Summary
United Kingdom, Company & Commercial, Competition & Antitrust, Insolvency & Restructuring, BCLP, National Security and Investment Act 2021 (UK)
Cancellation of debt a key element of most restructurings generally triggers taxable income. The German tax authorities had issued an administrative decree (the "Tax Restructuring Decree" - Sanierungserlass), however, declaring that, upon the satisfaction of certain requirements and conditioned on forfeiture of any loss carry forwards, the cancellation of debt income ("CODI") would not be taxed.