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A Centro Einaudi report on bankruptcy in Italy • 3 / Documentation: the reforms in France and Germany and the situation in the United Kingdom
This article proposes to relate the reforms underway and the current law as far as bankruptcy procedures are concerned in the main European countries: France, Germany and the United Kingdom. The comparative analysis of bankruptcy law regulation gives a better perspective in understanding the best route to follow for the Italian legislator who wants to return to the reform proposed by the Amato government proposing a new reform project in bankruptcy law. A reform that is increasingly insisted upon by the operators given the time and costs involved in ‘bankruptcy’ according to the Italian model. The conclusion highlights the elements to the European bankruptcy law and the Amato reform project.