GRR Live, Hong Kong: Scheme jurisdiction in a multi-jurisdictional context
The Gibbs rule - that a contractual debt can only be compromised under the law governing it - has received a fair amount of negative press since a Singapore court declined to apply it in Pacific Andes last year. But in his keynote at GRR Live Hong Kong last month, Companies Court judge Jonathan Harris said the rule had been helpful locally in providing a “sufficient connection” for the sanctioning of schemes relating to foreign companies.
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