Even though the rehabilitation schemes of Australia, Germany and New Zealand trace back to Chapter 11 of the American Bankruptcy Code, they vary in their objects. The law of Australia and NZ gives priority to the rescuing of the business, the German proceeding aims for the best return for the creditors. There are major differences between the schemes: In Germany, there is only one uniform insolvency procedure whereas Australia and NZ have separate liquidation procedures; this variety gives room for abuse. Secondly, the involvement of the German insolvency court is mandatory. In...