Prior to 1 st January, 2021, the cross-border recognition and enforcement of insolvency proceedings and judgements between the European Union (" EU") and the United Kingdom (" UK") was largely consolidated within the framework of the European Insolvency (Recast) Regulation (the " EIR") which generally attributed automatic recognition to such proceedings and/or judgements. Following the end of the Brexit transitional period on the 31 st December 2020, the EIR no longer applies to the UK. Consequently, insolvency proceedings opened in the UK after 31 st December 2020 will not benefit from automatic recognition. The EIR applies a set of common rules in determining the jurisdiction to open insolvency proceedings. Article 19 of the EIR