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ARTICLE · 18 DECEMBER 2020

Tax 2020: Developments Affecting Financial Restructurings

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During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial

United StatesInsolvency/Bankruptcy/Re-Structuring

Key Points

  • Joint and Several Liability Notices for Directors of Insolvent Companies
  • HMRC Preferred Creditor Status
  • DAC6
  • Updates to HMRC Guidance Relating to Company Residence and Permanent Establishments in Response to COVID-19
  • Updates to U.K. Anti-hybrid Rules
  • Brexit and the U.K. as a Holding Company Jurisdiction
  • Increasing Emphasis on Economic Substance
  • Removal of the Cayman Islands from EU Blacklist

Executive Summary

During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial restructurings and corporate reorganizations. There have also been other international developments this year that may have some bearing on international restructurings, which we discuss below.

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