Four models for rescue: convergence or divergence in European insolvency laws? Part 2

This, the second part of a two part article, traces the development of corporate rescue procedures in France leading to Law 2005-845 of 26 July 2005 on the Preservation of Enterprises. Explains provisions of the 2005 law, highlighting the procedure of preservation, or "sauvegarde", and the parallel procedure of judicial rescue. Notes similarities and differences between the insolvency law reforms in England, Spain, and France, and questions whether a fourth model at EU level exists, and the extent to which harmonisation is possible.