1E9Ct5D

assess the assets that are located within the subsidiary to be liquidated, as it will inpractice lose control over such assets.IV. ConclusionThe twenty-eight members of the European Union have their own insolvency laws.Insolvency law is not consistent throughout the EU, and is certainly not consistentwith the U.S. Bankruptcy Code. Although almost all EU member countries arebound by the EU Regulation on Insolvency, this Regulation only helps determine theCentre of Main Interests of the debtor for purposes of determining the proper forumfor the insolvency proceeding. It does not provide any substantive insolvency law.A creditor involved in a cross-border insolvency proceeding set in a European Unionmember country has certain rights, but those rights might vary from country tocountry. Consequently, the creditor needs to engage professionals who are familiarwith the substantive law that controls the foreign insolvency proceeding.59