الإفــلاس التجــاري والإفــلاس المدنــي (أو الإعســار) في كل من التشريع اليمني والمصري والكويتي والإماراتي

Abstract

The majority of Arab legislation has been taken into bankruptcy by trade (individuals or commercial companies) in their trade laws, but they have differed in the introduction of civil bankruptcy (or civil insolvency.(

The purpose of this study is to clarify the meaning of commercial bankruptcy, civil bankruptcy (insolvency) and the difference between them in the various legislations, as well as the meaning of the bankruptcy of the debtor and the insolvency of the debtor and the difference between them. It also clarifies the meaning of the insolvent debtor, the insolvent debtor, Place of study (Yemeni, Egyptian, Kuwaiti, UAE).

The second topic was devoted to dealing with commercial bankruptcy and civil bankruptcy in Yemeni legislation. The second topic was devoted to dealing with commercial bankruptcy and civil insolvency in Egyptian legislation. The third topic was devoted to talk about commercial bankruptcy and civil insolvency in legislation. And in the fourth section dealt with commercial bankruptcy and civil bankruptcy (stone on the bankrupt debtor) in UAE legislation.

At the end of the research, I reached a set of conclusions and recommendations to raise the contradiction between the laws in comparison. I hope that this study will be the first step towards unifying the provisions of these laws.