Subordination of Tax Claims in Favor of the Treasury of a Foreign State in Cross-Border Insolvency

The master dissertation is devoted to the analysis of the procedure of considering revenue claims within the framework of cross-border bankruptcy procedures. The author discusses in detail the existing models of considering of such claims in the register of debtor's creditors' claims (including cross-priorities on the basis of ex post or ex ante reciprocity or on the basis of international treaties). Based on the results of the study, the author concludes that the institute of subordination of claims of the debtor's creditors may be used as a transitional model of considering of revenue claims, taking into account the broad interpretation of this concept, which implies lowering of such claims in the register of creditors' claims. At the same time, the paper proposes to establish a narrow interpretation of public policy when considering revenue claims.