Review of Company Rescue Mechanisms
Joint DTI / Treasury Review of Company Rescue Mechanisms
A Review of Company Rescue and Business Reconstruction Mechanisms
ANNEX B
CREDITOR RIGHTS AROUND THE WORLD – Porta, Schliefer, Lopez de Silanes and Vishny
– Journal of Political Economy, 1998
Country
No Automatic Stay Secured Creditors First Paid Restrictions For Going into Reorganisation Management Does Not Stay in Reorganisation Creditor Rights Legal Reserve Required as a Percentage of Capital
A. Creditor Rights (1=Creditor Protection Is the Law)
Australia
0
1
0
0
1
.00
Canada
0
1
0
0
1
.00
Ireland
0
1
0
0
1
.00
New Zealand
1
0
1
1
3
.00
United Kingdom
1
1
1
1
4
.00
United States
0
1
0
0
1
.00
France
0
0
0
0
0
.10
Greece
0
0
0
1
1
.33
Italy
0
11
1
0
2
.20
Netherlands
0
1
1
0
2
.20
Portugal
0
1
0
0
1
.20
Spain
1
1
0
0
2
.20
Austria
1
1
1
0
3
.10
Germany
1
1
1
0
3
.10
Japan
0
1
0
1
2
.25
Denmark
1
1
1
0
3
.25
Finland
0
1
0
0
1
.00
Norway
0
1
1
0
2
.20
Sweden
0
1
1
0
2
.20
[ Responses To ] [ Section 1 ] [ Section 2 ] [ Section 3 ] [ Section 4 ] [ Section 5 ] [ Section 6 ] [ Section 7 ] [ Section 8 ] [ Section 9 ] [ Section 10 ] [ Bibliography ] [ Annex A ] [ Annex B ]
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