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Set-Offs in Cross-Border Bankruptcy: A Comparative Study of the United States, the European Union, Germany, Austria, and Croatia

Set-off, or the legal right to discharge reciprocal obligations in bankruptcy, is recognized in the U.S. and Europe. But, despite its broad availability, this right has different characteristics in each jurisdiction. As a result, this article offers a comparative analysis of this right in the United States and Europe. By doing so, it identifies inconsistencies and ways to overcome any such issues with respect to how the law of set-offs is applied in a transnational context.

set-off, cross-border, bankruptcy, US Bankruptcy Code, Recast Regulation

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