The Effects of Issuing a Bankruptcy Order in the Legal Systems of Iran, England, and the United States: A Legal Analysis of Composition Agreements and Existing Challenges

Document Type : Original Article

Authors

1 Department of Law, Go. C. Islamic Azad University, Gorgan, Iran.

2 , Department of Law, Payame Noor University, Tehran, Iran.

3 Department of Law, Go. C., Islamic Azad University, Gorgan, Iran.

Abstract

Compromise agreements are of great importance in international systems and are considered as an important tool for solving financial problems in a way that they contribute significantly to economic prosperity by preventing the complete liquidation of economic units. Therefore, a comparative study of compromise agreements in different legal systems such as Iran, the United States and the United Kingdom can contribute significantly to the reform of commercial law laws and regulations in this field. The aim of the present study is to examine the economic policies and challenges in compromise agreements and to apply this issue in the legal systems of Iran, the United States and the United Kingdom. The main question is: "What is the main challenge of economic bankruptcy in compromise agreements in the legal systems of Iran, the United States and the United Kingdom?" It seems that the main challenge in the American and Iranian systems is debt security, while in the United Kingdom, restoration of credit is considered the main challenge. The present study has used a descriptive-analytical method, international legal documents and library studies. The research findings showed that in all three countries, politically, composition agreements play a vital role in resolving debts and rebuilding the financial situation of debtors, but each of these countries faces its own challenges. In Iran, there are problems such as lack of transparency in assets and resistance from some creditors. In the United States, challenges such as legal complexities and problems related to creditor cooperation are raised. The United Kingdom also faces issues such as administrative complexities and economic impacts of composition agreements, despite a modern legal framework.

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