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.
Joint and Several Liability Notices for Directors of Insolvent
Companies
The Finance Act 2020 provides Her Majesty s Revenue and
Customs (HMRC) with new powers to issue notices to directors,
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.
Joint and Several Liability Notices for Directors of Insolvent Companies
The Finance Act 2020 provides Her Majesty’s Revenue and Customs (HMRC) with new powers to issue notices to directors, shadow directors and certain other individuals connected to an entity (a ‘relevant person’) making them personally liable alongside the entity for its unpaid tax liabilities. These rules are targeted at arrangements that abuse insolvency procedures but