This paper drawls on the experience of the authors during a TACIS project in Russia. Part of the project involved assisting Russian legal experts in drafting a law on the reorganisation of companies. The methodology adopted was split into three stages: identification of the concepts of reorganisation in different jurisdictions, the policy and economic context of the proposed reform and examination of the institutional background. At each of these stages it was necessary to discover the underlying cultural, economic and philosophical issues which were formative of laws in each of the five jurisdictions that were examined and offer a menu of possible solutions to the risk-balancing exercise which this area of law presents.