This article addresses the issue of corporate veil piercing, first giving a general overview of its theoretical underpinnings, with particular stress on English theory
and literature, given that the doctrine has its origins in common law. In this respect, the article also presents decisions in which the court applied this doctrine.
Further, the author provides an overview of Czech international insolvency law (as determined both by the Insolvency Act and by the Act on Bankruptcy and Composition). In this respect, he shows how elements of the corporate veil piercing doctrine are present in the Insolvency Act.
The article also presents the corporate veil piercing doctrine within the German legal environment, where it has a venerable tradition, especially in judicature, and discusses its codification in the 2008 MoMIG (Act on the Modernization of the German Limited Liability Company Law and the Prevention of Misuse.
Finally, the article considers the issue of how to determine the governing law for international bankruptcy proceedings pursuant to Ordinance No. 1346/2000. In this context, the above-mentioned legal norms from Czech and German law concerning corporate veil piercing are applied to international insolvency proceedings in which the governing insolvency law is either Czech or German.