatory Statement, paragraph 8.3 · Chapter 10
Explained in Chapter 10, Restructuring Effective Date and Recognition Abroad, of Restructuring Plans.
The court’s order works in England. Valkenrade is based in Rotterdam, and a creditor that dislikes the order may sue it there instead. So the order needs recognition: a court abroad giving effect to it.Read Chapter 10, Restructuring Effective Date and Recognition Abroad →
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