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The problem of resolving cross-border insolvency disputes by Russian courts using foreign experience is analyzed in the article. The author describes how the problem of cross-border insolvency is resolved according to contemporary Russian legislation. It is noted that Russian courts are forced to independently develop approaches to dispute resolutions on cross-border insolvency in the absence of certain provisions in Russian law. The invocation of the concept “Center of Main Interests” (COMI) based on the analyses of the Russian courts’ cross-border insolvency precedents and the study of oversea conceptions is examined. The author comes to the conclusion that in order to justly resolve disputes on cross-border insolvency, it seems promising to use foreign experience by domestic courts.

Prospects for the application of the provisions of foreign and international law for disputes on cross-border insolvency by the Russian courts