SUMMARY
United Kingdom, Compliance Management, Insolvency & Restructuring, Litigation, Tax, BCLP, Corporate governance, Insolvency, HM Revenue and Customs (UK), Insolvency Service (UK), Corporate Insolvency and Governance Act 2020
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.