Abstrakt
This proceeding is dedicated to the question of international insolvency law, both from the perspective of European legal regulation and two national legal regulations, namely Czech Republic and Germany. The aim of this proceedings is the evaluation of how both national legal regulations react to the European one and their functioning in cases, in which the European legal regulation will not be applicable.
In this regard, first the European Insolvency Regulation is introduced, together with the conditions of its application (with the focus on the term "centre of the debtor's main interests"). Secondly, the legal regulations of the Czech Republic and Germany are evaluated.
The conclusion is then reached based on the legal comparison, that despite certain differences can both national legal regulations be considered satisfactory, especially their aim to eliminate the different handling of the "european" and "non-european" cases through the adoption of the rules of conflict-of-law rules contained in the Insolvency regulation directly into the national legal regulation of both states. .