Abstrakt
The publication provides an overview of how retention of title works in several EU member states as well as other countries. Given the fact that despite which governing law rules a specific cross-border insolvency proceeding, retention of title will have its own legal regime (i.e. a different choice of law shall apply), makes this topic rather practical for anyone dealing with cross-border insolvency proceedings.
The chapter on how retention of title works in the Czech republic focuses around article 260 of the Czech Insolvency Act and describes how retention of title is dealt with when the debtor goes bankrupt as either the seller or the purchaser.