الإفلاس العابر للحدود : دراسة تحليلية مقارنة بين القانون الأردني والقطري في ضوء قانون الأونيسترال النموذجي

الملخص EN

Cross-border insolvency has become an important topic as a result of major economic and commercial developments taking place in the world.

This is especially the case where the merchant (whether an individual or a company) is able to have more than one place of work in numerous countries.

This is often referred to within private international law as ‘commercial domicile’ and it differs from the merchant's place of residence or place of origin.

Furthermore, commercial activities for companies have expanded significantly, in relation to their activity and business, resulting in the establishment of holding companies within the state.

This research examines specific areas within the subject of cross-border insolvency by focusing on the nature and principles of the rule of insolvency as well as exploring the problems relating to the implementation of insolvency rules within both Jordan and Qatar in light of the UNCITRAL model law for international company insolvency.