Увреждащите действия на длъжника като предпоставка за правото на Павлов иск
The Fraudulent Actions as a Prerequisite for the Right to Actio Pauliana

Comparative Analysis Between Anglo-American and Bulgarian Law

Author(s): Yordanka Noneva-Zlatkova
Subject(s): Law, Constitution, Jurisprudence, Comparative Law, Roman law
Published by: Пловдивски университет »Паисий Хилендарски«
Keywords: Actio Pauliana; creditor’s rights; revocation action; fraudulent actions
Summary/Abstract: In the context of Actio Pauliana’s origin in the Roman law, his "transformations" were adopted by several countries in the continental legal system, including the Republic of Bulgaria. It is interesting to analyze the legal application of this action for annulment in countries belonging to the Anglo-Saxon legal system, focusing on the debtor's actions taken to harm the creditor and reduce his assets, serving as common security for his creditors. In the present material a comparative legal analysis of the legal nature and the features of the harmful actions performed by the debtor, as an element of the factual composition for the nascency of the creditor’s substantive right (Actio Pauliana).

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