13.01 As was the case with solvent set-off in civil law,1 insolvency set-off in civil law is not governed by one single legal system. Therefore, this chapter cannot be merely a mirror image of the analysis of insolvency set-off in English law.2 13.02 Insolvency set-off raises a number of issues linked to the law applicable to insolvency set-off. Since the way set-off operates in insolvency proceedings is largely governed by the way it operates between solvent parties,3 and since solvent set-off operates in quite different ways from one legal system to another in...
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