CENTER OF MAIN INTERESTS OF THE DEBTOR IN CROSS-BORDER INSOLVENCY
The article is dedicated to the analysis of the institute "center of main interests of the debtor" as a criterion for determining the debtor`s home country. The author analyzes the existing concepts of legal regulation of international bankruptcy, identifies the elements that constitute the COMI-standard, considers the Romano-German and Anglo-Saxon approach to the "presumption rule", and also indicates the problem of non-compliance of the COMI-standard with the theoretical grounds for determining the debtor`s home country.