To Be Or Not To Be (Solvent) - A Comparative Analysis Of Singapore, UK, US, And Australia On Recognising Foreign Proceedings Under The UNCITRAL Model Law

Mayer Brown

The recent case of Ascentra Holdings, Inc v. SPGK Pte Ltd [2023] SGCA 32 (Ascentra) has drawn a line in the sand in the Singapore court's interpretation of the UNCITRAL Model Law on Cross-Border Insolvency (UNCITRAL Model Law), as incorporated in the Third Schedule of the Insolvency, Restructuring and Dissolution Act 2018 (IRDA) to create the Singapore Model Law.

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