Foreign bankruptcies do not automatically control China assets — recognition and local proceedings are the fight.
When debtors span borders, China practice involves recognition/assistance questions, parallel enterprise-bankruptcy filings, and practical control of PRC assets, banks and subsidiaries. Treaties and judicial practice evolve; outcomes are counsel-grade. This wiki orients cross-border insolvency. Distressed M&A covers buying China assets out of distress. Claims filing still applies for PRC proceedings. Do not assume COMI folklore alone moves Shanghai title.
4 questions before you choose the route.
This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.
Where are the assets and subsidiaries?
Map.
MapForeign main proceeding recognised?
Recognition.
RecogLocal China filing needed?
Parallel.
LocalBuyer path vs claim path?
Distressed M&A related pages.
DealWorking rule: Map the regulated role before marketing or launch in China.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Does China apply UNCITRAL Model Law wholesale?
Do not assume full adoption — use current judicial practice with counsel.
Where is distressed M&A?
Open /distressed-manda-in-china.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.